REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
LAPU-LAPU CITY

EVA PSYCHEE S. PATALINJUG,

Complainant,

NPS Docket No: ___________

- versus - For: Rape

ALEKSANDER JOEL M. YARED,

Respondent.
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Republic of the Philippines ]

City of Cebu ] s.s
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AFFIDAVIT-COMPLAINT

I, EVA PSYCHEE S. PATALINJUG, 24 years old, single, and

resident of Basak, Lapu-Lapu City, after having been duly sworn to in
accordance with law, do hereby depose and state:

1. I personally know the accused Aleksander Joel M. Yared

(“Aleksander”) as we are first cousins, and we grew up together in the same
neighborhood. We are a close-knit family.

2. Sometime on 14 February 2020, Aleksander invited me and

some of our friends to celebrate Valentine’s Day and have some fun at the
Labyu Beach Resort in Lapu-Lapu City. Our common friends Joshua, Meah,
and Katherine were with us. We arrived at the beach at around 2:00 o’clock
in the afternoon.

3. The five of us were having so much fun. There were lots of

delectable food, singing, dancing, drinking, and storytelling.

4. At around 7:00 o’clock in the evening, my cousin Melwin

texted me to come to his house so we could prepare our application letters
that we intended to submit to Shangri-la Hotel the following day as we were
then looking for employment.
 5. As darkness began to fall and caress the night, I asked my
friend Joshua to accompany me in going to my cousin Melwin’s house
located about half a kilometer away from Labyu Beach Resort. But
Aleksander volunteered to go with me. As Aleksander was already in his
inebriated state, I tried to decline his offer, but Aleksander would not take no
for an answer.

6. Aleksander and I arrived at my cousin Melwin’s house at

around 7:30 o’clock in the evening. My cousin Melwin and I then wasted
no time in preparing our respective application letters, while Aleksander
stayed outside of my cousin Melwin’s house. We finished drafting and
finalizing our application letters after about thirty (30) minutes. My cousin
Melwin wanted me to stay for a little longer for more chit chat, but
Aleksander called me out and insisted that we now leave as Joshua, Meah,
and Katherine were waiting for us at the beach. Not wanting to piss
Aleksander off, I obliged.

7. As we walked a few steps away from my cousin Melwin’s

house on our way back to the beach, Aleksander suddenly grabbed my arm
and told me that I am insanely hot and beautiful and that he has long been
dying to have sex with me. Aleksander’s words hit me like a kick in the gut.
I never expected him to say it as I always treated him like a brother.

8. Fuming mad, I chided Aleksander and urged him to perish such

an evil thought. I told him that he should be ashamed of himself for wanting
to have sex with me even if we are first cousins.

9. But Aleksander’s irresistible evil desire for the flesh overran

sound judgment. He said that he does not care at all if we are first cousins
and pleaded with me that we make love and just keep it between us.

10. Sensing that Aleksander was really hell-bent in having sexual

intercourse with me, I tried to walk past him but Aleksander tightened his
hold of my arm and he was so strong that I could not get away.

11. Aleksander then dragged me to the bushy area at the back of

my cousin Melwin’s house and started kissing my lips and my neck and
fondling my breasts. I pleaded with him to stop but he never listened. I
wanted to shout for help and fight back but he told me that he would kill my
brother Kevin should I resist.

12. Aleksander then removed my shorts and underwear and licked

my vagina. I wanted to kick him but I was afraid that he will kill my brother.
After a while, Aleksander asked me to turn around and he inserted his erect
cobra-like penis into my vagina and kept pumping from behind like there
was no tomorrow. It was so horrible as if all hell broke loose. But I could not
do anything; I feared for my brother’s life.

13. After a few minutes, Aleksander sat on a rock and asked me to

sit on his lap, place his penis inside my vagina, and do the pumping myself.
Shortly after, I did some thrusting movements while Aleksander’s penis was
deep inside me, and while his body started to shiver and his eyes almost
popping out, Aleksander asked me If he can ejaculate inside my vagina, but I
adamantly refused because I was afraid to get pregnant. Aleksander then
pushed me away and let his semen burst into his palm.

14. Aleksander asked me to put my shorts and underwear back on

and threatened to kill my brother if I tell anybody of what happened. We
then went back to the beach resort where Joshua, Meah, and Katherine were
waiting for us. As we got back at the beach, we all continued to enjoy the
night as I pretended to act normally as if nothing bad ever happened to me.
We left the beach to return to our respective homes at around 11:00 o’clock
in the evening.

15. When I arrived at my parents’ house, I cried all night that I ran
out of tears. I even thought of killing my self. Since I feared for my
brother’s life and in my desire to spare my family from the slings and arrows
of public scandal and ridicule, I chose to suffer in silence. I was, and still
am, in a state of trauma. I almost lost my mind thinking about it.

16. A week after the incident, my application for employment was

accepted by Shangri-la Hotel and I busied myself working to make a living.
During my free time, I also pursued my modeling career on the side.

17. Sometime in September 2020, my parents confronted me about

a rumor circulating around via Facebook that Aleksander and I are having
sexual relations and that I am a sexually promiscuous woman for engaging
in sexual intercourse with several men, even with a cousin.

18. I vehemently denied these rumors. As my family has been

unfairly embarrassed and humiliated by these false and unfounded rumors,
and in order to vindicate my name and honor and get justice for this bestial
and heinous crime committed by Aleksander against my person and
womanhood, I finally decided to come forward and lodge this complaint
against Aleksander Joel Yared.

19. Upon the advice of some well-meaning friends, I reported the

incident to the Police Station of Cebu City. 1 I was then brought to the
Vicente Sotto Memorial Hospital for medical examination.2

1
Copy of the Police Blotter is attached as Annex “A”.
2
Copy of the Medical Certificate is attached as Annex “B”.
 20. I am executing this Complaint-Affidavit to attest to the truth of
the foregoing facts and in support for my complaint for Rape against
Aleksander Joel Yared.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

________ day of June 2021 in Lapu-Lapu City, Philippines.

EVA PSYCHEE S. PATALINJUG

Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, this _______ day

of June 2021. I hereby certify that I have personally examined the affiant,
and she declared before me that she willfully and voluntarily executed the
foregoing Complaint-Affidavit, and that to the best of her knowledge the
contents thereof are true and correct.

_______________________
Assistant City Prosecutor