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Republic of the Philippines]

City of Iligan ] S.S.

JUDICIAL AFFIDAVIT OF COMPLAINT

This Judicial Affidavit of Complaint is taken before and

conducted by Atty. Giulia Rosa C. Madera, retained external
counsel for Iligan Star Light, Inc. (ISLI), in her office at ISLI,
Barangay Pala-o, Iligan City. The examination is conducted
in the English language, a language that is known to the
complainant.

Questions and Answers

1. Q. Do you swear to tell the truth and nothing but the

truth in this Judicial Affidavit of Complaint?
A. Yes, Attorney.

2. Q. Kindly state your name and other personal

circumstances.
A. My name is JOE ALWYN, a Filipino of legal age,
married, and residing at Purok 4, Upper Hinaplanon,
Iligan City. I am the Revenue Protection Foreman of
the Technical Services Section of Iligan Star Light, Inc.
(ISLI), with office address at ISLI, Brgy. Pala-o, Iligan
City.

3. Q. And why are you here before me today?

A. I am here because I want to file a criminal complaint
for Less Serious Physical Injuries under Article 265 of
the Revised Penal Code, as amended, against JAKE
GYLLENHAAL, a Filipino of legal age, married, and
residing at Cornelia Street, Barangay Sta. Filomena,
Iligan City.

4. Q. And why do you want to file a criminal case for Less

Serious Physical Injuries against this Jake Gyllenhaal?
A. I want to file a criminal case for Less Serious
Physical Injuries against him because in the
afternoon of October 4, 2022, at around 2:15 P.M. or
2:30 P.M., he punched me on my left jaw, which

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caused a contusion requiring a recuperating period of

fifteen (15) days.

5. Q. You said the incident happened on October 4, 2022.

Can you please tell me how it all started on that day?
A. Yes, Ma’am. It all started at around 10:00 A.M. in
the morning of October 4, 2022, when I reported for
work at ISLI Pala-o.

6. Q. What happened when you reported for work around

10:00 A.M. at ISLI Pala-o Complex?
A. I was assigned Job Order (J.O.) No. 987654,
pertaining to Account No. P6969 registered in the
name of Harry Styles (formerly Style Beach Resort),
and occupied by the herein respondent Jake
Gyllenhaal, located at Barangay Sta. Filomena, Iligan
City.

7. Q. What is the purpose of J.O. No. 987654?

A. The purpose of J.O. No. 987654 is to remove the
service drop wire and kilowatt hour meter serving
Account No. P6969, which is an inactive account
since March 15, 2022.

8. Q. After you were assigned J.O. No. 987654, what did

you do next?
A. I formed a dragnet team composed of Joe Jonas (a
Lineworker-Metering of the Technical Services
Section) and Taylor Lautner (a Lineworker-Revenue
Protection Group of the Technical Services Section).
They were both with me at that time at ISLI Pala-o.

9. Q. What is the purpose of this dragnet team?

A. The purpose of this dragnet team, Ma’am, is for the
enforcement of Republic Act (R.A.) No. 7832,
otherwise known as the “Anti-electricity and
Electronic Transmission Lines/Materials Pilferage Act
of 1994.”

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10. Q. Do you commonly do this dragnet operation in

your line of work?
A. Yes, Ma’am. We usually do dragnet operations in
order to apprehend perpetrators of tampered
kilowatt hour electric meters, illegal use of
electricity, and those other crimes enumerated under
R.A. No. 7832.

11. Q. Alright. After you were assigned J.O. No.

987654 and formed a dragnet team, what did you do
next?
A. We proceeded to the area covered by Account No.
P6969, which was at Cornelia Street, Barangay Sta.
Filomena, Iligan City. We arrived at the place at around
10:15 A.M.

12. Q. When you proceeded to the area covered by

Account No. P6969, what were you wearing?
A. We were wearing our ISLI uniforms.

13. Q. Besides your ISLI uniforms, what did you have

with you which would identify you as employees of
ISLI?
A. We were wearing our respective Identification Cards
(I.D.s), Ma’am. We also used the ISLI service
vehicle, which bears the name and logo of ISLI.

14. Q. Now, when you arrived at the place covered by

Account No. P6969 at Cornelia Street, Barangay Sta.
Filomena, Iligan City, did anything unusual catch your
attention?
A. Yes, Ma’am. We saw that the building covered by
Account No. P6969 was lighted, as can be seen from
the outside.

