REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE PROVINCIAL PROSECUTOR
CITY OF MALOLOS, BULACAN

Ronna H. Adolfo,
Complainant,

NPS Docket No.

– versus – For: Violation of Par. 2
Article 266-A of the RPC
(Rape through Sexual
Assualt)

Armando Estevez,
Alejandro Aldama,
Louie Montemayor,
Elizabeth Zaragosa.

Respondent.
x---------------------------------------------x

COMPLAINT- AFFIDAVIT

Comes now, Ronna H. Adolfo, after being duly sworn in

accordance with law, hereby deposes and state that:

THE PARTIES

1. Complainant is Ronna H. Adolfo (“Complainant”, for

brevity), 15 years old, Filipino, single, and with an address at
321 Rizal St., Poblacion, Bocaue, Bulacan. He may be served
with summons, notices and other legal processes of this
Honorable Office through his legal counsel Refugees Law
Firm Unit 4, 2 floor The New Reich Building, Brgy.
Guinahawa, City of Malolos, Bulacan;

Respondents are the following where they may be served

with summons, notices and other legal processes of this
Honorable Office, respectively:

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 a. Armando Estevez, 15 years old, Filipino, single and with
an address at 32 Juan Luna St., Sulucan, Bocaue, Bulacan;

b. Alejandro Aldama, 16 years old, Filipino, single and

with an address at 98 J.P Laurel St., Bunlo, Bocaue,
Bulacan;

c. Louie Montemayor, 17 years old, Filipino, single and

with an address at 78 E. Delos Santos St., Turo, Bocaue,
Bulacan;

d. Elizabeth Zaragosa, 16 years old, Filipino, single and

with an address at 56 A. Mabini St., Lolomboy, Bocaue,
Bulacan.

THE FACTS OF THE CASE

2. The undersigned accuses Armando Estevez, Alejandro

Aldama, Louie Montemayor or Elizabeth Zaragosa of the
crime of Rape though Sexual Assault in consonance with the 2nd
Paragraph of Article 266-A of the revised Penal Code, committed as
follows:

a. That on the 28th of December 2019 around 8:30 in the

evening I went to the house of my best friend, Elizabeth
Zaragosa, for the celebration of her 16th birthday. That
since her parents were not around as they are both
Overseas Filipino Workers, only her aunt was left with her.
However, on that night her Aunt was not around as she
had to attend to a Christmas Party at Subic, Zambales.

b. That Elizabeth Zaragosa also invited our friends

Armando Estevez, Alejandro Aldama, Louie
Santiago. Elizabeth had prepared a small banquet for us.
About an hour after we have finished our supper, the
birthday celebrant started to bring out 3 bottles of alcohol,
to wit, a liter Fundador Ultra Smooth and 2 Emperador
Light (Empi) which were all gifts of the client of Elizabeth’s
Aunt and requested us to have a drinking spree. None us
refused such request;

c. We drank most of what we can until we were left with

only half bottle of Empi. Everybody at that time was so
noisy and crazy when it’s their turn for sharing stories
about anything them want. I was seated beside my best
friend, Elizabeth Zaragosa, I told her that I was no

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longer feeling well as the left part of my body was so weak
and I had an intense headache.

d Elizabeth Zaragosa told me to go to her room upstairs

and take a rest while they will finish the last bottle of
alcohol. I was assisted to the said room by Elizabeth while
Armando Estevez and Alejandro Aldama both carried
me upstairs as I can no longer manage to walk or even
stand on my own;

e. When I was laid on the bed, Armando Estevez

Alejandro Aldama and Elizabeth Zaragosa told me
that they will go downstairs to finish their drink and tidy
the sala where the drinking spree was held as it was
already a mess. When they all left the room, I immediately
went to sleep;

f. While asleep, I felt a discomfort around my vagina as if

something was being inserted. When I partially raised the
blanket covering my face, it was dark. The lights that my
friends left were no longer on, except a night light near the
door.

