Republic of the Philippines

Department of Justice
OFFICE OF THE CITY PROSECUTOR
Batangas City

Adelina Borbe
Complainant. Criminal Case No.xxxx
v. FOR: OTHER CASES OF ARSON
PD1613, Sec.3 (2)
Rolando Buela, Sarmelito Buebos,
Dante Buebos and Antonio Cornel
Accused.

COMPLAINT AFFIDAVIT
That I , Adelina Borbe, of legal age, married, Filipino and a resident of Barangay
Montecillo, Sariaya, Quezon, after duly sworn to according to law hereby depose and
say:

1. On September 2015, the Laurel’s left to me the administration and preservation

of their property located at Hacienda San Miguel, Montecillo, Sariaya, Quezon.
As such, they donated to me a small part of the their lot so I can put up my own
house;

2. My husband built a nipa hut since we cannot afford to build a concrete one and
since 1991 this nipa hut became our own dwelling house until now;

3. That On January 1, 2020 around 3:00 o’clock in the morning, I was inside the
house and watching over my sick child while my husband was in his province in
Albay since late December, attending for his parents who are now both bed
ridden;

4. When I was lying down when I heard some noise around the house.
5. At first, I thought it was just random drunk people just passing by near our house.
Until it became unusual noises and I heard some laughter and this time the
source of the noises became louder as if the source of the noise were inside my
fences.

6. I was frightened because of the idea that my husband was not there and my child
was sick;

7. That the noises is still on going, so I slowly got up and looked through the
window and I saw Rolando Buela, Sarmelito Buebos, Dante Buebos and Antonio
Cornel, Jr. congregating in front of my hut. I knew them since they were the one
who used to trimmed the grasses in the hacienda;

8. That I immediately went out, then I saw the roof of my nipa hut already on fire. I
shouted for help. But instead of helping me to put out the fire, the four fled. And
then I ran inside to get my sick child;

9. That since my house was nuilt in nipa, the fire almost consumed it in just a matter
of time;

10. That Olipiano Berjuela, came to rescue together with other men and after we put
out the fire, I went to the house of my brother Pepito Borbe together with my
daughter, and spent therein until our nipa being consumed by the fire will be
restored;

11. That I believed that the four persons I saw that time were the one who put the
fire. And that ever since it happened, I was not able to see them again passing
by near the hacienda.
 12. That all the elements to constitute arson under PD1613 were present, namely:1)
intentional buring, 2) What intentionally burn is inhabited place or dwelling;

13. I am executing this affidavit to attest to the truth of the foregoing facts and for the
purpose of charging the accused with the crime of other cases of arson
punishable under Article 322, Revised Penal Code as amended by P.D 1613.

City of Lucena Philippines. January 2020.

(sgd) Adelina Borbe

COMPLAINANT

SUBSCRIBED AND SWORN to before me, the undersigned prosecutor, this 20 th day of
January, 2020, in the City of Lucena, Philippines.

(Sgd.)

ASSISTANT CITY PROSECUTOR

The undersigned Prosecutor certifies that he personally examined the affiant and
satisfied that he voluntarily executed and understood his complaint-affidavit.

(Sgd.)
ASSISTANT CITY PROSECUTOR