Republic of the Philippines

Department of Justice
National Prosecution S ervice
Office of the City Prosecutor
General Santos City
People of the Philippines,
Plaintiff,-
 
versus -  CRIMINAL CASE N0. 23458
FORCIBLE ABDUCTION
WITH RAPE
JULIO JOSE
234 Pioneer Avenue, General Santos City.
Accused.
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COMPLAINT

The undersigned accuses Julio Jose of the crime of Forcible Abduction with Rape,
committed as follows:

That on or about July 9, 2012, in the City of General Santos, Philippines, the said accused,
with lewd designs, did then and there willfully, unlawfully and feloniously abduct, take and
carry away the undersigned complainant while coming out of a toilet in her home at 113
Magsaysay, Avenue, in said City, by means of force, violence and intimidation to wit: by
pulling her and forcing her to walk, at the same time pointing at her a gun and threatening to
kill her should she cry out for help, succeeded in bringing her to ride in his car, where they
rode going to the house of the accused’s Uncle Sam where the said accused, by
means of force, violence and intimidation, succeeded in having sexual intercourse with
her against her will.

Contrary to law.
KATERINA MONTENEGRO
Complainant

SUBSCRIBED AND SWORN TO before me this 23th day of February, 2023, in the City
of  General Santos, Philippines, by Katerina Montenegro, the complainant.

______________________________ 
Assistant Prosecutor