DEPARTMENT OF INTERIOR AND LOCAL GOVERNMENT

TABUK CITY, KALINGA

To: Hon. ANTHONY MANOLO I. BALLUG

Provincial Director/CESO V
DILG Tabuk City, Kalinga

AFFIDAVIT OF COMPLAINT
I, LUIS B. DUGA, of legal age, married, Filipino citizen and with
residence and postal address at Alliguia, Pinukpuk, Kalinga, Philippines, after
having been duly sworn to in accordance with law hereby depose and state
that;
1. I am the registered owner and possessor of a registered parcel land
embraced under Katibayan ng Orihinal na Titulo Blg.
CARP2015000763 containing an area of THREE THOUSAND TWO
HUNDRED TWENTY-ONE (3,221) located at Allaguia, Pinukpuk;

2. The land was part of my inheritance from my father PABLO C. DUGA

who was formerly the possessor of the above-mentioned land
formerly represented by a Declaration of Property with Tax
Declaration No. 2002-04003-0513;

3. On July 1, 2022 I together with companions went to the site of land

for the purpose of having it fenced to secure its boundaries. While we
were erecting the fence, Barangay Captain Jaime Gupaal, without
prior notice, suddenly shouted, in an angry loud and voice, for us to
stop the fencing and to have a talk regarding the ownership of land
on the premise that a certain Junie Banatao has a claim over my
property;

4. On July 19, 2022 I together with Engineer Pepe Lacyao went back to
land to have it surveyed. However, when we arrived there, we were
stopped by Junie Banatao who was accompanied Barangay Captian
Jaime Gupaal. Junie Banatao, on that day, stated that we can not have
the land surveyed for the reason he owns the same on the basis of an
unverified tax declaration covering my land;

5. Further, Barangay Captain Jaime Gupaal ordered me to stop

introducing any improvements on the land and prohibited from
entering into to my own titled property. All of this without the
benefit of a prior hearing and consultation;
 6. On the other hand, Barangay Captain Jaime Gupaal, on one of our
meetings regarding the settlement of our differences with Junie,
categorically stated that Junie Banatao can make any improvements
in my titled property even if his claim is entirely based on a tax
declaration;

7. By reason of the above circumstances, I have been deprived of my

lawful right over my land and had suffered moral and material
damages resulting from the evident partiality of our own barangay
chairman;

8. On basis of the forgoing, I am filing a case for violation of section 3,

Par c. of Republic Act No. 3019 or The Anti-Graft and Corrupt
Practices Act, to wit:

(e) Causing any undue injury to any party, including the

Government, or giving any private party any unwarranted
benefits, advantage or preference in the discharge of his
official administrative or judicial functions through
manifest partiality, evident bad faith or gross inexcusable
negligence. This provision shall apply to officers and employees
of offices or government corporations charged with the grant of
licenses or permits or other concessions.
9. This affidavit is executed attest to the veracity and truthfulness of the
foregoing declarations and for all legal intents and purposes this may
serve.
IN WITNESS WHEREOF, I have hereunto affix my signature this 25th
day of August 2022 at Tabuk City, Kalinga, Philippines.

LUIS B. DUGA
Affiant
PhilHealth ID No. 02-050327065-0

SUBSCRIBED AND SWORN TO BEFORE me this 25th day of August

2022 at Tabuk City, Kalinga, Philippines. Affiant personally appeared, and
known to me to be the same person who executed the foregoing instrument
and acknowledged to me that the same is his free and voluntary act and deed.

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Book II
Series of 2022
 VERIFICATION/CERTIFICATION
I, LUIS B. DUGA, of legal age, married, Filipino citizen and with
residence and postal address at Allaguia, Pinukpuk, Kalinga, Philippines, after
having been duly sworn to in accordance with law hereby depose and state
that:
1. I am the Complainant in the above-entitled case;
2. I have caused the preparation and filing of the foregoing
complaint;
3. I have read the contents thereof and all the allegations therein are
true and correct to the best of my own personal knowledge and based
on authentic records and documents;
4. The complaint is not filed to harass, cause unnecessary delay, or
necessarily increase the cost of litigation;
5. The factual allegations therein have evidentiary support or, if
specifically, so identified, will likewise have evidentiary support after a
reasonable opportunity for discovery;
6. I hereby certify that I have not commenced any other action or
proceedings involving the same issues and the same parties in any
court, the Court of Appeals or Tribunal or Quasi-judicial Agency, and to
the best of my own personal knowledge and belief, no such other action
or proceeding is pending before any Court, Tribunal, or Agency, that if I
should thereafter learn of similar action or proceeding before any
Court, Tribunal, or Agency, I will personally inform the Honourable
office of the same within five(5) days from knowledge thereof.

IN WITNESS WHEREOF, I have hereunto set my hand this 25th day of

August 2022 at Tabuk City, Philippines.

LUIS B. DUGA
Affiant
PhilHealth ID No. 02-050327065-0

SUBSCRIBED AND SWORN TO BEFORE me this 25th day of August

2022, at Tabuk City, Philippines. Affiant personally appeared known to me
who exhibited to his valid identification card to prove his identity known to
me to be the same person who executed the foregoing instrument and
acknowledged to me that the same is his voluntary act and deed.
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Book II
Series of 2022