REPUBLIC OF THE PHILIPPINES] ANGELES 

CITY ] S.S COMPLAINT AFFIDAVIT I,

KRISHA CYRILLE D. LUMBANG , Filipino, of legal age, and with residence at 304 2nd St.
Marisol Barangay Ninoy Aquino, Angeles City after having been duly sworn in accordance
with law, hereby depose and state that: 1. I am the live-in partner of JOEL A. TORRES.
During our relationship, we begot two children. Our first child is Angel Alexish L.Torres, born
on July 26, 2009 and our second child is Angelica Ayanna L. Torres, born on August 26,
2011. Copies of their Certificates of Live Birth are hereto attached and marked as Annexes
“A†and “B†respectively; 2. I first met Joel while I am studying at Angeles
University Foundation sometime in 2008. A few weeks later, Joel and I began to date. We
started our relationship as a couple on September 5, 2008. 3. During the start of our
relationship, we often fight because he is constantly engaged with casual relationships with
other women and he always have drinking sprees with his friends. 4. Our classmates found
out that he and his friends brought some women in his apartment. Thinking that I spread
such news, Joel got mad at me and threw a cup on my foot. 5. After six months of being
together, I found out that I am pregnant. I told Joel that I am four months pregnant with our
first child. Instead of consoling me during those depressing times, he decided to end our
relationship and leave me. 6. Later on, my family found out that I am pregnant. They
compelled Joel and his family to plan our wedding and give financial support. 7. His family
usually buys food for me during the course of my pregnancy. However, they don’t pay
for my prenatal checkups and the vitamins I need to take while I’m pregnant. 8. When I
gave birth to our first child, my family and Joel’s family paid for the hospital bill. 9. My
parents insisted that our daughter shall use our surname and not Joel’s surname
because we are not yet married and their family does not give full financial support. 10.
Later on, Joel’s family refused to provide financial support. They only give irregular
supply of formula milk to my daughter. They claim that they are not compelled to give
financial support since my daughter doesn’t use their surname. 11. Few months after
giving birth, I enrolled in Holy Angel University to continue my studies. On the other hand,
Joel worked at KFC in order to provide for our daughter’s needs. 12. While working at
KFC, he had a relationship with another woman. I confronted him about it but he got mad at
me and hit me. I obtained several wounds on my back after such incident. 13. Despite his
violent tendencies, I still go to their house in Lubao every weekends so that my daughter
can spend time with her father. 14. Thereafter, I got pregnant with our second child. All the
hospital expenses we incurred were paid by Joel’s family. 15. After giving birth to our
second child, we stayed at my grandmother’s house. Joel worked at SM Appliances to
provide for our children’s needs. Since his salary was not enough to sustain our daily
needs, his family gives us P3,000.00 per month. 16. Before our eldest daughter started to
go to school, I processed the necessary requirements in order to change her surname.
Using my own money, I was able to change her surname from Lumbang to Torres. 17. After
working at KFC for 3 months, Joel started to work at Coca Cola Company. He gives me his
monthly salary amounting to P4,000- P5,000 and he buys milk for our two daughters. 18.
While working at Coca Cola Company, I found out that he had a relationship with a woman
named Myla Cabrera. I discovered their relationship while browsing the inbox of his cellular
phone. I’ve seen their exchange of text messages consisting of “I love you†and
“I miss youâ€. I confronted Joel about it but he was furious because I checked his
cellular phone without his permission. 19. Few days later, he apologized to me and
promised that he will never do it again. I forgave him and we decided to live together at my
parent’s house. We planned our wedding but due to unavoidable circumstances, it did
not push through. 20. While we were living together at my parent’s house, Joel was
unemployed. All of our expenses and needs were paid and provided for by my parents and
brother, Errol Joseph Lumbang. 21. After several months of being unemployed, my brother
got mad at Joel and told him to leave our house. Joel went back to his parents in Lubao and
I decided to follow him and bring my children there so we can live as a family. 22. Few days
after we have settled in his parent’s house, Joel was again employed by Coca Cola
Company. 23. After six months of work, Joel was terminated by the Coca Cola Company.
Our family solely depend on my income from my part time business consisting of direct
selling, gadget selling, loan commission and load retailing. 24. While he is unemployed, he
had a relationship with another woman. He created a new Facebook account named Joel
Uchiha to facilitate his philandering. When I confronted him about it, he punched me on my
arm. After our fight, he asked for forgiveness and pleaded that he will never do it again. 25.