g. Without completely removing the said blanket and

pillow was violently throw unto my face and was pressed
against my head. I had difficulty in breathing, I tried to
shout but failed to so I felt so weak and suffering from a
headache. All my attempts to repel my attacker were all
rendered futile as I was definitely overpowered;

h. After a few seconds of struggle with the said attacker, I

passed out;

i. I woke up early in the morning, it was dawn and very

quiet. I immediately thought what had happened last night
might only be just a wild nightmare. I saw everybody,
Armando Estevez, Alejandro Aldama, Louie
Montemayor and Elizabeth Zaragosa, around my bed
all asleep;

j. I then felt pain on my vagina, somehow come to what I

have felt last night. I removed the blanket covering my
lower body, to my shock was all bare downstairs and there
are some few stains of blood on the bed sheets as well as on
the inside part blanket;

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 k. I shouted as load as I can and yelled “What have you
done to me?” Everybody around me was awaken. I then
immediately started crying, Elizabeth, Alejandro and
Louie suddenly went outside while only Armando stayed
with me and asked me, “What happened?” I then asked
Armando to call my parents and tell them to fetch me;

l. I told my parents the pain that I felt on my vagina and

went swiftly went to the hospital to be checked. The
physician concluded that a foreign object was introduced
unto my vagina, possibly an erect penis or any object;

(a copy of the Medical Certificate is hereby attached

herewith as …)

4. Due to what had transpired on that unfortunate night, it is

uncertain as to who among the respondents Armando Estevez,
Alejandro Aldama, Louie Montemayor and Elizabeth
Zaragosa should rightfully be held criminally liable for the crime
of Rape in accordance with Paragraph 2 of Art. 266-A of the Revised
Penal Code (Rape through Sexual Assault) as the complainant have
reasonable belief that one, if not all had violated her considering
the following points:

a. Armando Estevez, the current suitor of the complainant.

The most valuable player in the high school basketball
league and a childhood friend of the complainant;

b. Alejandro Aldama, the “ex” or the former suitor whom

the complainant dumped in favor of Armando Estevez.
The best friend of Armando and had secretly expressed
his intention to the complaint to be together again as a
young couple;

c. Louie Montemayor, the crush of the complainant, the

bad boy among the group as he already underwent a
diversionary program of the DSWD for committing
rape thru sexual assault against the daughter of their
kasambahay;

d. Elizabeth Zaragosa, the best friend of the complainant,

since their childhood, she and the complainant were
very close and treated each other as sisters, though the
complainant observed that Elizabeth would often times
be very “boyish” and would tend to show sweetness to
her.

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 5. It is therefore, requested from the Honorable Office of the
Provincial Prosecutor to file a case against herein the respondents
Armando Estevez, Alejandro Aldama, Louie Montemayor
and Elizabeth Zaragosa with the crime of Rape in accordance
with Paragraph 2 of Art. 266-A of the Revised Penal Code (Rape
through Sexual Assault), as amended by R.A 8353 or the Anti-rape
Law of 1997 and be brought to trial;

6. That this complaint was made to tell the truth, the whole truth
and nothing but the truth and ultimately prove the criminal
liability of the respondents, Armando Estevez, Alejandro
Aldama, Louie Montemayor and Elizabeth Zaragosa;

7. With the indulgence of the Honorable Office of the Provincial

Prosecutor, the complainant is more than willing to adduce further
pieces of evidence, documents or testimonies to be able to prove the
guilt of the said respondents.

AFFIANT FURTHER SAYETH NOT.

IN WITNESS WHEREOF, I have hereunto affixed my

signature this 15th day of January, 2020 at the City of Malolos,
Bulacan.

Ronna Adolfo
Affiant

SUBSCRIBED AND SWORN to before me this ____ day of

______________, 2020 at _______________. I further certify that I
have personally examined the affiant and that I am satisfied that
she has executed this Complaint-Affidavit and has understood the
contents hereof of her own personal knowledge.

Hon. Maricel Continuado

Assistant Provincial Prosecutor

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