Republic of the Philippines )

City of Zamboanga. . . . . . . . . ) s.s.

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JOINT AFFIDAVIT-COMPLAINT

We, ELVIRA VICENTE and MARIBEL DATOLIO, both of legal

age, married, Filipino citizens, and residents of Barangay Cabatangan,
Zamboanga City, after having been duly sworn to an oath in accordance with
law, hereby depose and say that:

We are Defendants in a damage suit filed by ANGELA B. DATOLIO

before the Municipal Trial Court, Branch ___, Zamboanga City, where one
of her witnesses is JHULGANDHI CARMIAN PAJIJI who, at the inception
of credit transaction with said Complainant was her caregiver, but later
claims after case filing that he is her husband even without proof of alleged
marriage;

On February 14, 2023, at or about 8:30 o’clock in the morning, we

were outside the courtroom together with our counsel to attend mediation set
for said case when we saw both ANGELA B. DATOLIO and
JHULGANDHI CARMIAN PAJIJI also with their counsel;

JHULGANDHI CARMIAN PAJIJI then opened the courtroom’s

door, and without provocation, he turned his face and started pointing
fingers towards us while shouting, “Walang hiya kayo, mga estafa kayo,
mapreso na kayo… mag-ingat lang kayo! Cuidao lang kamo!”, which
translates as follows: “Shameless you, swindlers and con-artists! Beware!
Beware!”;

Such aggression was loudly spoken that many of those at the scene,
including the court personnel of MTC-Branch ___, were alarmed by his
threats unto us, and we felt so embarrassed that he had publicly accused us,
more so, that no case for estafa is filed against us by anyone because the suit
filed against us was a claim for damages arising from pecuniary obligation.
Clearly, his utterance was solely to threaten and maliciously defame us in
public;

Though we were shamed by his deed, we still entered the courtroom

to attend our scheduled mediation, and as we tendered complete payment of
our debt to our creditor, ANGELA B. DATOLIO, witness JHULGANDHI
CARMIAN PAJIJI kept meddling to discourage complainant from receiving
our payment, thus preventing parties to amicably settle;

We reported the foregoing incident to the police authorities because of

the humiliation we suffered in public and the lingering threat uttered to us
without provocation by JHULGANDHI CARMIAN PAJIJI, copy of the
Incident Record Form with Blotter Entry Number 2023-0301-007 is attached
herewith as Annex “A”, and made an integral part hereof;
 Even to this day, we feel so embarrassed and threatened by such acts
of threat and defamation committed by JHULGANDHI CARMIAN PAJIJI,
that we decided to sue him for GRAVE THREAT and SLANDER, both
punishable by law;

We are jointly executing this Affidavit-Complaint as Private

Complainants purposely to sue JHULGANDHI CARMIAN PAJIJI for
GRAVE THREAT and SLANDER which he committed through acts
hereinbefore described, and through counsel, file these cases before the
Office of the City Prosecutor, Zamboanga City, and for whatever legal
intents and purpose this may serve.

IN WITNESS WHEREOF, we have hereunto set our hands, the day,

year and place written hereinbelow.

ELVIRA VICENTE MARIBEL DATOLIO

Private Complainant Private Complainant