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Republic of the Philippines )

Province of Laguna ) S.S.


City of San Pablo )

COMPLAINT – AFFIDAVIT

I, Wilfredo A. Hernandez, Filipino, 35 years old, single, and a resident of No. 34


Boomtown St., San Pablo City, Laguna, Philippines, after being sworn to in accordance
with law, depose and state:
1. I am the brother of Alberto A. Hernandez, 37 years old, a Barangay Peace and
Security Officer (BPSO) of Barangay Santiago II, San Pablo City, Laguna. A
machine copy of the Identification card of Alberto A. Hernandez attached and
made as an integral part hereof as Annex “A”;

2. Last December 3, 2019, on or about 12:00 Midnight, I was awakened by our


neighbor Randy Borromeo who arrived shouting frantically in front our house
calling my name. When I went outside and asked him why in the middle of the
night he is disturbing me, he said directly “Fredo ung kapatid mo nabaril, ayon sa
kanto nkahandusay!” (Fredo your brother was shot, he was lying there at the
corner);

3. Shocked with the news brought by Randy, I hurriedly ran to the place where Randy
said where my brother, Alberto, was. Randy followed me. Not far from our house,
about 50 meters, I saw my kuya Alberto lying in the ground, bathe in his own blood,
with a gun close to his right hand. Trembling and lost for words, I asked Randy—
who shot my brother, which he answered without hesitation as one named Jose
Sison. I asked him where Jose is and he replied “ayon tumakbo na” (he has already
fled). As I held my kuya Alberto in my arms crying, I told Randy to go to the
barangay hall, which is a few meters away, and ask for help to bring my brother to
the nearest hospital to call a police at the nearest police station. Randy quickly ran
towards the barangay hall and after a few minutes, police officers arrived, closely
followed by the ambulance. Mario Reyes, the ambulance driver, together with the
other BPSO responded;

4. Upon arrival at the San Pablo City Hospital, Dr. Carlo Velez immediately attended
my brother and after a thorough examination, declared him dead on arrival. The
medico-legal autopsy report and the NSO death certificate of Alberto A. Hernandez
is hereunto attached and made as an integral part of this complaint as Annex “B”
and “C” respectively;

5. While at the hospital, I asked Randy if he is sure that Jose Sison is the culprit. He
said “oo Fredo, nakita ko pa nga sya na tumakbo” (yes Fredo, I even saw him
running with the gun on his hand). The sworn statement of Randy Borromeo is
hereunto attached and made as an integral part of this complaint as Annex “D”;

6. Unexpectedly, Mario Reyes approached us and said “Fredo nakita ko mismo nung
binaril ang kapatid mo. At tama si Randy, si Jose nga ang bumaril sa kanya” (Fredo
I actually saw the incident when your brother was shot. And Randy was right, Jose
was the one who shot him). The sworn statement of Mario Reyes is hereunto
attached and made as an integral part of this complaint as Annex “E”;

7. I am therefore executing this affidavit freely and voluntarily in support of my intent


to file a case for MURDER under Article 248 of the Revised Penal Code against
Jose B. Sison, who is 33 years of age and a resident of No. 29 Pampanga St.,
Barangay Santiago II, San Pablo City, Laguna.
IN WITNESS WHEREOF, I have hereunto set my hand this 8th day of December,
2019 at San Pablo City, Laguna, Philippines.

WILFREDO A. HERNANDEZ
Affiant

SUBSCRIBED AND SWORN to before me this 8th day of December, 2019 at San
Pablo City, Laguna, Philippines and I FURTHER CERTIFY that I have personally
examined the affiant and I am satisfied that he has read and personally understood the
contents of his foregoing “Complaint-Affidavit”.

CRISTOBAL RIMANDO
Prosecutor II
Roll No. 54321-9876
IBP No. 246810-1/3/12
PTR No. 1234567-1/3/12; Laguna
MCLE Compliance III No. 0036912
Issued on April 11, 2011

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