Republic of the Philippines

Department of Interior and Local Government

PHILIPPINE NATIONAL POLICE
Caraga Regional Office 13
Libertad, Butuan City

JOHNA REYES TANJAY Case no.____________

Complainant

Versus – For:

“GRAVE MISCONDUCT”, “GROSS

IMMORALITY” and “CONDUCT
PREJUDICIAL TO THE
SERVICE”

NOEL CAFÉ TANJAY

Respondent
/----------------------/

COMPLAINT
-AFFIDAVIT
I, JOHNA REYES TANJAY, of legal age,
married to complainant, Filipino and
presently living in Butuan City, UNDER
OATH, hereby depose and state –

1. I am executing this Affidavit to

file a formal admistrative complaint
against my husband NOEL CAFÉ TANJAY, who
is amember of PNP-Agusan del Sur, of
legal age and a resident of P-1, Sta.
Irene, Bayugan City, for “GRAVE
MISCONDUCT”, “GROSS IMMORALITY” and
“CONDUCT PREJUDICIAL TO THE SERVICE” ;
2. Ever since our marriage, my husband
has repeatedly engaged in extra-marital
affairs, and when caught, he would
immediately end it.

Being a good and faithful wife, I would

always forgive him, for the sake of our
children’s and of their future.

3. However in 2019, I began hearing

humors about my husband’s infidelity.

Allegedly, he has a mistress and

they have been living together, as a
couple, in Butuan City.

At first, I did not believe said

rumors, however, when my husband began
spending less time with us and he
started getting loans without my consent
and for no reason at all, I became to
suspect that the same were true.

As a result, I would constantly

monitor the whereabouts of my husband
and for countless times, I caught him
lying as to where he was.

My husband would tell me that he was

on duty at the Police Station (as he is
a member of the PNP), but when I would
call up the station or go there to check
on him, he was not there.

4. These incidents resulted to marital

altercations, wherein my husband would
physically assault me.
 He would also threaten me and our
children with physical harm.

He also made threats to leave us and

withhold financial support.

These threats and abuses made me

think twice about leaving him or
reporting him to the authorities.

5. Despite all the pain, distress,

sleepless nights , anguish and hurt that
my husband caused me, I just kept the
whole thing private and acted mum about
it.

6. However, in May 2019, my whole world

came crumbling down, when my husband
told me that he is now a member of the
IP community, and can now marry another
woman.

To my greatest pain, he then asked me to

sign a document wherein it was made to
appear that I gave my consent for him to
get a second or third wife.

7. That incident was the lowest point

in my life. I soon got depressed and had
trouble sleeping.

8. For several days I could not sleep

and had to take sleeping pills just to
get some. But even that did not do much
as the pain was too much to bear.

9. By reason of my said document, my

husband become more bolder in his
 infidelity. He would divide his time and
income with his original and second
families.

10. It did not take long for him to

suggest that I, his other woman and him,
share the conjugal bed and act like we
are one family.

He would described to me his sexual

exploits with his other woman and would
often ask me to be open minded to a
threesome.

11. I felt so dirty and worthless

because of what my husband did to me.

He did not only respect me as his wife,

as a mother to his children, as a woman
but also violated the sanctity of our
marriage.

12. My repeated refusal to give in to

his wants, led to more spousal abuse,
psychological, financial and physical.

13. He would tell all our children that

it was all my fault that we fight.

He would tell them that I was a bad

mother and wife, since I was not willing
to sacrifice for him and for the family.

14. I endure all his abuses hoping that

he would eventually changed his ways.

All I could do was to keep the pain and

hurt all to myself hoping that
 eventually all will be will in God’s due
time.

15. However, the situation worsened as

it did not take long for me to learn
that my husband and his mistress already
had a child.

16. Apparently this is the reason my

husband began dividing his time as well
as his income between us and his other
family.

17. At one time, I went to Butuan City

and met a friend of a friend who told me
that I must be the mother of the
classmate of her child , when I told her
that I was wife of my husband.

I could not hold my tears when I went

home that day.

All along my husband has been lying.

18. My husband’s child with his mistress

is already 7 years old and it means that
their relationship has been going for at
least 7 to 8 years.

19. It appears that my husband has been

unfaithful and has been lying, to me for
the last 8 years .

It dawned upon me that he and his

mistress are in it for the long haul and
indeed serious in us living together as
one family.
20. I wanted to kill myself because of
that discovery and realization as the
pain and hurt was so much to bear.

Were it not for three kids and the

support of my family and friends, I
would have taken my own life already.

21. For the sake of my children, I

decided to give my husband an ultimatum
to change.

22. However, things turned for the

worst. There were more marital
altercations and abuse, the last one was
on January 29, 2021, wherein complainant
almost choked me to death.

23. Said incident led me to report it

to the authorities.

It resulted to my filing of a criminal

complaint against him for violation of
the VAWC law, before this Office, which
I withdrew as it was incomplete on many
material points.

24. However, instead of being repentant,

my husband filed a malicious complaint
against me for adultery, to destroy my
credibility and to force me to withdraw
the complaint that I filed against him.

25. Worst, he used my son to do it as he

verily knows that he could be held for
perjury as I have always been faithful
to him.
26. He made it appear that my son
witnessed the imagined adulterous affair
I allegedly have with my co-respondent.

27. If it were true that I and my c0-

respondent are in an adulterous affair,
I would have kept it a secret.

