REPUBLIC OF THE PHILIPPINES

Department of Justice
OFFICE OF THE CITY PROSECUTOR
Puerto Princesa City

DAYUNYOR NO.______________________
Complainant,

-versus-
NO.______________________
___

LEN LEN ROSE , OSKO FOR:

MORENO, PONG PING and
LUDY KAH
Kidnapping and Serious
Illegal
Respondents.
x---------------------------------------x

COMPLAINT-AFFIDAVIT

I, DAYUNYOR, 55 years of age, single, a resident of Pain Street, Barangay San

Jose, Puerto Princesa City, after having been sworn to in accordance with law, do
hereby depose and state:

1. On December 5, 2021, at around 5:30 in the morning, while I was waiting for
my driver near the main gate of Robinsons Palawan, a black van with three
males inside and one woman suddenly stopped, and one of them, who I know
to be Osko Moreno, one of the friends of Lenlen Rose, grabbed me by the hand
and forced me inside their vehicle. I tried to resist the grip of Osko Moreno,
but I was not able to free myself. He successfully forced me into the car, and
the driver, whom Osko Moreno called Ludy Kah, hurriedly sped away.

2. While inside the vehicle, I saw Lenlen Rose and said, "Akin na dapat ang lupa
mo Dayunyor!" I was shouting at Lenlen Rose, asking where they would take
me, and then a certain Pong Ping answered that they wanted to abduct me in
exchange of my signature to transfer the title of Lot 10, Pain Street, Bgy. San
Jose, Puerto Princesa City, which was legally owned by my father and now
occupied by Lenlen Rose. I kept on shouting and resisting that Pong Ping
covered my mouth with a piece of cloth and tightly tied it around my mouth so
that I would not be able to speak. He even tied both of my hands with a rope. It
was so tight that when I tried to free myself, I eventually wounded myself.
3. That after about three (3) or three (4) hours of driving from the time Osko
Moreno forced me in the vehicle, we stopped by a pink house surrounded by
tall trees that looked like an abandoned place. Ludy Kah then dragged me out
of the car, dragged me inside the house, and locked me up in one of the
second-floor rooms.

4. Ping Pong told me that if I tried to escape, he would kill me. He further said
that the only way to get out is for me to accept the proposal of their boss, who
is Lenlen Rose;

5. That seven days have passed and I’m still locked in the room. My mouth was
kept covered so that I would not be able to shout for help. My hands and feet
were also tied to keep me from moving around.

6. On the night of the eight day after being kidnapped, that is December 13, 2021,
Lenlen Rose presented a blank paper saying, "Pipirmahan mo ba ang papel na
ito o ipapatay kita sa kanila!!!” However, I refused to sign the said document
and then Osko Moreno, Ping Pong, and Ludy Kah punched me until I could
not move my body.

7. While I was being punched by Osko Moreno, Ping Pong, and Ludy Kah, I
heard the sirens of a police car and they tried to immediately escape the place
with Lenlen Rose;

8. That when the police entered the place Lenlen Rose, Osko Moreno, Ping Pong
and Ludy Kah escaped at the backdoor of the house;

9. That accordingly, the crime of Kidnapping and Serious Illegal Detention as

provided for under Article 267 of the Revised Penal Code of the Philippines as
amended by R.A 7659 has the following elements:
a) The offender is a private individual;
b) He kidnaps or detains another or in any other manner deprives the latter of
his liberty;
c) In the commission of the offense, any of the following circumstances is
present: (1) the kidnapping or detention lasts for more than 3 days; or (2) it
is committed by simulating public authority; or (3) any serious physical
injuries are inflicted upon the person kidnapped or detained or threats to kill
him are made; or (4) the person kidnapped or detained is a minor, female, or
a public officer.
10. That, in accordance with the aforementioned elements, respondents are private
individuals because they do not hold any public office or act as agents of a
person in authority;

11. That the respondents held me hostage against my will and I was deprived of
my liberty under the threat of being killed by the former;
12. That the the kidnapping and detention lasts for more than eight (8) days and
the respondent threatened to kill me;

13. That I am executing this sworn statement for the purpose of charging the
respondents for committing a crime of Kidnapping and Serious Illegal
Detention.

IN WITNESS HEREOF, I have hereunto affixed my signature this

December 14, 2021, Puerto Princesa City, Philippines.

DAYUNYOR
Complainant/Affiant

SUBSCRIBED AND SWORN to before me, the undersigned prosecutor,

this 14th day of December, in the City of Puerto Princesa, Philippines.

The undersigned Prosecutor certifies that she personally examined the

affiant and that she is satisfied that she voluntarily executed and understood her
complaint-affidavit.