15. Q. Why was this unusual?

A. It was unusual, Ma’am, because as per ISLI record,
Account No. P6969 was already disconnected as far
back as March 15, 2022 for being a delinquent
account.

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16. Q. So, when you saw that the building was lighted
as can be seen from the outside, what did you do next?
A. We proceeded to check the metering outfit of
Account No. P6969, which was mounted on the wall
of the building.

17. Q. What did you see or observe when you checked

the metering outfit of Account No. P6969?
A. We saw the tampered physical appearance of the
kilowatt hour meter of Account No. P6969. We
noticed that the meter glass was painted and
unreadable, the meter seal was removed, and the
meter rectangular box class 200 was closed at the
sealing lock using a padlock.

18. Q. Now, while you were checking the meter, did

anything else happen?
A. Yes. A lady came from outside the building and
asked what we were doing.

19. Q. And what did you tell her?

A. As a matter of procedure, we courteously introduced
ourselves to her, showed her our I.D.s, and informed
her of the purpose of our Job Order, which was to
remove the service drop wire and kilowatt hour
meter serving Account No. P6969, which is an
inactive account since March 15, 2022.

20. Q. And what was the lady’s response when you

told her that?
A. The lady informed us that she was the wife of the
occupant Jake Gyllenhaal. She also said that,
allegedly as per advice of her lawyer, we should
refrain from touching anything because the property
was allegedly the subject of a pending case. She
asked for our cellphone numbers, but we gave her
the ISLI hotline number instead, since our cellphone
numbers are our own private numbers.

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21. Q. What happened next?

A. We decided to disconnect/cut the service drop of
Account P6969 at the ISLI pole outside the building.
This was because, again, as per ISLI record, Account
P6969 was already disconnected as far back as
March 15, 2022 for being delinquent, but the
building was lighted as can be seen from the outside.

22. Q. After making this decision, what did you do?

A. We propped the ladder up on the ISLI pole. We were
preparing to mount the ladder in order to cut the
service drop.

23. Q. Did anything unusual happen then?

A. Yes. A man wearing a bonnet over his face emerged
from the building and approached us.

24. Q. What did he tell you or do to you?

A. He asked for our I.D.s, and we showed it to him. He
asked us what the purpose of ISLI was, and we
informed him of the Job Order, which was for the
removal of the service drop wire and kilowatt hour
meter serving Account No. P6969, which is an
inactive account since March 15, 2022. He told us to
refrain from disconnecting/cutting the service drop,
because the property is allegedly the subject of a
pending case, and it was a no-trespassing area.

25. Q. And what did you say?

A. Lautner courteously asked him who he was, since he
was wearing a bonnet over his face.

26. Q. And what did he say?

A. He said that he was Calvin Harris, an alleged head
guard of the property.

27. Q. What did you do?

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A. We still prepared to mount the ladder in order to cut

the service drop.

28. Q. And what happened next?

A. This bonneted man shouted menacingly at us,
saying, “Tiwasa na ninyo inyohang trabaho, kay
tiwason ta mo!” (“You finish your job, and I will
finish you off!”).

29. Q. What happened after that?

A. The bonneted man quickly went back inside the
building. Meanwhile, the wife of the occupant was
continuously shouting at us to go away and leave
immediately. She was waving her arms at us and
she was hysterical, saying that our lives were now in
danger from the bonneted man.

30. Q. What happened next?

A. We were troubled by the threat of the bonneted
man. Moreover, the wife of the occupant was
hysterical, telling us that our lives were in danger
from the bonneted man. We decided to leave the
area and ask for police assistance.

31. Q. What happened then?

A. We parked at a distance. Then I called our Unit
Head, Engineer John Mayer (Engr. Mayer, for
brevity), who was based in ISLI Pala-o. I informed
him of the situation, and I recommended that we ask
for police assistance since the occupants of the
property were uncooperative.

32. Q. What happened next?

A. Engr. Mayer instructed us to ask for police assistance
at PNP Precinct 3, Tag-ibo, Barangay Dalipuga, Iligan
City.

33. Q. Did you proceed accordingly?

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A. Yes, Ma’am. When we arrived at PNP Precinct 3, I

informed the desk officer on duty that we needed
police assistance in disconnecting Account No. P6969
because the occupants refused the disconnection and
removal of the kilowatt hour meter.

