Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 12
Makati City

MICHELLE RAVAL,
Plaintiff,
Civil Case No. 12345
-versus- For: Recovery of Damages Arising
From Article 26 (4) of the Civil
Code
OGIE EARL DIAZ,
Respondent,
x----------------------------------------------x

COMPLAINT-AFFIDAVIT
Plaintiff, Ms. Aj Michelle Raval, through the undersigned counsel and unto this
Honorable Court respectfully alleges that:

1. Aj Michelle Raval, herein plaintiff, is an actress, of legal age, Filipino citizen,

single and with postal address at 1617 Saint Paul Street San Antonio Village,
Makati City.

2. Ogie Earl Diaz, herein respondent, is of legal age, Filipino, and with postal
address of 16 Saturn St., Makati City.

STATEMENT OF FACTS AND CAUSES OF ACTION

3. Herein plaintiff is a Star Majick artist and herein respondent is her manager. On
the night of January 04, 2022, they were invited to a to a company dinner along
with business partners, producers, directors, photographers along with other
industry insiders.
4. Before the said dinner, plaintiff and her manager had the chance to discuss some
business matters and there she mentioned that she has plans on taking a break
in working in the show business industry. Plaintiff also mentioned that the plot
that was supposed to be the main story of the current drama she’s currently
working on had major changes, that is why her character, the shooting schedule
and her script all changed. Looking at the situation, plaintiff decided to discuss
with her manager taking a break and focusing on her future endeavours.

5. During the dinner, plaintiff was then shocked to hear defamatory words uttered
by her manager. Plaintiff heard the words “mayabang na porket alam niyang
nakaka angat na siya sa buhay. Girl! Kung alam mo lang kung hindi ka
kumakabit sa bosses eh hindi mo yan mararating!.”

6. Plaintiff alleged that her manager’s voice was loud enough that by-standers and
other restaurant customers started looking at their direction.

7. Plaintiff also stated that respondent did not stop there, after about several
minutes of uttering such words against her, respondent added the following
obscenities and foul language against her “Kung kani-kanino yan sumasamang
lalaki para may maabot sa career” “pasalamat ka nilakad kita sa mga bosses.”
“High-end escort ang pota” “kabit”.

The video footage is attached as Annex “F” .

8. The plaintiff stated that she was so shocked to hear such defamatory words from
her manager that she started to run towards the lavatory with her show business
best friend Barbie Imperial.

The affidavit of the plaintiff is attached as Annex “A”;

9. Plaintiff started to sob and become more stressed and worried when Barbie told
her that there are a lot of people in the restaurant witnessed the incident and
that some of them even caught the incident on camera.

The affidavit of witness Barbie Imperial is attached as Annex “B”;

10. Plaintiff stated that on January 05, 2022, she woke up with the news that a
video she was in was going viral. She is going viral for the wrong reason.
Netizens over the country bashed her through all her social media accounts.
People she barely knew started throwing mean words to her and the hashtag
#cancelAJkabit is trending on twitter. Plaintiff stated that she can’t do anything
but cry. She sobbed uncontrollably and was not able to sleep for days thinking of
the incident.
Screenshots of facebook posts against AJ Michelle Raval were attached as Annex “E”

11. As the result of the incident, plaintiff stated that she cannot go out in her condo
without gossips and judgmental looks against her. She experienced a lot of
trauma, fear, anxiety and emotional stress that she even got to the point of
thinking to end her own life.

12.Because of respondent’s defamatory words, the plaintiff suffered mental anguish,

fright, serious anxiety and moral shock; she was also diagnosed of depression.
The plaintiff was compelled to undergo therapy treatment and sessions to ease
her depression.

The affidavit of psychiatrist Doctor Strange is attached as Annex “C”;

13. Now, plaintiff comes before this Court and files for a case for the recovery for
damages, including actual damages for medical bills and other related costs
while the plaintiff is undergoing treatments.

Screenshots of Medical bills and other related costs attached as Annex “H”

14.Included in the damages is the lost work time and income of the plaintiff for lost
endorsements and promotions.

Screenshots of lost endorsements were attached as Annex “G”

15. Also included in the damages were moral damages plaintiff suffered from the
social humiliation, besmirched reputation, and baseless defamatory words
thrown to her by the respondent.

16. The total amount paid by the plaintiff for her therapy treatments and sessions
amounted to 100,000 pesos, and 35, 000 pesos for medications. The total
amount for plaintiff’s lost income due to loss of endorsements and photo shoots,
other engagements and promotions amounted to 2,000,000.

