Republic of the Philippines

Department of Justice
NATIONAL PROSECUTION SERVICE
OFFICE OF THE PROVINCIAL PROSECUTOR
SOUTH COTABATO

Angelie Cruz
Complainant
vs. I.S. No. ____________
For: Rape with Murder
Alias “Razi” and Alias “Max”
Respondent.

x-----------------------------------------------------------------------------------------x

COMPLAINT-AFFIDAVIT

I, ANGELIE CRUZ, Filipino, of legal age, and with residence at Block B, Lot 10,
Yayamanin Ville, Koronadal City, after having been duly sworn in accordance with law,
hereby depose and state that:

(1) This complaint-affidavit is being filed to charge a certain Razi and Max, Filipino
citizens, of legal age, whose residence is unknown, of the crime of Rape with
Murder under RA 8353 in relation to Article 248 of the Revised Penal Code
(RPC) and committed as follows:

(a) In the morning of April 4, 2022 at around 6:30AM, in the town of Polomolok,
South Cotabato, my brother, Angelo, a transgender, went out with his friends to
go to the beach in General Santos City. However, Angelo was not able to join his
friends to the beach. One witness saw that Angelo boarded a tricycle and was
accompanied by two men.

(b) On April 7, 2022, I looked for my brother. Using the CCTV footage near the
tricycle terminal, I found the tricycle driver who brought Angelo and the two other
guys. I asked the driver to bring me to the place where Angelo and the two other
men were dropped. There, I found Angelo tied, naked and unconscious.

(c) I brought Angelo to the nearest hospital in Polomolok, South Cotabato where he
was immediately attended.

(d) While in the hospital bed, Angelo temporarily gained his consciousness and told
the story of what had happened to him. He was able to mention the names of the
suspects - Razi and Max.
 (e) In his story, he told me that he was taken forcibly by Razi and Max in a small hut
in the middle of the rice field in Purok Palkan, Polomolok, South Cotabato. There,
Razi and Max beat Angelo and pointed a knife on him. They also undressed
Angelo. Razi then put off his pants and inserted his penis to the anus of Angelo
and did a push and pull motion.

(f) At 4PM of April 7, 2022, Angelo was declared dead due to internal bleeding.

(2) The elements of rape under paragraph 2 of Article 266-A provides the elements of
rape by sexual assault wherein it is committed by any person who, under any of the
circumstances mentioned in the paragraph 1, shall commit an act of sexual assault by
inserting his penis into another person’s mouth or anal orifice, or any instrument or
object, into the genital or anal orifice of another person.

(3) Furthermore, under Article 248 of the Revised Penal Code, any person who, not
falling within the provisions of Article 246, shall kill another, shall be guilty of murder and
shall be punished by reclusion perpetua, to death if committed with treachery, taking
advantage of superior strength, with aid of armed men, or employing means to weaken
the defense, or of means of person to insure or afford immunity.

(4) Based on the foregoing, it is beyond cavil that respondents Razi and Max committed
the crime of rape punishable under Art. 266-A and the crime of murder punishable
under Article 240 of the RPC.

(5) I am executing this affidavit to attest to the truth of the foregoing facts and to charge
herein respondents alias Razi and alias Max of the crime of rape with murder as
punishable under Article 266-A of the Revised Penal Code, Republic Act No. 8363, the
Anti-Rape Law of 1997 and Article 248 of the Revised Penal Code of the Philippines.

IN WITNESS WHEREOF, I have hereunto set my hand this 26th day of July,
2015 in General Santos City.

ANGELIE CRUZ
Complainant/Affiant

SUBSCRIBED AND SWORN TO before me, this 10th

day of April, 2022 in General Santos City. I hereby certify that I have examined the
Affiant and that I am fully satisfied that she has voluntarily executed and understood the
contents of her Complaint-Affidavit.

ATTY. RYAN OMAR V. REYES

Counsel
 ANNEX “A”
REPUBLIC OF THE PHILIPPINES)

SINUMPAANG SALAYSAY

I, MARIA LUISITA BILOG VIRGINIA, Filipino, of legal age, and with residence at
Block 11,Lot 11, Bombastik Homes, Kidapawan City, after having been duly sworn in
accordance with law, hereby depose and state that:

1)That in the morning of January 13, 2015 at around 7:30, I was left alone in the house
because my mother and father has to report to their offices while my younger brother
has to attend to his class as an elementary pupil. I am a 4 th year college student then,
but I was not able to attend class because I was sick the night before. After bidding
goodbye to them, I get back to my bed and sleep.
2) I was awaken by the sound of the alarm in my phone telling me that it was already
11:00 in the morning. I woke up feeling well and decided to take a bath. I was about to
close the bathroom door when Tata Anghelo appeared in front of me, holding a lagaraw
and told me “Pagsyagit dyud kay tigbason tika”.
3) I was begging him not to do what he plans to do. It was then that he entered the
bathroom and told me that, “Dili dyud ta magkaproblema og dali ra dyud ni kung di
kamusukol, talikod!”.
4) I was so afraid that he will hit me with me with the lagaraw and so I followed his
orders and was silently crying. With my back on him, he placed the said weapon on top
of the counter and was about to cuffed me with a wire (alambre) when I turn back to him
and kick his penis and punched him in the face. He then lost his balance and hit his
head in the mirror.
5)When I was on my way out, he pulled my hair with so much force that I hit the floor.
He kicked me in the stomach several times and stopped when I already vomited blood.
6) He again gets the weapon and cut me in my left thigh. I cried in pain but he hit me in
the face and told me to shut up.
7) Consequently, he took his pants and underpants off and seated on the toilet with the
weapon in his hands.
8) Thereafter, he told me to take off my pajamas and underwear. He ordered me to
bend down with head low and buttocks up, my hands on the mouth of the toilet.
9) He inserted his penis fiercely inside my vagina and thrust hastily while still holding the
weapon.
10) He was not satisfied with it that he laid down the weapon and inserted his penis this
time in my butt. I was in deep pain that I have tried to stand up and he then pulled my
hair and hit my head in the toilet twice and I do not know what happen next. I just woke
up in the hospital and my body is so painful.
 IN WITNESS WHEREOF, I have hereunto set my hand this 10th day of April
2022, in General Santos City.

ANGELIE CRUZ
Affiant

SUBSCRIBED AND SWORN to before me this 10th day of April 2022 at Philippine
National Police Station 123, General Santos City. I further certify that I have personally
examined the Affiant and I am satisfied that he/she voluntarily executed and understood
his/her statement.

WALLIE R. BAYOLA
Administering Officer

Doc. No. _____;

Page No. ____;
Book No. ____;
Series of 2015.

ANNEX “B”
HOWARD HUBBARD HOSPITAL

Medical Record Division

Palkan, Polomolok, South Cotabato

MEDICO LEGAL CERTIFICATE

______________________________________________________________________

April 12, 2015

TO WHOM IT MAY CONCERN:

This is to certify that Angelina, 20 years old, with residence

at Koronadal City, was examined and treated in this hospital on April 10, 2022 with the
following findings:

1. brain injury on the left parietal portion of his head

2. multiple contusion at the anterior and posterior chest and abdomen
3. in a non-virgin state physically
4. bruises and lacerations on the anus and the penis
5. Sperm was found on the anus and mouth
6. CAUSE OF DEATH: internal bleeding
 7. TIME OF DEATH: 4:00AM, April 7, 2022

Issued this 12th day of April 2022, for whatever purpose it may serve.

This certificate is issued by authority of the Director:

Angel D. Loccin, M.D.