REPUBLIC OF THE PHILIPPINES . . .

]
__________________.]S.S.
_________________. . . . . . . . . . . . . . . . .]
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COMPLAINT-AFFIDAVIT
I, ______________, of legal age, Filipino married, and a resident
of_________________, Philippines, after being sworn to in accordance with law,
hereby depose and state THAT:

1. I accuse_________________, of legal age, Filipino, residing

at__________________, Philippines for the crime of Perjury under Art. 183,
of the Revised Penal Code. The ultimate facts of which are discussed herein
below:

1.1 On June 21, 2018, ______________ executed a SINUMPAANG

SALAYSAY registered as Doc No.____; Page No. ____; Book
No._____; Series of _____ of the notarial registry of
Atty.__________, a notary public. Hereto attached is a copy
SINUMPAANG SALAYSAY marked as Annex “A”;
1.2 On October 23, 2018, ____________filed cases against me before
the Office of the Ombudsman docketed as ____________for
violation of Sec.3 (e), RA 3019, Falsification by Officer,
Employee or Notary or Ecclesiastic Minister, Violation of RA
9184 and OMB-P-A-18-0266 for conduct prejudicial to the best
interest of the services; grave misconduct and serious dishonesty.
To bolster his allegations, he attached the said SINUMPAANG
SALAYSAY as Annex “A” in his AFFIDAVIT COMPLAINT and
the same was sworn to by him before__________, Graft
Investigation Officer II of the Office of the Ombudsman (PAB).
Hereto attached is a copy of Affidavit complaint marked as Annex
“B”;
1.3 Nevertheless, ______________deliberately and wilfully narrated
in paragraph 5 of his SINUMPAANG SALAYSAY the
following fabricated, baseless, and malicious statement, to wit:
 “Nandoon din ang mga representatives
ng___________., na sina _________at iba pang
taga___________” (emphasis supplied)

Attached herewith is the copy of SINUMPAANG

SALAYSAY marked as Annex “C”;

1.3 Seemingly, unsatisfied in stating the afore-quoted false statement,

he deliberately narrates further in the same SINUMPAANG
SALAYSAY the following false and apparently perjurious
statement:

“_____________________” (emphasis supplied)

Attached herewith is the copy of SINUMPAANG SALAYSAY

marked as Annex “C-1”;

2. The afore-quoted statements of _____________under oath were false and

perjurious. The statement that ___________was deliberate, malicious,
felonious, baseless, unfounded and unjust fabrication intended by
_______________to boost his claims that I gave undue advantage
to_______________;

3. The truth of the matter being that _____________is not present during the
bidding process. Attached hereto is a copy of the attendance sheet dated June
19, 2018 marked as Annex “D”
4. Consequently, there is no truth also on the allegation that_____________.
The truth of the matter being that there is no occasion that I and Reynaldo Sy
went outside the conference room because in the first place the latter is not
around during the bidding process. Hereto attached is the copy of the
Minutes of the Opening of Bids marked as Annex “E”;
5. The afore-quoted malicious allegations are material inasmuch as it tends to
prove or strengthen the cases (violation of Sec.3(e), RA 3019, Falsification
by Officer, Employee or Notary or Ecclesiastic Minister, Violation of RA
9184 and conduct prejudicial to the best interest of the services; grave
misconduct and serious dishonesty) he filed against me. If those statements
 are true, then the charges he filed against me might prosper; however, if the
same are not true, those cases would be dropped or his credibility as a
witness will legitimately be affected;
6. ARTICLE 183 of the Revised Penal Code provides:

“Article 183. - False testimony in other cases and PERJURY in

solemn affirmation. — The penalty of arresto mayor in its maximum
period to prision correccional in its minimum period shall be imposed
upon any person, who, knowingly makes untruthful statements and
not being included in the provisions of the next preceding articles,
shall testify under oath, or make an affidavit, upon any material
matter before a competent person authorized to administer an
oath in cases in which the law so requires.

Any person who, in case of a solemn affirmation made in lieu of an

oath, shall commit any of the falsehoods mentioned in this and the
three preceding articles of this section, shall suffer the respective
penalties provided therein.”

WHEREFORE, it is respectfully prayed that __________be indicted

for PERJURY under Art. 183 of the Rev. Penal Code and/or such other penal laws
as may be justified by the facts of this case.

FURTHER, the herein Complainant pray for such and other reliefs as may be
deemed just and equitable in the premises.

IN WITNESS WHEREOF, I have hereunto set my hand this _____________

at_________________, Philippines.

Complainant
CEI:

SUBSCRIBED AND SWORN to before me this _____________

at______________. I hereby certify that I have examined the affiant and that I am
fully satisfied that he has voluntarily executed and understood the contents of his
Complaint-Affidavit.