34. Q. What happened next?

A. The desk officer on duty advised me to submit a
request letter for police assistance addressed to
Police Major Tom Hiddleston, Station Commander of
PNP Precinct 3.

35. Q. Did you comply?

A. Yes. I called our Unit Head Engr. Mayer, and
informed him of the need for a request letter for
police assistance. Engr. Mayer instructed us to wait,
as he would make the request letter and send
someone from his office to give it to us.

36. Q. What happened next?

A. Engr. Mayer sent Engineer Connor Kennedy (Engr.
Kennedy, for brevity), who is a Staff Engineer of the
Technical Services Section. He handed to us two
documents: the letter addressed to Station
Commander Hiddleston requesting for police
assistance, and Job Order No. 987654.

37. Q. You mentioned that Engr. Kennedy handed to

you Job Order No. 987654. What is the purpose of this
Job Order?
A. The purpose of Job Order 987654 is for the dragnet
team to take the necessary action in implementing
R.A. No. 7832 pertaining to Account No. P0199,
because aside from the tampered and destroyed
kilowatt hour meter, the subject building remained
lighted despite being disconnected way back March
15, 2022 for being a delinquent account.

38. Q. By the way, do you have a copy of this Job

Order?

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A. Yes, Ma’am.

39. Q. You are showing to me a two-page document

with the header “Job Order,” printed on October 4,
2022 at 1:36:22 P.M, with JO Number 987654, for
Account Number P6969. Is this the Job Order that you
are referring to?
A. Yes, Ma’am.

40. Q. I am marking a faithful photocopy of Job Order

987654 as Annex A to A-1, do you confirm my action?
A. Yes, Ma’am.

41. Q. Also, do you have a copy of the request letter

addressed to Station Commander Hiddleston?
A. Yes.

42. Q. You are showing to me a document, which is a

letter addressed to Police Major Tom Hiddleston, the
Station Commander of Precinct 3, Dalipuga, Iligan City.
It is signed by Engr. John Mayer, the Unit Head of
ISLI’s Technical Services. Is this the request letter that
you are referring to?
A. Yes, Ma’am.

43. Q. I’m marking a faithful photocopy of this

Request Letter for Police Assistance as Annex B, do
you confirm my action?
A. Yes, Ma’am.

44. Q. So, what happened next?

A. The dragnet team was now escorted by four (4) PNP
personnel from PNP Precinct 3. We then went to the
barangay hall of Sta. Filomena in order to request
one representative from the barangay to witness and
attest to the implementation of Job Order 987654.
Barangay Kagawad Lucan Till accompanied us.

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45. Q. What happened next?

A. Under heavy rain, we all went back to the area of
Account No. P6969 at Cornelia Street, Barangay Sta.
Filomena, Iligan City.

46. Q. And then, what happened?

A. As the rain subsided, we proceeded to the building.
The wife of the occupant met us and she was very
hysterical.

47. Q. What happened next?

A. We were preparing the ladder when a bonneted man
emerged from the property onboard a motorcycle.
He roamed around the area and blocked the ISLI
pole while with his motorcycle, such that we could
not prop our ladder up.

48. Q. What happened next?

A. The policemen approached the bonneted man on a
motorcycle. But he hurriedly went back inside the
property.

49. Q. What happened then?

A. We were able to prop the ladder up the ISLI pole. All
of a sudden, stones were thrown at the ladder. The
bonneted man was throwing stones at us. The
policemen shouted at the bonneted man to stop. He
eventually stopped when the lady held on to him. So,
the ISLI team successfully cut/disconnected the
service drop of Account P6969. We removed the
ladder and stowed it in the ISLI service vehicle.

50. Q. Do you have proof that you were able to

cut/disconnect the service drop?
A. Yes, Ma’am, we have the actual confiscated service
drop. We also took a photograph of the said service
drop on-site at the time, when we cut it and took it
down.

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51. Q. You are showing to me a colored photograph of

rolled black cables wrapped in brown masking tape and
lying on a cemented pavement. On the masking tape
are words written in felt-tip pen: “P6969 Jake
Gyllenhaal Style Beach Resort.” Is this the photograph
that you are referring to?
A. Yes, Ma’am.

