REPUBLIC OF THE PHILIPPINES

OFFICE OF THE CITY PROSECUTOR

ILIGAN CITY

JUAN DELA CRUZ, Criminal Case No.: 20-012345

Plaintiff,

- versus - For: Serious Physical Injuries

PEDRO SANTOS,

Defendant.

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AFFIDAVIT-COMPLAINT

COMES NOW, the plaintiff, by the undersigned counsel, and unto this
Honorable Court, respectfully alleges:

1. That plaintiff is of legal age, Filipino citizen, working as a security guard in

Robinsons Mall and resident of 3rd east, Brgy. Tubod, Iligan City while the
defendant is also of legal age, Filipino citizen, unemployed and resident of
3rd street, Brgy. Balulang, Cagayan de Oro City, where he may be served
with summons;

2. That the defendant’s son, Pedrolito Santos, who resided in 2nd street, Brgy.
Tubod, Iligan City, was caught in a buy-bust operation in January 31,
2020;

3. That the defendant, without having any proof, accused the plaintiff to be
the informant who gave the tip to the police officers which led to the
arrest of defendant’s son and thereby planned to retaliate against the
plaintiff;

4. That in the evening of February 1, 2020, while the plaintiff was walking on
his way home, the defendant who was holding a rock, suddenly appeared
and confronted him;

5. That the defendant shouted “Tungod nimu kay nadakpan akong anak!’;

6. That the defendant suddenly threw the victim to the ground and hit the
plaintiff repeatedly in his left eye with the stone he was holding;
 7. That after hitting the plaintiff, blood oozed from his eyes and lower left
part of his forehead while shouting “Agay! Tabang!”;

8. That some of the bystanders and neighbors came to stop the commotion
and pulled away the defendant from the plaintiff;

9. That the plaintiff was immediately taken to the Gregorio Lluch hospital
where he was examined, treated and confined for 15days;

10. That due to the incident, the plaintiff suffered hemorrhage and
sustained several wounds in his head and forehead due to severe beating,
as evidenced by a medico-legal certificate provided by Doctor Willie
Ong, a copy of which is hereto attached as “Annex A”;

11. That said Doctor, in his opinion stated in the said medico-legal
certificate, said that the injuries sustained by the plaintiff will incapacitate
him for 30days and will need medical attention for the said span of time;

12. That hitting incident is evidenced by a memorandum police report

made by Police Lieutenant Colonel Cardo Dalisay, a copy of which is
hereto attached as “Annex B”;

13. That due to the injuries inflicted by defendant against the plaintiff,
the latter was incapacitated to go to work for more than 30 consecutive
days resulting to the diminution of his salary as evidenced by a letter sent
by his manager Robina Gokongwei, a copy of which is hereto attached
as “Annex C”; and

14. That this affidavit-complaint is executed to attest to the veracity of

the foregoing facts in order to file a criminal charge for serious
physical injuries under Art. 263, paragraph 4 of the Revised Penal
Code against the defendant.

RELIEF

WHEREFORE, premises considered, it is respectfully prayed unto this

Honorable Court that, after hearing, judgment be rendered in favor of plaintiff
and against the defendant, ordering the latter:

1. To pay moral damages;

2. To pay actual damages in the amount proven in court;
3. To pay the plaintiff the cost of the suit; and
4. Such other relief as the court may deem proper

Other just and equitable reliefs are likewise prayed for.

Iligan City, Philippines, March 3, 2020.

 ATTY. NORAJANNAH D. LANTUD
Attorney for Plaintiff
LANTUD LAW OFFICE
ND
2 floor, Abalos Bldg, Aguinaldo St., Iligan City
Roll No. 123456
P.T.R. No. 123456/ Iligan City/ January 10, 2020
I.B.P. No. 123456/ Iligan City/ January 10, 2020
MCLE Compliance No. 123456

SUBSCRIBED AND SWORN to before me, this 3rd day of March 2020.
The affiant, whom I identified through competent evidence of his identity,
personally signed the foregoing instrument before me and avowed under penalty
of law to the whole truth of the contents of said instrument.

ATTY. LENI ROBREDO

Prosecutor
Roll No. 34567
P.T.R. No. 123, 12/31/20, Iligan City
I.B.P. No. 234, 12/31/20, Iligan City