Republic of the Philippines)

Arayat, Pampanga )s.s.

x------------------------------x

AFFIDAVIT - COMPLAINT

I, MA. FRANCESCA CHANELLE AYSON, minor, Filipino with

residence address at 160 zone 4 arenas arayat pampanga under oath, hereby
depose and say, that:

1. I hereby formally charge __________, of legal age and with

residence address at __________________for the  crime of
Grave Threats, as defined by Article 282 of the Revised Penal
Code and penalized by paragraph 2 of the same Article;

2. On December 21, 2019, while my father and I were safely

traversing __________, we tried to pass a slow-moving vehicle
identified as ______ and being driven by herein respondent.

3. Thereafter, respondent exhibited aggressive behavior thru

dangerous driving methods and verbal insults towards my father.
In an attempt to avoid any altercation, my father opted to ignore
the respondent.

4. Upon arriving home, I received a threatening message from the

respondent thru facebook messenger saying that, and I quote
verbatim hereunder:

“Tigas ng tatay mo no. Tgnan nten tigas nya

paguwe nten ng arenas. Sya papatayin nmen”

Made as integral part of this Affidavit- Complaint is the screen

grabbed photo of the threatening facebook message herein
attached as “Annex A”.
5. The foregoing acts committed by the RESPONDENT squarely fall
within the purview of Article 281 of the Revised Penal Code
of the Philippines as penalized by paragraph 2 of the same
Article, to wit:

Art. 282. Grave threats. — Any person who shall

threaten another with the infliction upon the
person, honor or property of the latter or of his
family of any wrong amounting to a crime, shall
suffer:
X X X
2. The penalty of arresto mayor and a fine
not exceeding 500 pesos, if the threat shall
not have been made subject to a condition.

X X X

6. According to our existing laws and jurisprudence, the elements

of grave threats not subject to a condition are as follows: (i) that
the offender threatens another person with the infliction upon
the latter's person, honor or property, or upon that of the latter's
family, of any wrong; (ii) that such wrong amounts to a crime;
and (iii) that the threat is not subject to a condition. This felony
is consummated as soon as the threats come to the knowledge of
the person threatened (Paera vs. People, G.R. No. 181626, May
30,2011, citing People vs. Villanueva, Nos. 3133-3144- R, 27
February 1950,48 O.G. 1376 (No.4), 1381).

7. Anchoring on the foregoing, the first element is present in this

case. Respondent threatened to inflict upon my family any wrong
by saying that he will kill my father.
 8. The second element is likewise present. The threatening
facebook message could amount to homicide or murder,
depending on the circumstances.

9. Lastly, the threat of respondent, was apparently not subject to a

condition.

10. Accordingly, I am executing this Complaint-Affidavit for the

purpose of attesting the truth of the foregoing statements and to
charge the RESPONDENT _______ with the crime of Grave
Threat as defined by Article 282 of the Revised Penal Code and
penalized by paragraph 2 of the same Article.

IN WITNESS WHEREOF, I have hereunto set my hand this 3rd day of

December 2019 in Arayat, Pampanga

MA. FRANCESCA CHANELLE AYSON

Affiant

SUBSCRIBED AND SWORN to before me this __ day of December, 2019 at

Arayat, Pampanga.

Notary Public

Doc. No. ____;

Page No.____;
Book No. ____;
Series of 2019