However, a similar incident occurred again. I saw a text message from another woman
saying that she loves Joel and not her boyfriend. I was about to leave him but his mother
consoled me and asked me not to leave her son. 26. Few months later, I found out that Joel
was communicating with his ex-girlfriend named Jhoana dela Rosa thru chat. Joel was
sending messages like “I miss you na†to Jhoana. I was so angry that I kept on
shouting at Joel. He hit me with my daughter’s guitar toy. 27. We also had another
argument after I asked him to pay for the cellular phone I bought for him. He kicked and
punched me in front of our eldest daughter. He also bit my arm. 28. After Christmas, we
reconciled and started to plan our wedding. However, his parents told me to wait for another
five years because they are going to the United States. I didn’t agree but they told me
that I have no other choice. 29. I continued to work hard in order to provide for the needs of
our family. I usually go home late and I am too tired to help with the household chores at
times. One night, Joel shouted at me saying, “Pinapagod mo ang nanay ko! Tumulong
ka naman!†I ignored him to prevent another argument but he kicked me and threw the
remote control to me while I was holding our youngest daughter. Our daughter got hit by the
remote control and cried. 30. Few days after our fight, his mother complained that I am lazy.
We got into another argument wherein he slapped me. 31. Despite the fact that he is
unemployed for several months, Joel still found an opportunity to have a relationship with
another woman named Camille. I found out that he always texts her and drives her to work.
I confronted him about it but he became violent again. He kicked me, bit my arm and
scratched me. 32. Whenever I ask him to let me use his cellular phone, he gets angry. One
night, he punched me on my chest, nose and nape after refusing to give me his cellular
phone. He kicked me and dragged me towards our room. All of these were witnessed by
our eldest daughter. She was crying and begging his father to stop hitting me. 33. As I could
no longer bear his treatment to me, I decided to go back to my parent’s house in
Angeles City and bring my two daughters with me. 34. I went back to Lubao to get my
things and to ask Joel’s mother to pay her debts to me. However, his mother refused to
give my things and pay her debts. Due to this incident, Joel and I got into another fight. He
hit my head with his shoe, he punched me and pushed me. 35. Few days later, Joel begged
me to forgive him and marry him. He wants us to rent a house and live together as a family.
Thinking that he finally became a responsible father, I forgave him and agreed to marry him.
He promised me that his parents will go to our house in Angeles City to ask for my
parent’s approval. However, all of his promises were mere empty words. 36. One day,
he confessed that he had a relationship with another woman. According to him, they had
sexual intercourse but he used contraceptives. I was hurt but I forgave him. All I want is for
us to get married and start a new life. 37. His parents went to our house to talk to me. I
thought they will convince my parents to allow us to get married. However, they told me that
they have no plans of letting us get married. 38. I told his parents that Joel was cheating on
me all this time. Joel was so angry at me and he kept on using foul language directed
towards me. He kept on sending messages to me thru chat saying “Anak puta ka!â€.
39. On April 2, 2016, I found out that Joel had a relationship with Mary Jane Espinoza, his
coworker at Handy Man. I sent a message to her thru Facebook chat to confirm their
relationship. According to her, they have been in a relationship since March 2016. She
confessed that she is aware that Joel has a family. However, she claims that Joel reassured
her that he no longer has any ties with his former family. 40. I was really hurt so I decided to
confront the two of them at Handy Man. Joel told me that our relationship has ended and
there is nothing left for us to settle. 41. After that incident, I decided to finally leave him. All I
am asking from him is to give financial support to our children. 42. However, his salary was
not enough to sustain the needs of our children. There was an instance when our eldest
daughter could not take her examination because we were not able to pay her tuition. At
times, we cannot get her report card from school because we are not able to settle her
account. 43. All the foregoing instances have caused so much emotional and financial
distress not only to me but to our two children. 44. To make the situation worse, Joel
refused to give financial support starting from March 2016 up to the present. 45. Due to his
failure to give financial support, I was forced to ask for money from my mother and siblings
so that my two children will be able continue their studies. At present, my children and I
have been totally dependent for support from my family. 46. I am executing this affidavit to
attest to the truth of the foregoing facts and circumstances. AFFIANT FURTHER SAYETH
NAUGHT. IN WITNESS WHEREOF, I have hereunto set my hand this ____ day of
_______ 2016, Angeles City. KRISHA CYRILLE D. LUMBANG Affiant SUBSCRIBED AND
SWORN to before me this _______ day of _______ 2016, Angeles City, Philippines and I
FURTHER CERTIFY that I have personally examined the affiant and I am satisfied that
he/she has read and personally understood the contents of her foregoing “Complaint-
Affidavitâ€. ___________________________ Investigating Prosecutor