52. Q. I am marking a faithful photocopy of this

photograph as Annex C, do you confirm my action?
A. Yes, Ma’am.

53. Q. If the investigating prosecutor and a court of

law were to ask you to produce the actual service drop
as object evidence, would you be able to produce it and
identify it for proper marking?
A. Yes, Ma’am.

54. Q. So, what happened next?

A. As a matter of standard procedure, Engr. Kennedy
prepared the “Metering Facilities Inspection Report
with Notice of Violation and Disconnection,” for
acknowledgment by the occupants of the premises.

55. Q. And did the occupants of the premises

acknowledge the said document?
A. No. There was intense resistance, intimidation, and
hysterics by the occupants. So, I just marked therein
“REFUSED TO SIGN.”

56. Q. Is the “Metering Facilities Inspection Report

with Notice of Violation and Disconnection” with you?
A. Yes, Ma’am, I have it with me.

57. Q. You are showing to me a document with the

header “Metering Facilities Inspection Report with
Notice of Violation and Disconnection.” It shows the
name of Jake Gyllenhaal as occupant, ISLI Account
Number P6969, the name of Harry Styles as registered

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owner, the date of apprehension at October 4, 2022,

and the address at Cornelia Street, Sta. Filomena,
Iligan City. On the tick list, the following items are
check-marked: tampered KWH meter, missing ISLI
seal, and others “being painted KWH meter glass, can’t
be read; account P0199 was inactive/offline but found
lighted during dragnet operation.” It is marked “refuse
to sign”, with date of October 4, 2022 and time at 2:10
P.M. It is witnessed by PNP personnel and the dragnet
team, as well as Barangay Kagawad Lucas Till of Sta.
Filomena. Is this the document that you are referring
to?
A. Yes, Ma’am.

58. Q. I am marking a faithful photocopy of this

“Metering Facilities Inspection Report with Notice of
Violation and Disconnection” as Annex
D, do you confirm my action?
A. Yes, Ma’am.

59. Q. So, what happened next?

A. I was near the ISLI pole to conduct a post-check of
the disconnection when, all of a sudden, a bonneted
man onboard a motorcycle appeared out of nowhere.
He slowly maneuvered his motorcycle towards me,
and he suddenly punched me on my left jaw.

60. Q. And what did you do?

A. I defended myself by pushing the motorcycle to the
ground, and punching the bonneted man.

61. Q. What happened next?

A. The PNP personnel restrained the bonneted man,
who was wild. His bonnet was removed, and it was
revealed that he was none other than Jake
Gyllenhaal, the respondent in this case.

62. Q. What happened next?

A. The PNP personnel loaded the still-resisting Jake
Gyllenhaal inside their mobile patrol car. The PNP left

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the premises followed by the ISLI team, and we

went to PNP Precinct 3 in order to file an incident
record form and police blotter report.

63. Q. And do you have copies of this Incident Record

Form and Police Blotter?
A. Yes Ma’am, we have it with us.

64. Q. You are showing to me an Incident Record

Form with IRF Entry Number 5571 for Physical Injury,
as well as Police Extract Blotters with Entry Numbers
5571-00337 and 5573-0037, are these the documents
that you are referring to?
A. Yes, Ma’am.

65. Q. I am marking faithful photocopies of these

documents, namely Incident Record Form as Annex E,
Police Extract Blotter Number 5571-00337 as Annex E-
1, and Police Extract Blotter Number 5573-0037 as
Annex E-2, do you confirm my action?
A. Yes, Ma’am.

66. Q. By the way, did the team ever get proof of the
tampered and destroyed kilowatt hour meter?
A. Yes, Ma’am. The ISLI team took a photograph of the
tampered and destroyed kilowatt hour meter.

67. Q. You are showing to me a colored photograph of

an electric meter. The meter glass is painted and
covered with white, there is no meter seal, and the
meter rectangular box is closed at the sealing lock with
an ordinary padlock. Is this the tampered and
destroyed meter of Account No. P6969 that you are
referring to?
A. Yes, Ma’am.

68. Q. I am marking a faithful photocopy of the

photograph of this electric meter as Annex F, do you
confirm my action?

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A. Yes, Ma’am.

69. Q. And is your team in possession of this

tampered and destroyed electric meter?
A. Unfortunately not, Ma’am. In the heat of the
moment, the ISLI team forgot to remove the
tampered and destroyed electric meter. It is still
there attached to the building.

