Republic of the Philippines

Department of Justice
Provincial Prosecutors Office of Dumaguete City
Dumaguete City

B and C,
Complainants, Criminal Case no: 0001

-versus-

A and D, For: Estafa

Respondents.
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COMPLAINT – AFFIDAVIT
I, B, of age, married, and a resident of Sibulan, Dumaguete City, after having been duly
sworn to according to law depose and say:
That I am legally married to A, in a religious ceremony before Rev. Juan Tomas at the
Parish Church of Tokyo, Japan on June 17, 2009, Xerox copies of the aforesaid marriage
contracts are hereto attached as Annexes “A” and “B”, forming integral parts of this affidavit;
After our marriage, I was led to believe by my wife of her total concern, love and
devotion to me valid. In turn, I lavished her with all the material comfort at my command. As a
token of my love and unfailing trust, we decided to reside in the Philippines where she is more
comfortable with and close to her relatives.
At the start of our marriage, we want back here in Sibulan, Dumaguete City with my
father, C. Me and my father bought a piece of land owned by D and built a house for my
conjugal home with my wife since she is unemployed and no money to finance both.
Since, my father and I are already Japanese citizens, we cannot acquire land here in the
Philippines. As the foundation of trust in a marriage, my wife was to be the owner of the piece of
land that I and my father financed as to appear in the title to be processed by D.
Shortly thereafter the purchase of the land from D, we agreed to build a mansion. I and
my father both financed the mansion contributing 1,000,000.00 php each, since then again, my
wife had no means of such amount. A deed of sale was to be executed in favor of me, my father
and my wife for the mansion to be processed by D.
 After quite some time, my wife and I were always fighting until finally she decided that
she doesn’t want to live with me and my father anymore. My wife, A, together with D, went to a
lawyer to file for another deed of sale in favor of my wife only. She then went to the police to
claim that she is the sole owner of the house and the lot from the new deed of sale that both she
and D procured. She then also claimed that my father and I were merely airbnb tenants and that
we were overstaying.
That D has known that the deed of sale of the mansion was to be named by me, my father
and my wife. Moreover, it was me and my father whom he received payment from the purchase
of land and the house. In which, he knew the situation, concerning the prohibition of the
purchase of land in the Philippines, which gave rise to the agreement that the title was to be
named to the only Filipino citizen amongst us, the buyers.
D, conspiring by agreeing to A, my wife, to procure another deed of sale for the mansion
to be solely in the name of her for the purpose of deceit towards the police officers. Alleging that
she is the sole owner of the mansion and the parcel of land in which the mansion was built.
Alleging further that I and my father was mere tenants in which were overstaying thus needed a
course of action which is eviction.

That I and my father, C, are formally charging my wife, A and D of the crime of Estafa
against them.

City of Dumaguete, Philippines, March 5, 2020.

B and C
Complainant

SUBSCRIBED and SWORN to before me, the undersigned prosecutor, this 5th day of
March, 2020 in the City of Dumaguete, Philippines. I hereby certify that I have personally
examined the above-named affiant and that I am satisfied that the foregoing statements were
given by him voluntarily and of his own free will.

Atty. John Arjay Onia

Assistant Prosecutor