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REPUBLIC OF THE PHILIPPINES)

PROVINCE OF MAGUINDANAO )S.S.

CITY OF COTABATO

AFFIDAVIT OF COMPLAINT

I, IVANA Y. MAYLAWIT, of legal age, Filipino, single, with


home address at 4 Love Street, Doggy Village, Rosary Height 8,
Cotabato City, after being sworn to in accordance with law, hereby
depose and state that:

1. I know the person of respondent PO2 CARDO M. DALISAY,


who is a resident of 11 Care Street, Doggy Village, Rosary
Height 8, Cotabato City;

2. Respondent is a police officer assigned at the Police


Station 2 of Cotabato City;

3. Respondent has cajoled a loan from me in the total amount


of One hundred fifty thousand pesos (P150,000.00) with a
corresponding monthly interest of Ten thousand pesos
(P10,000.00) in exchange for sex. (A photocopy of a bank
deposit slip showing a deposit of the amount of Seventy
thousand pesos (P70,000.00) in the Bank of the Philippine
Islands account of respondent is hereto attached as Annex
“A”);

4. Respondent owes me the total principal amount of One


hundred fifty thousand pesos (P150,000.00) plus the
accumulated twelve months of unpaid interest in the
amount of One hundred twenty thousand pesos
(P120,000.00);

5. Between the months of May to August 2018, respondent


and I had several sexual encounters;

6. From the time that the interest on the said loan fell due,
respondent had, on a number of occasions during the
aforesaid period, succeeded in coaxing me into having sex
with him instead of paying;

7. I warned respondent that I will file formal charges against


him if he continues to ignore the payment of his loan
obligation;

8. Sometime in 29 July 2019, respondent sent via Facebook


messenger a two-minute video of the two of us having sex.

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(A DVD containing a copy of the video is herewith
submitted as Annex “B”);

9. Respondent has recorded the said sex video without my


knowledge and consent;

10. I am shocked, humiliated and disturbed that respondent


has made a video recording of me while engaged in a
private and intimate act;

11. Respondent has threatened to spread or cause the spread


of the said sex video if I proceed with the filing of formal
charges against him. (A screenshot of the conversation
between me and the respondent is hereto attached a
Annex “C”);

12. Upon consultation with my lawyer, I understand that the


acts of the respondent qualify as a violation of Section 4
(a) of Republic Act No. 9995 or the Anti-Photo and
Voyeurism Act of 2009;

13. Section 4 (a) of R.A. No. 9995 reads:

“Sec. 4. Prohibited Acts. —It is hereby prohibited


and declared unlawful for any person:

(a) To take photo or video coverage of any person or


group of persons performing sexual act or any similar
activity or to capture an image of the private area of a
person/s such as the naked or undergarment clad
genitals, public area, buttocks or female breast
without the consent of the person/s involved and
under circumstances in which the person/s has/have
a reasonable expectation of privacy;

xxx”

14. The aforesaid acts of the respondent seriously compromise


his character and standing in the Philippine National Police
in such manner as to indicate vitiated or corrupt state of
moral character which shows his unworthiness to remain in
the police service;

15. I am executing this affidavit to attest to the truth of the


foregoing facts and for the purpose of filing an
administrative complaint against PO2 CARDO M.
DALISAY of Police Station 2 Cotabato City for Conduct
Unbecoming of a Police Officer pursuant to Rule 21,

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Section 1 (5) of the Revised Rules of Procedure Before the
Administrative Disciplinary Authorities and the Internal
Affairs Service of the Philippine National Police.

16. Further, I hereby declare under oath that this complaint is


not a form of harassment or retaliation and the supporting
evidence/documents herein are authentic and from
verifiable source and fully aware of the consequences of
being held liable for perjury in case of false or
misrepresentation of this affidavit.

IN WITNESS WHEREOF, I have hereunto affixed my signature


on the 16th March 2020 in Cotabato City, Philippines.

IVANA Y. MAYLAWIT

Affiant

SUBSCRIBED and SWORN TO BEFORE ME, this 16th day of


March 2020, complainant exhibiting to me her Residence Certificate
No. RR2345XX09 issued at Cotabato City on 12 January 2020.

HOMER B. SIMPSON
Roll No. 49280

PTR No. 0754821 07/15/2020

IBP No. 234890 07/09/2020

MCLE Compliance IV-0002456-09/27/2019

Cell Phone No. 0917-0906289

MC Squared, Einstein Suites, E. Guttierrez Ave., Cotabato City

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CERTIFICATION

I hereby certify that I have personally examined the Affiant and


that I am satisfied that she voluntarily executed and understood her
Affidavit.

HOMER B. SIMPSON
Roll No. 49280

PTR No. 0754821 07/15/2020

IBP No. 234890 07/09/2020

MCLE Compliance IV-0002456-09/27/2019

Cell Phone No. 0917-0906289

MC Squared, Einstein Suites, E. Guttierrez Ave., Cotabato City

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