Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
Laoag City

Juana Cruz NPS Doc. No 123456-123

Complainant,
vs. For

Juan de la Cruz Violation of Article 267 of the Revised Penal

Respondent. Code (Kidnapping)

COMPLAINT AFFIDAVIT

I, Juana Cruz, the undersigned, of legal age, and a resident of Brgy. 01, Laoag City,
accuses Juan de la Cruz of the crime of Kidnapping, committed as follows:

1. At around 11:30PM of Saturday, January 01, 2020, I, Juana Cruz was passing by
Rizal Street, Laoag City going to my house at Brgy. 01, Laoag City.

2. While I was passing by the said street, I was holding a blue eco-bag on my left
arm and a cellphone on the left arm, walking in a moderate pace towards Ablan
Avenue, Laoag City.

3. That at Rizal Street, before I cross Ablan Avenue, the accused riding a white van
stopped right in front of me. The driver of the van got out and pointed a gun at me
saying, “aglugan ka dita van wenno patayen ka”.

4. That because I was afraid that he will kill me, I went inside the van.

5. That I learned that he took me inside the van in order to have sex with him but I
violently objected which made him furious to the point that he threatened again to
kill me by pointing the gun to me.

6. That upon entering the van, he drove. I asked him where are we going but he
refused to answer the question and he told me to keep quiet or else he will kill me,

7. That upon reaching Sta. Maria Elementary School, he slowed down because there
is an ongoing road project, I took the opportunity and opened the door of the van
and jumped out.

8. That because I knew that the police station is nearby, I ran very fast towards the
police station to report the incident.

9. He chased me but he cannot take me because he was currently chasing me with

the van thus, he cannot go out. That because of such situation, he drove towards
west.

10. He was of a large built, brown-skinned and of average height wearing a white t-
shirt and black short pants.
 11. That the police officers then immediately conducted a hot-pursuit operation but
unfortunately, he was not apprehended.

12. That I was afraid and crying when I arrived at the police station.

13. The following day, the police officers that conducted the investigation, showed
me pictures of persons and I positively identified him as the one who took me
because I remembered his face as well as the clothing that he wore is the same as
the clothing of the person who took me.

14. That person appeared to be Juan de La Cruz, a resident of Brgy. 02, Laoag City as
according to the police officers

15. That all of these statements are made voluntarily without any threat, force, or
intimidation.

16. To attest to the truthfulness of the foregoing, I, Juana Cruz, complainant,

voluntarily affixes my signature in this affidavit.

_________________________
Juana Cruz
Complainant

SUBSCRIBED AND SWORN to before me, in the city of Laoag City, this 2nd day of
January, 2020, the affiant exhibiting to me her Driver’s License No. 123456789 issued by
Land Transportation Office, Laoag City on 30th of November 2020 at Laoag City.

___________________________
Ruth Katherine P. Maala
Assistant City Prosecutor