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AFFIDAVIT–COMPLAINT

I, NELSON T. LEONARDO, Filipino, of legal age, with

residence and postal address at Rafaella Subd., Makinabang,
Baliuag City, Bulacan and with mailing address at c/o J
PERALTA LAW OFFICE, 376 B.S. AQUINO AVE., TANGOS,
BALIUAG CITY, BULACAN, where subpoena, writs, resolution
and other processes of this Honorable Office may be served,
after being duly sworn in accordance with law, hereby depose
and say, THAT:

1. I am the duly authorized representative of complainant

Jesus is our Shelter Church International Ministry, Inc.,
(JSCIMI), a non-stock religious corporation duly organized and
existing under Philippine Laws, with office address at 668
Taal, Pulilan, Bulacan. Copy of the Secretary’s Certificate is
hereto attached as Annex “A”.

2. Respondent MARK ANTHONY M. REYES, II, is a

Filipino, of legal age, with last known address at 787 Taal,
Pulilan Bulacan where subpoena, writs, resolution and other
processes of this Honorable Office may be served.

3. JSCIMI is a religious non-stock religious corporation,

duly registered with the Securities and Exchange Commission
on February 10, 2004. Its principal and business address is
located at 668 Taal Pulilan Bulacan. On the same address,
JSCIMI constructed/established its Church where its
members congregate and conduct their religious activities.
Copies of the Articles of Incorporation and General Information
Sheet are hereto attached as Annexes “B” and “C”,
respectively.

4. Since 2004 and up to the present, JSCIMI has been in

possession of the subject property and in fact
established/constructed a Church therein. Copy of the
Certification from Barangay Taal is hereto attached as Annex
“D”.

5. On July 24, 2017, a Contract to Sell was executed

between Maria Lourdes Trinidad and JSCIMI (represented by
respondent’s father Mark Anthony Reyes) for the purchase of
the said property covered by TCT No. RT-63270 (T-242945).
Copy of the Contract to Sell and TCT No RT-63270 (T-242945)
are hereto attached as Annexes “E” and “F”, respectively.
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6. In compliance with its obligation under the Contract to

Sell, JSCIMI paid on installment the purchase price of the
above mentioned properties. Copies of the proof of payments
are hereto attached as Annexes “G” to “G-8”.

7. Last January 29, 2023, Anita, C. Adriano, a member of

the board of JSCIMI, informed me through her cellphone that
there were people who unlawfully entered and started
barricading and fencing the premises of the Church.

8. I immediately proceeded to the Church and saw more

or less fifteen (15) persons, who forced their way on the
property and constructed fence over the property where our
Church was built. There is already a “NO TRESPASSING”
sign hanging on the fence. Incidentally, one of our board
members Norvin C. Flameno happened to be there and
confronting the said individuals about their unlawful entry
and illegal fencing of the property.

9. I asked the said individuals why and who authorized

them to enter, fence and barricade the premises of the
Church, but respondent Mark Anthony D. Reyes II, the son of
our former Pastor Mark Anthony Reyes arrogantly answered
that he is the owner of the said property.

10. I asked him when he became the owner of the

property and if he has the means to buy it but he insisted on
his claim of ownership of the property.

11. Despite our protestation and vehement objection,

respondent Mark Anthony D. Reyes II and his cohorts
continued to fence the Church property. We were not able to
prevent them from fencing the property because we were
clearly outnumbered. We were even threatened with lawsuit by
Mark Anthony D. Reyes. Luckily, my wife Mallorie R.
Leonardo, Church-members Norvin C. Flameno and his son
Prince Norbin Flemeno, Joselito Ramos were also present and
were able to witness and document the incident. Screen
capture of the video footage are hereto attached as Annexes
“H” to “H-” and the video footage (USB) is hereto attached as
Annex “I”. Copies of the Affidavits of Mallorie R. Leonardo,
Norvin C. Flameno and Joselito Ramos are hereto attached as
Annexes “J”, “K” and “L”. I also reported the said incident to
the barangay as evidenced by the blotter hereto attached as
Annex “M”.
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12. On February 1, 2023, we visited again the Church

and we noticed that the fence with a “NO TRESPASSING” sign
was adjusted so much so that it occupied a larger portion of
the Church property. Photograph of the fence is hereto
attached as Annex “N”.

13. As a result of the illegal fencing, we could no longer

access the property we regularly used for almost two decades
for our religious and other Church activities.

14. Due to this predicament, JSCIMI, engaged the

services of a lawyer, who sent a demand letter dated February
3, 2023 to respondent Mark Anthony M. Reyes, II, for him to
remove the illegal fence and allow JSCIMI access to the
property but to no avail. Copy of the Demand Letter dated
February 3, 2023 and LBC Receipt are hereto attached as
Annexes “O” and “O-1”, respectively.

15. I am executing this Affidavit-Complaint, to attest to

the truth of all the foregoing and to support the Complaint for
Grave Coercion, Other forms of Trespass, and malicious
mischief, against respondent Mark Anthony M. Reyes, II.

IN WITNESS WHEREOF, I have hereunto affixed my

signature this ___ day of February 2023 in _______________.

NELSON T. LEONARDO
Affiant

SUBSCRIBED AND SWORN to before me this ____ day of

_____________ February 2023 in ___________________.

_____________________________
Asst. Provincial Prosecutor

CERTIFICATION

I hereby certify that I have examined the affiant and I am

satisfied that he voluntarily executed and fully understood his
affidavit.

_____________________________
Asst. Provincial Prosecutor