REPUBLIC OF THE PHILIPPINES)

LEMERY, BATANGAS ) S.S.

COMPLAINT-AFFIDAVIT

I, CELINE DIAZ, having been duly sworn in accordance with law,

hereby state:
1. I am 16 years of age born on ___, Filipino, residing at
Dulangan San Luis Batangas and a Grade 10 student of
Lemery National High School in Lemery Batangas. Attached
herewith is my Birth Certificate as Annex “A”

2. Mr. Abando is a Filipino, single, residing at Mataas na Bayan,

Lemery Batangas and our class adviser in Lemery National
High School. Attached herewith is the Certification of
Employment of Mr Abando as Annex “B” and Student
Identification Card as Annex “C”.

3. On September 12, 2019, Mr. Abando gave me stuffed toys and

chocolates which made me think that I was his favorite in class.
This was witnessed by my best friend, Dion Berberabe, who is
my classmate;

4. On October 2, 2019, Mr. Abando told me to go to the computer

room after dismissal time at around 4 o’clock in the afternoon.
While inside the computer room, he started hugging me and
kissed me on the lips. I did not defy the acts because I was
afraid since he is my adviser.

5. On October 3, 2019 at around 4:30 in the afternoon, Mr Abando

again told me to be the last to leave the room and inside our
classroom, Mr. Abando started touching my breast, inserted his
palm inside my panty and fondled my clitoris and inserted his
fore finger on my sexual orifice. Again, I did not defy the acts of
 his adviser and did not dare tell anyone what happened
because I am afraid that I will be the main topic of my
classmates’ gossip.

6. On the succeeding weeks we became friends and we

eventually became intimate with each other. We started
sending text messages to each other wherein Mr. Abando
called me, “love”. Attached herewith is the duly authenticated
exchange of text messages between me and Mr. Abando as
Annex “D”;

7. On November 17, 2019, Mr Abando invited me to eat in Mc

Donalds Lemery Batangas. At around 5 o’clock in the afternoon
we went to a nearby lodging house in Brgy Magihan, Lemery,
Batangas. Mr. Abando told me that he loves me. He kissed me
on the lips and caressed my breast and other different parts of
the body. He started to undress me and he succeeded in
having sexual intercourse with me inside the lodging house.
Afterwards, he brought me home on board his motorcycle;

8. On December 2, 2019 and December 16, 2019, Mr. Abando

fetched me and we again went to the same lodging house
where we had sexual intercourse. Attached herewith is the
Medico-Legal of Celine as Annex “E” signed by Dr Juan Dela
Cruz;

9. On December 18, 2019 as I arrived home late, my mother was

waiting for me. She asked where I came from and she noticed
that I was in distraught. She then admitted that she heard
rumors from our neighbors that I was seen going out with my
class adviser, Mr. Abando. She asked me if it was true. I
admitted to her everything of what was going on between the
two of us. This made her angry and asked me to break up with
Mr Abando and to cut connections with him. The next day she
brought me to the hospital to undergo a medical examination;
10. I informed Mr. Abando that my mother knew already
about us and asked him that we should break-up and I’ll have
to cut connections with him. He did not agree that we be
separated but I insisted. This made him angry. He threatened
me through a text message that he will release our video
scandal to the public if I will cut connection with him, as shown
in Annex “D”;

11. The aforementioned acts constituted “child abuse”, in violation

of Sec 5 Par b of Republic Act No. 7610 (the SPECIAL
PROTECTION OF CHILDREN AGAINST ABUSE,
EXPLOITATION AND DISCRIMINATION ACT), particularly
the following provision:

Section 5. Child Prostitution and Other Sexual Abuse.

– Children, whether male or female, who for
money, profit, or any other consideration or due to the coercion
or influence of any adult, syndicate or group, indulge in sexual
intercourse or lascivious conduct, are deemed to be children
exploited in prostitution and other sexual abuse.

The penalty of reclusion temporal in its medium period to

reclusion perpetua shall be imposed upon the following:
(b) Those who commit the act of sexual intercourse of
lascivious conduct with a child exploited in prostitution or
subject to other sexual abuse; -xxx

in relation to the following provision:

Section 3. Definition of Terms. – xxx

(b) “Child abuse” refers to the maltreatment, whether

habitual or not, of the child which includes any of the following:
(1) Psychological and physical abuse, neglect, cruelty,
sexual abuse and emotional maltreatment;
 (2) Any act by deeds or words which debases, degrades
or demeans the intrinsic worth and dignity of a child as a human
being; xxx

AFFIANT FURTHER SAYETH NAUGHT.

IN WITNESS WHEREOFF, I have hereunto set my hand

this February 11, 2021, Lemery Batangas.

CLARITA DIAZ
Complainant/Affiant

SUBSCRIBED AND SWORN TO before me this 11 th day of

February, 2021, in Batangas City.

MERLYN U. GUTIERREZ
Notary Public for and in the City of Batangas
Commission No. 2018-15
Until December 31, 2021
2nd Floor ABC Building, Rizal Ave,
Batangas City, Batangas
Roll of Attorneys No. 12345
PTR No. 1234567/Batangas City/01-05-21
IBP Lifetime No. 8910112/Batangas City
MCLE Compliance No. V-0022843;08-12-20
TIN: 156-277-235-000

CERTIFICATION

I hereby certify that I personally examined the affiant and that I am convinced
that she voluntarily executed the foregoing affidavit and that he understood the contents
thereof.
MARIA GINALYN P. CASTILLO
Asst. City Prosecutor
ANNEX A
 ANNEX B

Republic of the Philippines

Department of Education
Region IV-CALABARZON
Division of Batangas City

CERTIFICATE OF EMPLOYMENT

This is to certify that MR. RAMONSITO ABANDO, residing at Mataas na Bayan, Lemery Batangas,
employee of this Department assigned to this School District – Lemery National High School since
January 4, 2016 and presently holding the position of Teacher I.

Issued this 12th of December 2020 upon request of Mrs. Clarita Diaz for any legal purposes it
may serve.

CRISOSTOMO IVANA
Division Superintendent
ANNEX C
ANNEX D
 ANNEX E

MARY MEDIATRIX MEDIATRIX MEDICAL CENTER

JP Laurel Highway, Lipa 4217 Batangas

MEDICO-LEGAL CERTIFICATE

Name: CELINE C. DIAZ

Address: Dulangan, San Luis, Batangas
Date Admitted: January 16, 2021
Date and Time of Examination: January 16, 2021

Findings:

The child suffered from complete laceration with sharp coaptable border without congestion of
the hymen at 9 o’clock position. The laceration is about few weeks old.

Respectfully submitted:

Dr. Juan Dela Cruz

Medico-Legal Consultant
Lic. No. 0002389