70. Q. If the investigating prosecutor or a court of law

were to conduct an on-site inspection of the premises,
would you be able to guide them towards the tampered
and destroyed electric meter?
A. Yes, Ma’am.

71. Q. So, you mentioned that you and the PNP escort
proceeded to PNP Precinct 3, together with the arrested
Jake Gyllenhaal. What happened there?
A. The PNP personnel informed us that, since the case
was for physical injuries, the respondent Jake
Gyllenhaal cannot be brought for inquest, and the
complaint must first be brought before the Barangay
officials of Sta. Filomena.

72. Q. What happened next?

A. We saw that Jake Gyllenhaal was released, and a
motorcycle picked him up. Meanwhile, the officer on
duty at PNP Precinct 3 issued a Medico-Legal
Request addressed to the Iligan City Health
Office/City Hospital, requesting for a physical
examination of my person because of the injury that
I sustained.

73. Q. Do you have a copy of this Medico-Legal

Request?
A. Yes, Ma’am.

74. Q. You are showing to me a Medico-Legal Request

from the PNP Precinct 3 dated October 4, 2022 and

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signed by PSSG Katy Perry, is this the document that

you are referring to?
A. Yes, Ma’am.

75. Q. I am marking a faithful photocopy of this

Medico-Legal Request as Annex G, do you confirm my
action?
A. Yes.

76. Q. So, after your report at PNP Precinct 3, what

happened next?
A. The ISLI team returned to ISLI Pala-o Office, where
we reported the entire incident to our Unit Head,
Engineer John Mayer.

77. Q. Now, you mentioned that you sustained

physical injuries because Jake Gyllenhaal punched you
in the face. You also mentioned that the PNP Precinct 3
issued a Medico-Legal Request for your physical
examination at City Health Office/City Hospital. What
happened with this physical exam?
A. The following day, on October 5, 2022, I went to the
City Health Office for my physical exam. However,
the volume of people at the CHO precluded me from
being physically examined.

78. Q. So, what did you do?

A. I was advised by our ISLI company nurse to proceed
to the clinic of Dr. Selena Gomez at Gomez Medical
Center – Iligan City, because he is an accredited
physician who can issue a medico-legal certificate.

79. Q. And what did you do?

A. On that same day of October 5, 2022, at around
3:10 P.M., Dr. Gomez examined me and found that I
had a contusion on my left lower jaw, which required
a recuperation period of 7-10 days.

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80. Q. Do you have a copy of the Medical Certificate

issued by Dr. Gomez on October 5, 2022?
A. Yes, Ma’am.

81. Q. You are showing to me a Medical Certificate

dated October 5, 2022. It certifies that Joe Alwyn was
treated before Dr. Selena Gomez at Gomez Medical
Center – Iligan City, on that same date at 3:10 P.M.
The diagnosis is a contusion on the lower left jaw,
which requires a convalescing or recuperation period of
7-10 days. Finally, it is signed by Selena Gomez, M.D.
Is this the Medical Certificate that you are referring to?
A. Yes, Ma’am.

82. Q. I am marking a faithful photocopy of this

Medical Certificate dated October 5, 2022 as Annex H,
do you confirm my action?
A. Yes, Ma’am.

83. Q. What happened next?

A. I went to the Barangay Hall of Sta. Filomena, Iligan
City, in order to lodge a complaint for Less Serious
Physical Injuries against Jake Gyllenhaal.

84. Q. What happened afterwards?

A. On October 14, 2022, I went back to the clinic of Dr.
Selena Gomez for a follow-up check-up on my injury.

85. Q. And what happened at the clinic of Dr. Selena

Gomez?
A. She examined me and found that my left jaw was
still swollen and tender. For recuperation, she
recommended an extension of 5 days for my sick
leave.

86. Q. Do you have any documents to prove the

diagnosis of this second check-up?
A. Yes, Ma’am. I have with me a Medical Certificate on
that day of October 14, 2022.

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87. Q. You are showing to me a Medical Certificate

dated October 14, 2022. It certifies that Joe Alwyn was
treated before Dr. Selena Gomez at Gomez Medical
Center – Iligan City, on that same date at 1:54 P.M.
The diagnosis is that the left jaw is still swollen and
tender, which requires an additional extension of 5
days worth of sick leave. Finally, it is signed by Selena
Gomez, M.D. Is this the Medical Certificate that you are
referring to?
A. Yes, Ma’am.

