REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE PROSECUTOR
MANILA

Paper Towns Bank, as represented by

Atty. Bong Gomez de Papel
Head, Legal Department of
Complainant,

-versus- I.S. # 153045

For: Robbery with Homicide

Sergio Marquina aka. Professor, et.al

Accused,

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CRIMINAL COMPLAINT AFFIDAVIT

I, Atty. Bong Gomez de Papel, the undersigned, of legal age, Head of the Legal Department
of Paper Towns Bank and a resident of #35 Wallflower Street, Vito Cruz Manila, accuses
Sergio Marquina aka. Professor, Rex Revilla a.k.a Berlin, Angel Moreno a.k.a Tokyo,
Carlo Aquino a.k.a Moscow, the crime of Robbery with Homicide, committed as
follows:

1. At around 9:30AM of Friday, October 15, 2020. Arturo Roman the bank
manager of Paper Towns Bank located at A. Mabini St. cor. P. Ocampo St.,
Malate Manila, Philippines 1004 was getting ready to start his day when the
accused went inside the bank and pretended to transact business.

2. However, after 30 minutes at about 10:00AM, the above-mentioned accused

declared robbery.

3. That the accused took Arturo Roman as their hostage, together with two (2) of
his colleagues in the person of Miss Monica Gastambede, and Miss Ginger Star.
They were then tied up and threatened that if they don’t comply with the orders
of the robbers they will be shot. The accused then proceeded to open the vault
of the bank containing 20 Million Pesos.

4. That the accused, as Arturo Roman together with Miss Monica Gastambede, and
Miss Racquel Espanto remembered, were all wearing plastic masks of the
painter Salvador Dali and red over-alls. In the course of the robbery at some
point all of them took their masks off, as a consequence thereof they were able
to see their faces and identify them individually.

5. All of them are of normal built and appeared to be “kayumanggi” or brown-

skinned and of average height.

6. Then, a certain outsider had reported to the Police about the robbery incident.
After 45 minutes, the Policemen came and ordered the accused to surrender.
7. However, the accused instead of surrendering fired their guns towards the
Policemen. The Policemen then tried entering the building premises of Paper
Towns Bank by means of breaking the walls and windows.

8. Ten (10) Policemen were able to enter the building premises to arrest the
accused. Unfortunately, the accused killed four (4) Policemen namely SPO4
Michael Boyd, SPO3 Geralt Ofrivia, SPO4 Malone Carl, and SPO4 Wardell Curry
in the course of Robbery.

9. After the shoot out the police were able to subdue the robbers and rescue the
hostages. They then brought them to the nearby police station where they
narrated the incident.

10. Later on, they positively identified the men arrested as those who robbed the
bank due to fact that the accused removed their masks albeit momentarily in
the course of the robbery.

11. That all these stated herein are true and were stated freely without any force or
intimidation done against me.

12. To attest to the truthfulness of the foregoing, I, Atty. Bong Gomez de Papel,
complainant, attaches my signature below.

_____________________________
Atty. Bong Gomez de Papel
Complainant

SUBSCRIBED AND SWORN to before me, in the city of Manila, this 16th day of
October, 2020, the affiant exhibiting to me his Passport No A-165243 issued by
Department of Foreign Affairs Manila on 15th of April 2020 at Roxas Blvd, Manila.

___________________________
Emma Jane
Assistant City Prosecutor