Republic of the Philippines)

Province of La Union ) S.S

City of San Fernando )
x-----------------x

AFFIDAVIT - COMPLAINT

I, LOVELY SIÑGIAN y Sanchez, of legal age, Filipino, single

and a resident of Upper Bank’s Poro, San Fernando City, La Union,
after having been duly sworn in accordance with law hereby depose
and state that:

1. I am filing a complaint for Violation of Republic Act No. 9262,

otherwise known as the Anti-Violence against Women and
their Children Act of 2004 against the father of my two minor
children, ADRIANE FABELA y Varona (hereinafter referred to
as “RESPONDENT” for brevity) who is presently residing at
Brgy. Mayamot Sumulong, Halang Creek, Antipolo City, Rizal;

2. I and RESPONDENT became boyfriend and girlfriend on

January 17, 2011. I got pregnant with the RESPONDENT but
suffered miscarriage sometime in October 2013;

3. We cohabited as husband and wife without the benefit of

marriage sometime in December 2013 at Bank’s Center,
Barangay Poro, San Fernando City, La Union;

4. We were blessed with two children namely LIAMM ADRIEL S.

FABELA (Liamm) and MARIEA YSABELLE S. FABELA
(Ysabelle) born on November 5, 2014 and September 29,
2016, respectively. Copies of their Certificate of Live Birth are
hereto attached and marked as Annexes “A” and “B”,
respectively;

5. My relationship with the RESPONDENT was a roller coaster as

he used to reproach or rebuke everything that I do. He
happens to scold me every now and then. He even used to
hurt me not just verbally but also physically. Moreover,
whenever he gets angry, he becomes hysterical and destroys
our stuffs at home like our refrigerator and cellular phone;

6. Also, he used to leave me and my children despite my

vehement objection. He will leave us, then come back
whenever he wants to--- this kind of incident happened
around four to five times in the span of our 7-year on and off
relationship;

PAO-SFC
7. Sometime in November 2017, he said that he will go to Manila.
I beg him not to leave us but he did not listen to me. Since
then, our communication became so hard. He lived his own
life as if he does not have children. We received nothing from
him as financial, not even moral support;

8. On December 25, 2017, he came back here in San Fernando

City, La Union, as if nothing happened. I accepted him again
and gave him another chance, hoping that he will not leave us
anymore;

9. However, after New Year, he once again left us on January 4,

2018. He promised to support our two children but this
promise turned futile;

10. When I asked him for his support to our children, he

would often tell me to go to his mother, Gina Galardo
(hereinafter referred to as “TITA GINA” for brevity), at her
residence and workplace located at Fountain Bar, Brgy. Poro,
San Fernando City, La Union;

11. TITA GINA would give me milk, diaper and biscuits for
my children, sometimes for a month and nothing for the
succeeding month (not regular). But before she gives me these
stuffs, she often calls first the RESPONDENT scolding him, to
wit: “May pinapatago ka bang pera sa akin para papuntahin
mo dito si Lovely? Andami-dami ko na ngang problema,
dadagdag pa kayo!” and the like. There was also a time that
she told me, viz: “Ito galing ‘to sa akin ha, hindi kay Adriane.
Ang laki-laki ng kinikita niya doon, hindi man lang
makapagbigay para sa mga anak niya!” This kind of incidents
happened around February 2018 to July 2018 when I can no
longer contact the RESPONDENT;

12. There was also a time that our younger child Ysabelle got
sick so I went again to TITA GINA to ask for financial help.
There, she gave me One Thousand Pesos (Php1,000.00);

13. Because of the foregoing, I was constrained to look for a

job. Thus, sometime in July 2018, I worked as posting checker
at Pier 2, Poro Point, San Fernandio City, La Union. I
requested TITA GINA to take care of Liamm and Ysabelle
during my working hours, from 8:00 P.M. to 9:00 A.M. every
day until the end of my contract to which she acceded;

14. However, on July 12, 2018, TITA GINA asked permission

from me for her to bring Liamm and Ysabelle to the

Affidavit-Complaint for Violation of RA 9262

Maria Elaine M. Pagaduan vs. Ronnie N. Bugaoan
Page 2 of 5
 RESPONDENT at Brgy. Mayamot Sumulong, Halang Creek,
Antipolo City, Rizal;

15. TITA GINA assured me that the custody of my children

will be given back to me after the end of my contract. Thus,
because of such assurance and out of respect, I acceded to
TITA GINA’s request;