17. Plaintiff likewise prays for moral damages amounting to 1,000,000.

18. Consequently, plaintiff was constrained to engage the services of counsel with
obligation of paying Attorney’s Fees in the amount equivalent to at least twenty
percent (20%) of the total amount to be awarded as the costs of the suit.
RELIEFS PRAYED FOR IN THE LIGHT OF THE FOREGOING,

it is most respectfully prayed of the Honorable Court to render

judgment in favor of the plaintiff and against the defendant in the following
manner, to wit:

1. Ordering the DEFENDANT to, pay for damages in the amount of

Php. 135,000.00 as actual damages;

2. Ordering the DEFENDANT to pay the costs of suit and attorney’s

fees;

3. Ordering the DEFENDANT to pay MORAL DAMAGES for the

unnecessary anxiety, mental anguish and continued pain and suffering of the
plaintiff from the time of the accident until this day.

Plaintiff prays for such other relief or remedy consistent with law and
equity. Makati City, Philippines, January 17, 2022.

  
   Chona bells
ATTY. CHON A. BELLS
Counsel for the Plaintiff
Roll of Attorneys No. 12345
XYZ Towers, Cebu City 6000, Makati, Philippines
IBP No. 5672, 02-01-2023,
Cebu City PTR No. xxxxxx, 02-01-2023
MCLE V No. 124356, 02-01-2023, Makati City
 VERIFICATION/CERTIFICATION OF NON-FORUM SHOPPING

I, Ms. Aj Michelle Raval, plaintiff in this case, of legal age, a Filipino citizen
with the residence at 1617 Saint Paul Street San Antonio Village, Makati City,
after being sworn in accordance with law, hereby depose and say:

1. That I am the plaintiff in the above-entitled case;

2. That I have caused the above complaint to be prepared and have read
and known the contents thereof;

3. That the allegations therein are true of my own knowledge.

4. That I have not heretofore commenced any other action or proceeding

involving the same issues in the Supreme Court, the Court of Appeals, or any
other tribunal agency of hearing officer; to the best of my knowledge no such
action or proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal, agency or hearing officer;

5. That should I thereafter learn that a similar action or proceeding has

been filed or is pending before the Supreme Court, the Court of Appeals, or any
other tribunal, agency or hearing officer, I undertake to report that fact within
five (5) days therefrom to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto set my hand on the 17 day of January 2022
th

in Makati City, Philippines.

Aj raval
Michelle Raval
Affiant

SUBSCRIBED AND SWORN to before me on the 17 day of January 2022, affiant

th

exhibiting to me competent evidence of his identity by way of a Professional Driver’s

License with number D01-01-654321 issued at LTO Makati Office which is valid until
December 29, 2022.

ATTY. LALA MOOVE

Notary Public of Makati City
Until December 31, 2022
PTR No. 1111111A / 01-05-2020 / Makati
IBP No. 1111111 / 01-07-2020
Roll of Atty. No. 30000
MCLE Compliance No. 0001111
TIN No. 121212121212
Makati City

Doc.  No. 111;

Page No. 11;
Book No. III;
Series of 2023.
 SWORN ATTESTATION OF COUNSEL
 
I, CHON A. BELLS, of legal age, and with office address at in 6th Floor, 1789
Ayala Ave., Makati City., after having sworn in accordance with law, hereby depose and
state THAT:

a. I am the Legal Counsel for the respondent in the above-titled case;

b. I have faithfully recorded the questions I asked and the corresponding

answers that the witness gave; and

c. Neither I nor any other person then present or assisting me coached

the witness regarding the latter’s answers.

I hereby affix my signature on the date and place written below.

   Chona
bells
ATTY. CHON A. BELLS
Counsel

SUBSCRIBED AND SWORN to before me on the 17 day of September 2021, affiant

th

exhibiting to me competent evidence of his identity by way of a Philippine Passport with

number P1234567A issued at DFA La Union which is valid until February 09, 2023.
 ATTY. LALA MOOVE
Notary Public of Makati City
Until December 31, 2022
PTR No. 1111111A / 01-05-2020 / Makati
IBP No. 1111111 / 01-07-2020
Roll of Atty. No. 30000
MCLE Compliance No. 0001111
TIN No. 121212121212
Makati City

Doc.  No. 112;

Page No. 11;
Book No. III;
Series of 2023.