REPUBLIC OF THE PHILIPPINES

Department of Justice
National Prosecution Office
Office of the City Prosecutor
Manila

People of the Philippines,

Plaintiff,
CRIMINAL CASE No. 123456
- versus - FORCIBLE ABDUCTION
WITH RAPE
MOMOTARO KAGEYAMA
Accused.
x ----------------------------------------- x

COMPLAINT

The undersigned accuses Momotaro Kageyama of the crime of Forcible Abduction with
Rape, committed as follows:
That on or about April 01, 2021. in the City of Manila, Philippines, the said accused, with
lewd designs, did then and there willfully, unlawfully and feloniously abduct, take, and carry
away the undersigned complainant while on her way home from work at Tondo Manila, by
means of force, violence and intimidation to wit: by pulling her and forcing her to walk, at the
same time pointing at her a gun and threatening to kill her should she cry out for help, succeeded
in bringing her to ride in his car, where they rode to an abandoned warehouse where the said
accused, by means of force, violence, and intimidation, succeeded in having sexual intercourse
with her against her will.
Contrary to law.
ALEXIA S. ESPARAGOZA
Complainant

SUBSCRIBED AND SWORN TO before me this 17th day of April, 2021, in the City of
Manila, Philippines, by Alexia S. Esparagoza, the complainant.

HELEN CARLA L. TABERNERO

Assistant Prosecutor