Republic of the Philippines )

Province of Leyte ) S.S.

Municipality of Tolosa )
x-------------------------------------x

COMPLAINT-AFFIDAVIT (IN JUDICIAL AFFIDAVIT FORM) OF

PRIVATE COMPLAINANT SUSAN R. DE LA CRUZ

I, SUSAN R. DE LA CRUZ of legal age, Filipino, married,

residing at San Miguel St., Brgy. Poblacion, Tolosa, Leyte,
Philippines, after having been sworn to in accordance with the law, do
hereby depose and say:

That Atty. Remy R. Trinidad is the counsel who conducted and

supervised my examination at her office at the G/F Uytingkoc
Building, Avenida Veteranos, Tacloban City, Philippines;

That the questions are asked in the English language which I

speak and fully understand; and

That I am answering the questions herein fully conscious that I

do so under oath and that I may be criminally liable for false
testimony or perjury.

1. Q: Please state your name, age and personal circumstances.

A: I am Susan R. de la Cruz, 50 years old, Filipino, married,
and a resident of San Miguel St., Brgy. Poblacion, Tolosa,
Leyte, Philippines.

2. Q: Do you swear to tell the truth and nothing but the truth?
A: Yes, attorney.

3. Q: Why are you here in this office?

A: I am here to file a formal complaint against Apolinario “Jojo”
M. Laroa, Jr., 25 years old, Filipino, single and a resident of
Brgy. San Vicente, Tolosa, Leyte, Philippines for the killing of
Vince R. de la Cruz.

4. Q: Do you personally know the victim in this case, Vince R. de

la Cruz?
A: Yes, he is my son.

5. Q: When did the killing incident occur?

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 A: It occurred on October 6, 2020 at around 7 o’clock in the
evening.

6. Q: Where did it happen?

A: At the Laroa’s residence located at Brgy. San Vicente,
Tolosa, Leyte.

7. Q: On that particular time and date, where were you?

A: I was at home with my husband.

8. Q: How did you come to know of the killing incident?

A: My friend, Edith S. Ty, who was also at the Laroa’s
residence, called to tell me that my son was being rushed to the
Leyte Provincial Hospital after being stabbed by Jojo.

9. Q: What did you do next, if any?

A: My husband and I immediately proceeded to the Leyte
Provincial Hospital where my son Vince was already declared
dead on arrival.

10. Q: Do you have any proof of such death?

A: Yes, I have the Post Mortem Report and Death Certificate.
(Attached to this Judicial Affidavit is the photocopy of the Post
Mortem Report marked as “Exhibit A” and the photocopy of the
Death Certificate of Vince R. de la Cruz marked as “Exhibit B
and series”)

11. Q: Do you personally know the respondent in this case,

Apolinario “Jojo” M. Laroa, Jr.?
A: Yes, attorney.

12. Q: How is he personally known to you?

A: He was my son’s high school batch mate at Tolosa National
High School.

13. Q: Do you have anything else to say, Mrs. de la Cruz?

A: Nothing more, attorney.

IN WITNESS WHEREOF, I have hereunto affixed my signature

this 18th day of October, 2020 in Tacloban City, Leyte, Philippines.

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 SUSAN R. DE LA CRUZ
Affiant

SUBSCRIBED AND SWORN to before me this 18 th day of

October, 2020 in Tacloban City, Leyte, Philippines, Affiant exhibiting
to me her Driver’s License bearing No. H02-20-001072 expiring on
02/06/2025. I hereby certify that I have examined the Affiant and that
I am fully satisfied that she has voluntarily executed and understood
the contents of her Complaint-Affidavit.

ATTY. REMY R. TRINIDAD

Notary Public until December 31, 2021
Notarial Commission No. 2020-12-20
G/F Uytingkoc Bldg, Avenida Veteranos, Tacloban City
Roll of Attorneys’ No. 40044: 10/12/18
IBP Receipt No. 1600373; 02/06/20; Leyte Chapter
PTR No. 059400; 02/08/20; Tacloban City
MCLE Compliance No. VI – 0002073 valid until 09/05/2021
Doc. No. 20;
Page No. 5;
Book No. II;
Series of 2020.

ATTESTATION OF LEGAL COUNSEL

I, ATTY. REMY R. TRINIDAD, after having been sworn to in

accordance with the law do hereby depose and say:

1. That I have faithfully recorded or caused to be recorded the

questions I asked and the corresponding answers thereto of the
private complainant, Susan R. de la Cruz;

2. That I have not, nor any other person present or assisting,

coached the private complainant regarding the latter’s answers;
and

3. That I fully understand that any false attestation shall subject

me to disciplinary action, including disbarment.

IN WITNESS WHEREOF, I have hereunto affixed my signature

this 18th day of October, 2020 in Tacloban City, Leyte, Philippines.

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 ATTY. REMY R. TRINIDAD
Notary Public

SUBSCRIBED AND SWORN to before me this 18 th day of

October, 2020 in Tacloban City, Leyte, Philippines.

KIMBERLY ANNE H. LATONIO

Prosecutor I
MCLE Compliance No. VI – 0006020
Valid until June 05, 2021

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