88. Q. I am marking a faithful photocopy of this

Medical Certificate dated October 14, 2022 as Annex I,
do you confirm my action?
A. Yes, Ma’am.

89. Q. Meanwhile, you mentioned that you caused the

filing of a complaint for Less Serious Physical Injuries
against Jake Gyllenhaal before the barangay officials of
Sta. Filomena, Iligan City. What happened before the
Lupong Tagapamayapa?
A. The respondent Jake Gyllenhaal refused to appear
during our scheduled hearings before the Barangay.

90. Q. Because of Jake Gyllenhaal’s non-appearance,

what did the barangay officials do?
A. The Office of the Lupong Tagapamayapa issued a
Certification to File Action (CFA) and Certification to
Bar Counterclaim.

91. Q. Do you have copies of these Certification to File

Action (CFA) and Certification to Bar Counterclaim?
A. Yes, Ma’am.

92. Q. You are showing to me two documents: one is

a Certification to File Action, and another is a
Certification to Bar Counterclaim, issued by the Office

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of the Lupong Tagapamayapa on November 8, 2022.

Are these the documents that you are referring to?
A. Yes, Ma’am.

93. Q. I am marking faithful photocopies of the

Certification to File Action as Annex J, and the
Certification to Bar Counterclaim as Annex J-1, do you
confirm my action?
A. Yes, Ma’am.

94. Q. As I end my direct examination, do you have

anything else to say regarding this matter?
A. Yes. As a matter of standard procedure, and in order
to protect the interests of the electricity consumers
as a whole, Jake Gyllenhaal must be held liable for
Less Serious Physical Injuries under Article 265 of
the Revised Penal Code, as amended. He punched
me in the face while I was only doing my job, which
caused a contusion on my lower left jaw requiring a
recuperation/healing period of 15 days. Such an act
must be punished by the courts of law in order to
caution the public not to emulate what Jake
Gyllenhaal did.

95. Q. Do you affirm the truthfulness of the

statements that you made herein, fully conscious that
you answered my questions under oath?
A. Yes, Ma’am.

96. Q. Are you aware that you can be charged with

false testimony or perjury if it turns out that your
statements here are false or fabricated?
A. Yes, Ma’am.

IN WITNESS WHEREOF, I have hereunto affixed my

signature this 9th day of December 2022, at ISLI Pala-o,
Iligan City, Philippines.

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JOE ALWYN
Complainant-Affiant

SUBSCRIBED AND SWORN to before me this 9th day

of December 2022 at Iligan City, Philippines, the
complainant-affiant personally appearing before me and
showing to me Driver’s License which is a competent proof
of his identity.

ATTESTATION

I, Atty. Giulia Rosa C. Madera, a Filipino of legal age,

married, retained external counsel of Iligan Star Light, Inc.,
with office address at Madera Law Office, Ground Floor,
Madera Building, Purdue St., Celdran, Barangay Tubod,
Iligan City, swear that:

1. I am the retained external counsel of Iligan Star Light,

Inc. (ISLI), and I conducted the foregoing direct
examination of the above-named complainant-affiant,
whose signature appears above his name;

2. The examination was conducted at my assigned office in

ISLI Pala-o Complex, Barangay Pala-o, Iligan City;

3. I faithfully recorded the questions directed to the

complainant-affiant, together with the corresponding
answers, in this Judicial Affidavit of Complaint consisting
of nineteen (19) pages (including this attestation)
numbered correspondingly;

4. I did not coach nor assist the complainant-affiant in his

answers, and neither did any person do so;

5. The questions were made in a dialect known and

understood by him, and the contents thereof were
explained to him before he affixed his signature.

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IN WITNESS WHEREOF, I have hereunto affixed my

signature this 9th day of December 2022, at ISLI Pala-o
Complex, Iligan City, Philippines.

Atty. Giulia Rosa C. Madera

Affiant

SUBSCRIBED AND SWORN to before me this 9th day

of December 2022 at Iligan City, Philippines, the affiant
personally appearing before me and showing to me her IBP
I.D. No. 082395, which is a competent proof of her identity.

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