I would NOT have brought my son or any

of my daughters to these alleged
encounters between my co-respondent in
said complaint, if the same really
happened or if there was something to
hide.

28. It is noteworthy to mention that my

son is already 17 years old and not an
innocent child as what complainant is
portraying him to be.

29. In exchange for his perjurious

testimony, my husband allowed my son and
his girlfriend to live together despite
them being minors, thus contributing to
their delinquency.

30. To date, I am still receiving

threatening text messages from my
husband.

I have moved out of the conjugal

dwelling and live with relatives in
Butuan City, for my safety.

31. Also, by reason of the husband’s

infidelity, he is left with only a Php.
9,000.00 monthly net pay, which is not
enough to feed us – his first family.
 Yet he continue to extra-marital
affairs.

He repeatedly made several loans without

my knowledge, the proceeds of which,
never redounded to the benefit of our
family.

32. Clearly, my husband, NOEL CAFÉ

TANJAY, should not be a member of the
PNP. He is a disgrace to said
organization.

His acts constiturte GRAVE MISCONDUCT,

GROSS IMMORALITY AND CONDUCT PREJUDICIAL
TO THE SERVICE.

His immediate dismissal fromm the PNP

organization is just proper.

33. To prove the foregoing. Attached

hereto are the following:

a. Photos of SMS exchanges between me

and my husband – collectively marked
as ANNEX “A”;

b. Photos of SMS exchanges between my

husband and my mistress –
collectively marked as ANNEX “B”;

c. Screenshot of the personal messages

which my husband sent to our eldest
daughter, marked as ANNEX “C”;
 d. Copy of the waiver that my husband
had me sign against my will, marked
as ANNEX “D”.

e. Affidavit of my daughter, marked as

ANNEX “E”.

f. Complaint that PNP Bayugan City

filed against my husband, marked as
ANNEX “F”.

34. Moreover, I would like to state

herein that evidently, my husband used
his influence and membership in the PNP,
in ensuring that PNP Bayugan City file a
useless and patently incomplete criminal
complaint against him (see ANNEX “F”),
which I was forced to withdraw to avoid
its dismissal on the merit.

35. I specificifically gave a detailed

narration of facts to the concerned
personel of PNP Bayugan City but what
they made me signed was a complaint for
marital psychological abuse (punishable
under RA 9262), which absurdly did not
even state that I was psychologically
abused.

What said office made was a complaint

for physical injuries without any
medical certificate attached to support
it or even an allegation as to the
extent of my injuries.

Apparently, said complaint was prepared

and submitted to be dismissed.
 36. While my complaint against him was
defective, the complaint that my husband
filed against me, thru the same office,
was complete and well prepared (albeit
perjurious).

37. I am now apprehensive that this

instant complaint will also be dismissed
because that my husband will again use
his influence on the investigating
officer.

I therefore pray that my husband, NOEL

CAFÉ TANJAY be immediately put in
restrictive custody, pending
investigation and resolution of this
administrative complaint.

38. I execute this affidavit to attest

to the truth of the foregoing. I pray
for the immediate dismissal of my
husband from the service.

I likewise pray to the PNP leadership

that, pending litigation, my husband,
NOEL CAFÉ TANJAY be put unto restrictive
custody.

IN WITNESS WHEREOF, I have hereunto set

my hand this
_______________________________at Butuan
City, Philippines.

JOHNA REYES TANJAY

Affiant-Complainant
SUBCRIBED AND SWORN to before me this
____________________________ at Butuan
City, Philippines, affiant exhibiting to me
her competent evidence of identity, as
above-indicated, thus satisfactorily having
proven her identity to me.

I further certify that I have personally

examined the affiant and I am convinced and
satisfied that she voluntarily executed the
foregoing Complaint-Affidavit and
understood all the contents hereof and that
they are true and correct as to her own
personal knowledge.
 VERIFICATION AND CERTIFICATE OF
NON-FORUM SHOPPPING

I, JOHNA REYES TANJAY, of legal age, married

to respondent, Filipino and presently living in
Butuan City after having been duly sworn to in
accordance with law, hereby, depose and say:

I am the Complainant in this complaint and I

have caused this Complaint to be prepared; that
I read and understood its contents which are
true and correct of my own personal knowledge
and/or based on authentic records; It is not
being presented for any improper purpose, such
as to harass, cause unnecessary delay, or
needlessly increase the cost of litigation; The
claims, defenses, and other legal contentions
are warranted by existing law or
jurisprudence, or by a non-frivolous
argument for extending, modifying, or
reversing existing jurisprudence; The factual
contentions have evidentiary support or, if
specifically so identified, will likely have
evidentiary support after availment of the modes
of discovery under these rules; and The
denials of factual contentions are
warranted on the evidence or, if
specifically so identified, are reasonably
based on belief or a lack of information.
That I have not commenced any action of
proceeding involving the same issue in the
Supreme Court, the Court of Appeals or any other
tribunal or; that to the best of our knowledge,
no such action or proceeding is pending in the
Supreme Court, the Court of Appeals or any
tribunal or agency, and that, if I should learn
thereafter that a similar action or proceeding
has been filed or is pending before these Courts
of tribunal or agency, I undertake to report
that the fact to the Court within five (5) days
therefrom.
 IN WITNESS WHEREOF, I have hereunto set my
hand this _____________________________ in
Butuan City, Philippines.

JOHNA REYES TANJAY

Affiant-Complainant

SUBSCRIBED AND SWORN to before me hand this

_________________________in Butuan City,
Philippines.