REPUBLIC OF THE PHILIPPINES)

Ingud a Piyagma City ) S.S.

AFFIDAVIT-COMPLAINT

I, NADINE A. LUSTRE, 35 years old, married, and a resident of Block

30, Lot 11, Guwapa Street, Phase 4, V&G Subdivision, Ingud a Piyagma City,
after having been duly sworn to in accordance with law, hereby deposes and
says THAT:

1. I am the mother of ISSA A. LUSTRE, 12 years old, enrolled as

a Grade Six Pupil at Liceo Del Sarimanok, Ingud a Piyagma City.
A Machine copy of the both certificate of ISSA A. LUSTRE is
hereunto attached and made as an integral part hereof as Annex
“A”;
2. Last January 21, 2020, on or about 9:30 PM, my daughter ISSA
A. LUSTRE with her cousin KATHRYN BERNARDO, asked
for my permission to attend the funeral of their grandmother,
the late ROMINA AZUCENA.
3. Because of the assurance of KATHRYN BERNARDO that she
will be looking and taking care of ISSA, I allowed them to go
ahead of me as I was also planning of going there and that the
place of the wake was only few houses away. While I was on my
way to the wake, I heard a commotion at a near distance, which
was followed by shouting and crying so I hurriedly went to the
place. Upon my arrival, I saw my daughter lying in the ground,
bathe in her own blood, with KATHRYN BERNARDO
hoarsely shouting and crying for help. Trembling and lost for
words, I asked KATHRYN BERNARDO who was the culprit
of the crime which she answered without hesitation as one
named JAMES Q. REID. I asked her where JAMES is and she
replied “miyakapalagoy dn ante” (he already fled auntie). Crying
for help, I asked and begged people around us to help me bring
my daughter to the nearest hospital which was responded to
with haste by DANIEL PADILLA and other relatives who
 were around. The sworn statement of DANIEL PADILLA is
hereunto attached and made an integral part of this complaint
as Annex “B”;
4. Upon arrival at the IAP City Hospital, DR. BEA ALONZO,
immediately attended my daughter who were barely breathing
and after a thorough examination, declared her dead. The
medical case report, the NSO death certificate and a
certification from the City Civil Registrar of ISSA A. LUSTRE
is hereunto attached and made an integral part of the complaint
as Annex “C”, “D” and “E”, respectively;
5. While at the hospital, I inquired KATHRYN if the said JAMES
Q. REID was the same JAMES who is our neighbour and who
came to our house earlier that day to borrow money from me
which she positively identified as the same person. The sworn
statement of KATHRYN BERNARDO is hereunto attached
and made an integral part of this complaint as Annex “F”;
6. I denied the request of said JAMES Q. REID because of his
notorious character in our neighbourhood as a drunkard,
gambler and without a permanent job and that after the said
refusal to lend money, he mumbled and uttered to me that I
would surely regret my decision which statement I took granted.
7. I immediately reported the stabbing incident on or about 12:00
o’clock midnight at the Sarimanok Police Station which is the
nearest police station. The original copy of the excerpt of the
police blotter duly issued by Senior Police Inspector CARDO
DALISAY of Sarimanok Police Station is hereunto attached
and made as an integral part hereof as Annex “G” of the
complaint;
8. I am therefore executing this affidavit freely and voluntarily in
support of my intent to file a case for MUDER and/or the
appropriate criminal case against JAMES Q. REID, who is 33
years of age and a resident of Block 30, Lot 9, Guwapa Street,
Phase 4, V&G Subdivision, Ingud a Piyagma City.
 IN WITNESS WHEREOF, I have hereunto set my hand this 25th day of
January, 2020 at Ingud a Piyagma City, Philippines.

NADINE A. LUSTRE
Affiant

SUBSCRIBED AND SWORN to before me this 25th day of January 2020,

at Ingud a Piyagma City, Philippines and I FURTHER CERTIFY that I have
personally examined the affiant and I am satisfied that he/she has read and
personally understood the contents of her foregoing “AFFIDAVIT-
COMPLAINT”.

ANNE CURTIS
Prosecutor II
Roll No. 51379-2006
IBP No. 808787-1/3/19
PTR No. 4124-1/3/19; Ingud a Piyagma
MCLE compliance III no. 0013601
Issued on April 2, 2019