Republic of the Philippines)

City of ______________) s.s.

AFFIDAVIT-COMPLAINT

I, MA. PERPETUA M. REGALA, of legal age, married,

Filipino and resident of Unit 8F Synergy Ville, Dalig 2, Antipolo
City, under oath, hereby depose and say, that:

1. On 14 of December 2020, at around 10:00 o’clock in the

morning, I had a an argument with Mrs. Cristina Cortez, a
resident of Unit 9, Synergy Ville, Dalig 2, Antipolo City;
where she slandered, cursed, and threatened me in public
saying “Putang ina mong matanda ka, bumalik ka
dito, sasabunutan kita!” and other inhumane words,
at the top of her lungs, as a result of our disagreement on
an issue in our subdivision;

2. On December 28, 2020, Mrs. Cortez, flared-up in front of

my grandson after a conversation with the Homeowners
Association President, cursed and humiliated me in public
while uttering foul words. It was followed by her
confronting my grandson who is a minor and who
witnessed her besmirching me while my grandson was
playing along pool side of the subdivision with a friend
and touched him against his will. Said incident prompted
me to file a complaint against Mrs. Cortes to the Barangay
Hall of Dalig, Antipolo City of Grave Threats, Alarm and
Scandal, and Oral Defamation, which was mediated by the
Lupon ng Tagapamayapa, presided by its Chair, Jimmy
Chico, where she continuously lied during the mediation
proceedings and fabricated stories that never happened to
defend her inappropriate actions towards me despite me
being a senior citizen.
3. On January 21, 2021, as a result of the mediation by the
Barangay Council, Mrs. Cortes and I both agreed to settle
the incident for peace and harmony within the village, and
as a sign of compassion to my neighbor, I we signed the
resolution to settle the complaint against her which she
also signed.

A copy of the said Barangay Resolution No. 12-2020-60 is

attached as Annex "A"

4. The aforementioned resolution has provisions,

particularly in Paragraphs 2 and 3 that pertains to posting
and stating any words that might affect to the said
Resolution to wit:

“(2) Na iiwasan din ang mag-post ng mga salitang

makaka-apekto sa karapatang pantao ng bawat isa,
mapa Facebook man o messenger;

Na iiwasan din ang magkaroon ng parinigan sa bawat

panig na maaaring pagmulan ito ng kaguluhan”

5. All along, I thought that the Barangay Resolution would

pave way to re-establishing peace and harmony in our
village for the sake of the homeowners and the community
in general. I was in deep faith with the Barangay
Resolution that I will abide by its condition and
understood its provisions knowing that I am a law-abiding
citizen.

6. However, on March 13, 2021, between 8:00-9:00 pm,

while I was accompanying a friend to the Homeowners
President whom we unfortunately met, but bumped with
someone we knew, and passing along the house of Mrs.
Cortez, she suddenly appeared as if suspecting that we are
talking about her and assumed that I was talking behind
her back quoted:
 “Ano na naman yan Potpot (referring to me as
my nickname), Ano na naman gusto mo,
sinisiraan mo na naman ako. Bumalik ka
dito!”

7. On April 27, 2021, Mrs. Cortez, in a Facebook Group

Messaging of Synergyville, created for the purpose of
informing the residents of the village of the latest events,
happenings, and important matters that concerns the
Homeowners Association, Mrs. Cortez suddenly accused
me of maneuvering the security system of the village, that
I instructed the Security Guards quoted:

“Kapag may mga delivery sa tindahan ay ipadiretso

sa akin at kung sa iba ay ipaiwan sa guard at baka
may covid”

I would never say such remark considering that I am one

of the founding officers of the Homeowners Association
and that I know the policies we installed before she
assumed position as Head of Security.

8. She even posted a photograph of our family car in the

Group Messenger with its plate number vividly seen as
well as our house, with a real intention of shaming me and
my family to have been violating the Homeowners’ Rules
and Regulations

A copy of the said photograph of the car and our house

attached as Annex "B"

9. Mrs. Cortez has always been known in our community as

the person who always brings up any issue in our village to
our Facebook Group Messaging. One incident involves
her and another Homeowner, Ms. Gem Reyes, as she
continuously published and spreads malicious intents
 against the latter and uses the Group Messaging to malign
the person and destroy her reputation. Such was reacted
upon by the latter and asked that if there are issues
concerning her must be addressed with personally and not
use the said messaging system where it is seen by all
members of the group without concern on their personal
matters.

A copy of the said grievance by Ms. Gem Reyes is attached

as Annex "C"

10. On a related matter, Mrs. Cortez posted on January 4,

2021, again in the Group Messenger, questioning my
identity stating that my existence in the community is a
threat against her family and the community security in
general accusing me of bullying her which is not in my
capacity considering that I am already a Senior Citizen
and any matter that involves chaos will only affect my
health condition.

A copy of the accusation of Mrs. Cortez is attached as

Annex "D"

A copy of proof of my identity as Senior Citizen is attached

as Annex "E"

11. As far as I know, I am no longer included in the Facebook

Group Messaging created for Synergyville Homeowners
since I suffer from hypertension every time I read negative
on its feed, where my son, Chris substituted for me so that
we may be informed of important announcements from
the officers of the village.

12.My understanding of the situation is that if she has a

problem or issue with me, she should have gone straight
to me and tell me her concerns, considering that she is the
Security Head of the Homeowners Association which I am
 not part of and that not choose the Homeowners
Facebook Group Messaging to air his personal comments
or concerns where everyone in it may read, including
defamatory statements.

A copy of the besmirching statements Mrs. Cortez made is

attached as Annex "F"

13.The afore-quoted portion of the online accusation

authored by respondent Mrs. Cristina Cortez created in
the minds of the readers that I am above the law, liar, and
deceitful as a neighbor;

14.The article written and published by respondents has no

factual basis, is highly speculative and was all false
statements made to destroy my reputation Respondent
was motivated by bad faith in the publishing of the said
accusation online to defame, embarrass and discredit me
to my colleagues, friends, and family due to the
aforementioned antecedent where I filed a complaint
against her before the Barangay;

15.The libelous article having been published through the

Facebook Group Messaging of the village, a group
messaging system accessible to and is made available to
the general public, particularly the residential owners, was
read by the everyone in it, including my colleagues,
friends and family among others;

16.Due to the said malicious public imputations by

respondents, I suffered and continue to suffer serious
anxiety, besmirched reputation, mental anguish, sleepless
nights, not to mention the damage they have caused to my
reputation and honor among the readers of the said group
messaging including my friends in the village;
 17.Due to such grossly unjust malicious and libelous
imputations, I therefore pray that respondent be made to
pay jointly and severally, the damages I was made to
suffer as a result of the online besmirching of reputation
in whatever amount the Honorable Court deems sufficient
and proper together with the attorney’s fees and the cost
of this suit.

I hereby execute this affidavit to attest to the truth of the

foregoing facts and hereby request the investigating prosecutor to
file the crime of Libel under R.A. 10175 against the herein
Respondents.

IN WITNESS WHEREOF, I have hereunto set my hand this

5 day of May 2021 in Antipolo City, Philippines
th

MARIA PERPETUA M. REGALA

Affiant

SUBSCRIBED AND SWORN TO before me this 5th day of

May 2021 in Antipolo City, Philippines, the following affiant MA.
PERPETUA M. REGALA exhibiting to me her Senior Citizen ID
No. 17090555 being sufficient and competent evidence of his/her
identity in pursuant to the 2004 Rules of Notarial Practice.

NOTARY PUBLIC

Doc. No. ____;

Page No.____;
Book No. ____;
Series of 2021