16. On July 14, 2018, I and TITA GINA brought Liamm and
Ysabelle to the RESPONDENT and left them thereat ;

17. On August 28, 2018, I asked the RESPONDENT to bring

back to me the custody of our two minor children but he
refused to. I even went there personally, twice, but to no avail.
Thus, I was constrained to file a case for Habeas Corpus
against the RESPONDENT as evidenced by hereto attached
Petition dated October 2, 2018, docketed as Spl. Pro. Case No.
18 3085, marked as Annex “C” hereof;

18. On our first hearing on October 5, 2018, fortunately, he

brought Liam and Ysabelle to the court and surrendered to me
their custody;

19. Since then, I was traumatized and never came back to

TITA GINA. RESPONDENT continuously refused to give
financial support to our minor children. I tried to contact him
but to no avail. Hence, I was constrained to seek legal
assistance from the Public Attorney’s Office – San Fernando
City District Office (PAO) which immediately assisted me on
December 10, 2018 by writing the RESPONDENT for a
mediation/conciliation conference on December 17, 2018.
Copy of the letter sent to the RESPPONDENT is hereto
attached and marked as Annex “D”;

20. Came December 17, 2018, he did not appear, so the PAO
sent him again another Notice of Mediation/Conciliation
Conference hereto attached and marked as Annex “E”;

21. Again, he failed to appear on the said scheduled

mediation/conciliation conference on January 17, 2018 before
the PAO. A Final Notice of Mediation with Warning attached
hereto as Annex “F”, thus, was sent to him. However, again,
despite warning, he did not appear and continued turning a
deaf ear to my repeated plea. The Affidavit of my brother,
Leonardo Singian, who witnessed most of the incidents herein
addressed is hereto attached and marked as Annex “G”;

Affidavit-Complaint for Violation of RA 9262

Maria Elaine M. Pagaduan vs. Ronnie N. Bugaoan
Page 3 of 5
 22. On this date, I came back to PAO to file the necessary
legal remedy against the RESPONDENT. Despite having a
work at the vulcanizing shop (beside Eunice Store) located at
Brgy. Mayamot Sumulong, Halang Creek, Antipolo City, Rizal,
he refuses and continuously fails to give financial support to
our children. Hence, is a deliberate and wanton failure on his
part to comply with his responsibilities as father of our two
minor children pursuant to applicable laws and jurisprudence;

23. His act of continuous failure to give support to our

children despite repeated demands tantamount to economic
abuse which is defined under R.A 9262 or Violence Against
Women and their Children as:

"Economic abuse" refers to acts that make or attempt to

make a woman financially dependent which includes, but is
not limited to the following:

Withdrawal of financial support or preventing the victim from

engaging in any legitimate profession, occupation, business or
activity, except in cases wherein the other spouse/partner
objects on valid, serious and moral grounds as defined in
Article 73 of the Family Code;

xxxxxxxxx.”

24. Further, Sec. 5 paragraph 2 of the said law defined

the acts which constitutes the crime of Violence against
women and their children, to wit:

“(2) Depriving or threatening to deprive the woman or her

children of financial support legally due her or her family, or
deliberately providing the woman’s children
insufficient financial support.” (Emphasis supplied)

25. Following the above quoted provision of law, I believe that

RESPONDENT has has transgressed Republic Act No. 9262;
and

26. I am executing this Affidavit-Complaint to attest to the

truth of the foregoing in support for the filing of criminal
charge/s against respondent, ADRIANE FABELA y Varona,
for violation of Republic Act No. 9292 otherwise known as
Anti-Violence against Women and their Children Act of 2004.

IN WITNESS WHEREOF, I have hereunto set my hand this 6 th

day of February, 2019 at San Fernando City, La Union, Philippines.

Affidavit-Complaint for Violation of RA 9262

Maria Elaine M. Pagaduan vs. Ronnie N. Bugaoan
Page 4 of 5
 LOVELY S. SIÑGIAN
Affiant-Complainant

SUBSCRIBED AND SWORN to before me this 6th day of

February, 2019 at San Fernando City, La Union, Philippines and
further certify that I personally examined the affiant and I am
convinced and satisfied that he gave his statement freely and
voluntarily and understood the contents hereof.

Affidavit-Complaint for Violation of RA 9262

Maria Elaine M. Pagaduan vs. Ronnie N. Bugaoan
Page 5 of 5