Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch ___, Makati City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- R-MKT-19-0001-CR
For: Kidnapping defined and
penalized under Article 267(4)

JUAN DELA CRUZ y GAMBOA,

(No. 11-A Zenaida Street,
Poblacion, Makati City)
Accused.
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INFORMATION

The undersigned Prosecutor accuses Juan Dela Cruz y Gamboa of the

crime of kidnapping defined and penalized under art. 267(4), committed as
follows:

On the 24th day of July 2019, in the City of Makati, the

Philippines, accused, a private individual, did then and there
willfully, unlawfully and feloniously, take, kidnap and carry
away MARIA DELA CRUZ y LARA, 10 years old, a minor,
for the purpose of permanently separating said minor child from
CLARA DELA CRUZ y LARA and JOSE DELA CRUZ y
LORO, parents of said child, detaining her away from home
and depriving her of her liberty.

CONTRARY TO LAW.

SHAILA LYN G. GUERRERO

Assistant City Prosecutor

This is to certify that the foregoing information is filed pursuant to the

REVISED RULES OF CRIMINAL PROCEDURE, the accused not having
opted to avail of his right to a preliminary investigation and not having
executed a waiver pursuant to the REVISED PENAL CODE, Art. 125. I
further certify that this Information is being filed with this prior approval of
the City Prosecutor.

SHAILA LYN G. GUERRERO

Assistant City Prosecutor
SUBSCRIBED AND SWORN to before me this 30th day of July 2019 at
Makati City.

EUGENE GERARD V. INOCENCIO

Senior Deputy City Prosecutor

Witnesses:
1. Clara dela Cruz, Jose Dela Cruz and Maria dela Cruz
No. 12 Zenaida Street, Poblacion Makati City

2. And others