AFFIDAVIT-COMPLAINT OF

____________

I, ___________, of legal age, single, Filipino and a resident of _____________,

Butuan City, under oath, hereby depose and say, that:

1. I hereby executed this Affidavit-Complaint to formally charge a certain _____________ all

of legal age, Filipino and residents of Butuan City, for the crime of libel under Article 353 of
the Revised Penal Code;

2. Sometimes on June 17, 2020 at around 9-10pm, respondents by collaborating with each
other, malign my person, character and honor, caused the publication through FB comment,
publicly posted by respondents which says:

_______________

3. That prior to the above-quoted comments, respondent _______________ made a post in her
FB account which says:

_________________

Attached are the full text of libelous article hereto referred as Annex “A”-“A-6”.

4. Said conversations published by the respondents between themselves through post and
comments, without the ethical standards to be observed in social media postings, contained
imputations with bad intentions and unjustifiable motives, purposely to malign, dishonor,
discredit, insult and assassinate my character and good reputation to the public as well as to
my family,

5. The afore-quoted portion of the FB post and comments authored by respondents, created in
the minds of the readers that I am a Gold Digger who took advantage of girlfriends for
money.

6. The said FB Post earned replies and various negative comments from my friends and those
people who were able to read it which clearly imputed some malicious acts towards me as a
person and connotes derogatory attribution on my honest and decent reputable character not
only as a boyfriend but as a person.

7. I believe that I am the one being alluded in the said FB Post and Comments because even
one of my friends who was able to discover and read the same was able to identify who is
the person respondents are talking about.

Copy of the Affidavit of ______________ is herein attached as Annex “B”.

 I will also attach our conversation with respondent ______________, previous to these post
and comments mentioned above as Annexes “C”-“C-16”, showing that I am the one they
referred to.

8. The said post and comments written and published by the respondents has no factual basis,
is highly speculative and all false statements made to destroy my reputation as a person.
Respondents were motivated by bad faith in the publishing of the said online
comments/conversations online through fb to defame, embarrass and discredit me to my
colleagues, friends, and family;

9. That even the same is true, it will not excuse them for the crime because they have no good
intention in doing the same. Under the crime of Libel, every defamatory imputation is
presumed to be malicious, even if it be true, if no good intention and justifiable motive for
making it is shown.

10. The libelous comments and post having been published through Facebook, a website
accessible to and is made available to the general public was read by the said general public,
including my colleagues, friends and family among others;

11. Due to the said malicious public imputations by respondents, I suffered and continue to
suffer serious anxiety, besmirches reputation, mental anguish, sleepless nights, not to
mention the damage they have caused to my career, reputation and honor among the readers
and the general public;

12. Due to such grossly unjustified malicious and libelous imputations, I therefore pray that
respondents be made to pay jointly and severally, the damages I was made to suffer as a
result of the online published article in whatever amount the Honorable Court deems
sufficient and proper together with the attorney’s fees and the cost of this suit.

13. I hereby execute this affidavit-complaint to attest to the truth of the foregoing facts and
hereby request the investigating prosecutor to file the crime of libel under Article 353 of the
Revised Penal Code against the herein respondents.

In witness whereof, I have hereunto set my hand this _____, 2020 in Butuan City,
Philippines.

_____________
Affiant
 Subscribed and sworn to before me this ____ day of ___ 2020, at Butuan City,
Philippines. Complainant-affiant exhibited to me her valid ID as written above. I hereby
certify that I have personally examined the Complainant-affiant and I am convinced that he
executed this Affidavit-Complaint freely and voluntarily and understood the same.
Doc. No ___;
Page No. ___;
Book No ____;
Series of 2020.