Republic of the Philippines]

Capas, Tarlac ] s.s

AFFIDAVIT OF COMPLAINT

The UNDERSIGNED, JONAS DAVID, accuses ROXANNE PASCUAL of Cyber

Libel by means of deceit under section 4(c)(4) of Republic Act 10175, in relation to Articles 353
and 355 of the Revised Penal Code, committed as follows, to wit:

That on or about the 1st day of March 2021 and subsequently thereafter in the Brgy.
O’Donnell, Municipality of Capas, Tarlac, Philippines, the said accused did then and there
willfully, unlawfully, feloniously posted statements which are libelous, contemptuous and
derogatory to Mr. JONAS DAVID, “with evident and malicious purpose of insulting,
dishonoring, humiliating and bringing into contempt the good name and reputation” of said
complainant in the following manner to wit:

1. That on or about March 1, 2021, the said accused being then a friend to the complainant
posted a public electronic message on social mediaFacebook specifically a statement
which read as follows:
“KAIBIGAN PA NAMAN KITA, HINDI KO AKALAING MAGAGAWA MO SAKIN
ITO JONAS DAVID!!! LAWYER KA PA NAMAN!

PARA PO SA LAHAT NG MGA KABABAIHAN, HUWAG PONG MASYADONG

MAGTIWALA AT MAGING SOBRANG KOMPORTABLE SA MGA KAIBIGANG
LALAKI, MAY TIWALA KA MAN O WALA. NAWAY MAGING ARAL SAINYO
ITONG PAGKAKAMALI KO.

JONAS DAVID, BAKIT? KAIBIGAN KITA FOR FIVE YEARS TAPOS

MAGAGAWA MO SAKIN YON? PARA PO SA KAALAMAN NG LAHAT, ANG
JONAS DAVID PO NA KILALA NIYONG BANAL, MATULUNGIN, MAASAHAN
AT MALALAPITAN SA KAHIT ANONG ORAS SEXUALLY HARRASED ME! HE
SEXUALLY HARRASED HIS 5-F*CKING-YEAR FRIEND WITHOUT EVEN
BEING INFLUENCED BY ALCOHOL. NAGAWA NIYA PO YON IN BROAD
LIGHT.

SANA MAKATULOG KA PA SA GINAWA MO SAKIN. NAGKAMALI AKO NG

PINAGKATIWALAAN,” together with the photos of the said JONAS DAVID.
 2. The above electronic message being defamatory or constituting an act causing or tending
to cause dishonor, discredit or contempt against the person of the said ROXANNE
PASCUAL, to the damage and prejudice of the said offended party.
3. On or about February 25, 2021, the respondent and the undersigned had a non-public
conversation where in it will be seen their that the latter warned the former that she will
destroy the reputation he worked for on a long period of time.
4. As a result of the defamatory electronic message, the complainant was suspended in his
job, cancelled by everyone who saw the said electronic message and was labelled as a
sexual harasser.

Contrary to Law.

The undersigned executed this affidavit to attest the truthfulness of the foregoing facts
and to support the filing of Criminal Cases against Roxanne Pascual for violations of Republic
Act 10175, section 4(c)(4) in relation to Article 355 of the Revised Penal Code, as amended, this
10th day of March, 2021.

Jonas David____
Offended Party

SUBSCRIBED AND SWORN to before me this 10th day of March, 2021 at about 2pm
in the afternoon. I HEREBY CERTIFY that I have personally examined the herein offended
party and I am satisfied that they voluntarily executed and understood their given affidavit.

_Angelina Morales_
Judge