GAND A. LANG
Assistant City Prosecutor

ANNEX “A”

Republic of the Philippines)

Puerto Princesa City )S.S.
 AFFIDAVIT

I, DICK GOODYAN, Filipino, of legal age, single and a resident of Kind Street,
Barangay San Jose, Puerto Princesa City Philippines, after being sworn in
accordance with law, depose and state:

14. That I am the driver of Mr. Dayunyor;

15. That on December 5, 2021, at around 5:30 in the morning, while I was near the
main gate of Robinsons Palawan, a black van with three males inside and one
woman suddenly stopped, and one of them, who I know to be Osko Moreno,
one of the friends of Lenlen Rose, grabbed Mr. Dayunyor and forced him
inside their vehicle. I tried to assist Mr. Dayunyor by following the black van,
but it was too fast;

16. That I immediately informed the guards of the Robinsons Mall of what
happened, and thereafter, reported the incident to the nearby local police
(Attached herewith as Annex “A” is a copy of the missing person report) ;

17. That eight days has already passed and Mr. Dayunyor was still not home, and
nowhere to be found;

18. That at night of December 13, 2021, eight days from the time he was forcibly
taken by respondents , Kiko Sanaol informed me that he also followed the
same balck van and know where they brought Mr. Dayunyor, thus, and so, we
imeediately reported it to the San Pedro Police Station ;

19. That I am executing this Affidavit to attest to the truth of the foregoing and to
support and corroborate the statements contained in the Complaint-Affidavit
executed by Mr. Dayunyor for the purpose of filing a case for
“KIDNAPPING AND SERIOUS ILLEGAL DETENTION" against LEN
LEN ROSE , OSKO MORENO, PONG PING and LUDY KAH .

DICK GOODYAN
Affiant

CERTIFICATION
SUBSCRIBED AND SWORN to before me in the City of Puerto Princesa this 14 th
day of December, 2021. I hereby certify that I have personally examined the above
named affiant and that I am satisfied that the foregoing statements were given by
him voluntarily and of his own free will.

GAND A. LANG
Assistant City Prosecutor

Dick Goodyan’s Affidavit: ANNEX “A”

 MISSING PERSON’S REPORT
San Pedro Police Department
Puerto Princesa City

MISSING PERSON

Name: Alias/Street Relatives:

Dayunyor Name/Nickname Imayunyor (Mother) and
: Yunyor Imeeyunyor (Sister)

Nationality: Height: Weight: Hair: Eyes: Sex:

Filipino 5’8" 125 lbs Brown BLACK MALE

Hat: Jacket/Coat: Shirt: Pants: Skirt/ Shoes:

Green shirt Red Dress: black
jogging shoes
pants

Age: DOB: Social Security Scars/Marks/Tattoos:

55 #: none
XXX-XX-XXXX

Overall Health: Last Seen Health Condition:

Good In good health

Last Seen By: Last Seen Location: Last Seen Last Seen
Dick Goodyan (family Main gate of Robinson Date: Time:
driver) Palawan Sunday, Approx.
December 5:30 in
05, 2021 the
morning

Address: Residence Phone:

Pain Street, Barangay San Jose, Puerto 000000000
Princesa City Business Phone: N/A

Occupation: Employer/School: N/A Employer Address:

Businessman N/A

MISSING PERSON REPORTED BY

Name: Relation: Address: Residence Phone:

Imanyunyor Mother Pain Street, Barangay 0000000
San Jose, Puerto Business Phone: N/A
Princesa City

 
  REPORTING PERSON’S NARRATIVE (Brief narrative of the facts surrounding the missing person
report.)
The missing person was reported by the victim’s family driver,
Dick Goodyan.

 DATE  December 05,

 REPORTING OFFICER James Bonda 2021
REPORTED

December 05,
 SUPERVISING Lata Lapad  O09000 2021
OFFICER  Signature  Unit Number  Date

ANNEX “B”

Republic of the Philippines)

Puerto Princesa City )S.S.

AFFIDAVIT

I, KIKO SANAOL, Filipino, of legal age, single and a resident of Gwapito Street,
Barangay San Manuel, Puerto Princesa City, Philippines, after being sworn in
accordance with law, depose and state:
20. That on December 13, 2021, at around 9:30 in the morning, I saw a black van
stopped in front of the main gate of Robinson Palawan. About four (4) persons
went in the house. One of them is a woman who seems like talking to the three
guys accompanying her;

21. That at first, I did not suspect anything wrong because it is common for me to
see that there are groups of people, male or female, entering said house,but I
know that a certain Lenlen Rose occupied the said pink house;

22. That in the silence of the night of November 5, 2018, at around 9pm, I heard a
sound similar to a broken class. The sound came from the direction of the
house close to mine. And said house is the one where I saw a white Honda
Civic stopped, and where four (4) persons went inside, six days ago;

23. That I went out the house to observe what was happening, and to my surprise,
a lady jumped over the wall, and fell on my yard;

24. That the lady looked so frightened, run towards me and asked me to help her
go home;

25. That the said lady, who introduced herself as Chiang Santos, told me that she
lives in Pasig, and that she was taken by a certain Jay Nilaga six days ago, and
detained her. She further said that someone helped her escape from the house,
and broke the window of the room where she was locked, so that she can get
out without using the from door;

26. That I quickly started my car, and drive her home;

27. That upon reaching the house address given by Chiang, she hurriedly alighted
the car, run toward the house, knocked at the door and shouted for the people
inside to open it.There, her parents and sister Marigold, finally were reunited
with Chiang;

28. That I am executing this Affidavit to attest to the truth of the foregoing and to
support and corroborate the statements contained in the Complaint-Affidavit
executed by Chiang Santos for the purpose of filing a case for “KIDNAPPING
AND SERIOUS ILLEGAL DETENTION" against JAY NILAGA.

JERICHO KORALES
Affiant

CERTIFICATION
 th
SUBSCRIBED AND SWORN to before me in the City of Mandaluyong this 25
day of November, 2018. I hereby certify that I have personally examined the above
named affiant and that I am satisfied that the foregoing statements were given by
her voluntarily and of his own free will.

ASSISTANT CITY PROSECUTOR

MANDALUYONG CITY