Republic of the Philippines))

La Trinidad, Benguet) s.s

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JOINT AFFIDAVIT-COMPLAINT
We, Alfred Nacnas Guitoc, Lydia Guitoc Lis-eg and Aleen Lis-eg, of
legal ages, all married, Filipinos, and residents of JF 125, E, Ganasi St.,
Toyong, Pico, La Trinidad, Benguet after having duly sworn to in
accordance with law, do hereby and depose and state THAT:

1. We are filing a case for Robbery with force upon things and/or
other appropriate case/s under the Revised Penal Code and allied
laws as may be warranted by the circumstances, against Butler
Moyongan likewise of legal age, married, Filipino, and a resident
of Barangay Quirino Hill, Baguio City, Philippines;

2. The circumstances surrounding the commission of the crime are

the following, to wit:

2a) On the last week of July 2022, we went home for a visit to
Bauko, Mountain Province. We stayed there for several days,
including our families until July 26, 2022. We left inside our house
above-described, which we fully locked and secured, several
personal belongings, valuables and other miscellaneous items. For
ready reference, we are attaching hereto a copy of the List of the
items left inside our house, marked as Annex “A”;

2b) On July 26, 2022, we travelled back home here in La Trinidad,

Benguet. When we arrived, it was already late in the evening.
Since we were all tired and exhausted, we immediately rested and
went to sleep.

2c) In the morning of July 27, 2022, before 9:00 o’ clock, we woke
up. Thereafter, we noticed that the afore-stated personal items,
valuables and other belongings were missing or were no longer in
the place where we kept them. Since we were greatly surprised, we
then and there immediately searched and locate for the said items.
However, we failed as these items were no longer there;

2d) As soon as we realize that our house might have been robbed,
entered forcibly, without our consent or permission while we were
away on vacation at Bauko, Mountain Province, we immediately
reported the incident to the proper authorities. We then proceeded
to the La Trinidad Municipal Police Office at Km. 5, La Trinidad,
Benguet for this purpose. A copy of the Police Blotter/Certification
is hereto attached and marked as Annex “B”;

2e) Further, we informed one of our neighbors, Jannet M. Matis

(Jannet), about what happened. It was then and there that she told

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us that on July 22, 2022, in the morning, while she was attending
to her sari-sari store located thereat, she saw a male person went to
our house and passed by her sari-sari store. When this male person
returned, she asked him why he was there and who were he
looking for. The male person replied that he was looking for us,
Alfred Guitoc and Allen Guitoc. When she replied in the
affirmative, the male person left;

A copy of the Sworn Statement of Jannet M. Matis is hereto

attached and marked as Annex “C”.

2f) Further investigation by the police authorities revealed that the

suspect gained entry to our house by climbing up the ladder for the
fire exit, and upon reaching the fourth floor of the house, forcibly
removed or destroyed the screw of the sliding glass door and once
inside, took all the afore-cited items. He used also the same as exit.

2g) As it should be, our co-complainant, Alfred Guitoc,

immediately proceeded to the BDO-Luneta, Baguio City Branch
located at Session Road, Baguio City to request for stop payment
order for the BDO checks that were missing or stolen. While on
the process, he was informed that one of the checks was already
encashed few days before. We came to know the name of said
person as Jeremias Abdon.

2h) We then searched through the social media platform Facebook

the name of Jeremias Abdon. Fortunately, we find one and so, we
had his profile picture printed and his address taken. Thereafter, we
submitted these to the police authorities to follow up;

2i) After, on the night of August 2, 2022, Jeremias Abdon

voluntarily went to the La Trinidad Police Station, Km. 5, La
Trinidad, Benguet and accordingly informed the police authorities
that he just wanted to clear his name because he was being
suspected as the one who robbed our house. Mr. Jeremias Abdon
(Mr. Abdon) also admitted that he was the one who encashed the
blank check at BDO-Luneta Branch, Session Road Baguio City as
instructed by respondent Butler Moyongan. Further, Mr. Abdon
said that he got a share from the proceeds thereof. A copy of his
Sworn Statement is hereto attached and marked as Annex “D”;

2j) On August 3, 2022, we, Alfred Guitoc and Aleen Lis-eg went
to the La Trinidad Police Station to request for police assistance
because Mr. Abdon informed us that Butler Moyongan and he
previously scheduled to encash the other checks. Consequently, we
proceeded to the parking lot beside the University of the
Cordilleras, Gov. Pack Road, Baguio City where the respondent
was waiting for Mr. Abdon.

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 2k) While thereat, we found the respondent and we asked him if he
was the one who gave the checks to Mr. Abdon to which he did not
answer. He was then invited by the police officers to the La
Trinidad Municipal Police Office to shed light on about the matter.
A copy of the Affidavit of the police officers is hereto attached and
marked as Annex “E”.

2l) At around 1:00 o ‘clock of August 3, 2022, we were informed

by the police authorities that the respondent surrendered the items
stolen/taken. In turn, the police authorities delivered to us the said
items. Attached hereto is a copy of the Turn Over Receipt and
marked as Annex “F”;

3. Clearly, the respondent committed criminal acts when he forcibly

entered our residential house at JF 125, E, Ganasi St., Toyong,
Pico, La Trinidad, Benguet by climbing through the fire exit, and
upon reaching fourth floor, by using force, destroyed and/or
removed the screw of the sliding door thereof, thus was able to
open the said door, and once inside, took all the items listed above,
and thereafter, left the premises using the same way as an exit,
against our will and consent. The respondent likewise gained from
the acts as in fact, the items subject of our complaint were personal
properties and valuables, some of which they already encashed and
disposed of accordingly, to our damage and prejudice;

4. Such acts of the respondent, it is respectfully submitted, are

punishable under Article 293 of the Revised Penal Code and/or by
other offense/s under the same Code or allied laws warranted by
the foregoing;

5. Finally, we are executing this Joint Affidavit-Complaint to attest to

the truthfulness of the foregoing facts and for all legal intents and
purposes it may serve.

IN WITNESS WHEREOF, we have hereunto set our hands this

___________ at La Trinidad, Benguet, Philippines.

Alfred N. Guitoc Lydia G. Lis-eg Aleen Lis-eg

Affiant Affiant Affiant

SUBSCRIBED AND SWORN to before me this _______________ at

La Trinidad, Benguet, Philippines by the Affiants. I further certify that I
have personally examined the affiants and that I am satisfied that they freely
and voluntarily executed, read and understood the contents of their Affidavit
Complaint.

_____________________________________
Administering Officer
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