Republic of the Philippines

Department of Justice
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
Angeles City, Pampanga

PEOPLE OF THE PHILIPPINES

Criminal Case No. 003
-versus- For: Kidnapping and
serious illegal detention
(Violation of Art. 267 of
the RPC)

BRANDO MARTIN y ROQUE,

Accused.

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COMPLAINT-AFFIDAVIT
I, PATRICIA GARCIA , 18 years of age, single, residing at 1322 Lanzones
Street, Clakview, Barangay Malabanias, Angeles City, after having been sworn to in
accordance with law, do hereby depose and state:

1. That BRANDO MARTIN y ROQUE, had been my friend since

childhood and had started to court me last year of March;

2. That despite of his persistence and efforts, I refused to accept him

as boyfriend for I see him only as a friend;

3. That on December 23, 2019, at around 8 o’clock in the evening, he

visited me at home and asked that I come with him to Baguio for a
week-long Christmas vacation, to which I refused for I wished to
spend the vacation with my family;
4. That on December 27, 2019, at around 5 o’clock in the afternoon,
as I walked home from JJ Supermarket, BRANDO MARTIN
suddenly pulled over his car and asked me to get in so we could go
to AUF hospital with haste for, according to him, my mother was
sent to the emergency room.

5. That due to sudden panic and fear for my mother’s life, I

immediately got in his car, which was heavily tinted; then
BRANDO MARTIN put a cloth to my face and I lost consciousness;

6. That I woke up in a not well-lighted room and saw myself tied up

to the bed as BRANDO MARTIN approached me with a plate of
food. He said that we were in their old house in Baguio and that he
just wanted me to stay with him for a few days;

7. That BRANDON MARTIN held me tied to the bed for six days
despite me consistently begging for my freedom. He didn’t touch
me but only brought food and asked that I finally consider him as
boyfriend if I really wanted my freedom;

8. That upon saying that I would accept him as boyfriend, he was

ecstatic and immediately removed the rope tied on my arms and
legs;

9. That as soon as my hands were free, I grabbed a nearby vase and

immediately hit his head knocking him out, and thereafter I ran
out for help.

10. That a group of women saw me running out of the house and
assisted me to the nearest police station;

11. That upon hearing what I told them, the police rushed into the
house to apprehend BRANDO MARTIN, but he was no longer there
when they arrived for he had escaped;

12. The foregoing acts committed by the accused squarely fall within
the purview of Article 267 of the Revised Penal Code of the
Philippines, to wit:

“Article 267. Kidnapping and serious illegal detention. – Any

private individual who shall kidnap or detain another, or in any
other manner deprive him of his liberty, shall suffer the penalty of
reclusion perpetua to death: 1. If the kidnapping or detention shall
have lasted more than five days. xxxx”
 13. I am executing this complaint-affidavit in order to file a case of
Kidnapping against BRANDON MARTIN y ROQUE.

AFFIANT FURTHER SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto set my hand this 06th day of January
2020 at Angeles City.

PATRICIA GARCIA
Affiant

SUBSCRIBED AND SWORN to before me in Angeles City this 14th day of

January 2020. I hereby certify that I have personally examined the above named
affiant and that I am satisfied that the foregoing statement were given by him
voluntarily and of his own free will.

Raffy Cruz
Assistant City Prosecutor