REPUBLIC OF THE PHILIPPINES

OFFICE OF THE CITY PROSECUTOR

MAKATI CITY, METRO MANILA

PEPAY JORNACION
Complainant,
for: Violation of Art. 294 of the Revised
Penal Code

versus

TONY CRUZ and FRED MUNDIN,

Respondent.

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COMPLAINT AFFIDAVIT
THE UNDERSIGNED COMPLAINANT respectfully alleges:

I, PEPAY JORNACION, of legal age, single, Filipino, and a resident of 18 T Upper Paz
Street, Morning Breeze, Caloocan City, having been duly sworn in accordance with the law,
hereby depose and state that:

1. Around 10:00 in the evening of Monday, September 27, 2019, I, Pepay Jornacion,
was standing by the side of Sen. Gil Puyat Avenue in Makati City, waiting for a ride home.

2. While I was waiting for a ride, I was holding my bag when suddenly a man with a
stocky build and bald head emerged out of nowhere, sprinted towards me and forcibly grabbed
my bag containing the following items:
a. Mobile phone;
b. Law books;
c. Reviewers;

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 d. A laptop; and
e. A wallet containing my driver’s license, credit cards, and cash.

3. The man sped-off in a motorcycle driven by another man who was tall with a
bearded face.

1. I was able to write down the plate number of the motorcycle which is FW 8720K.

2. That around 9:00 in the morning of September 28, 2019, I reported the incident at
the Makati Police Station, wherein I was accompanied by Sgt. Arvin Beluang who took my
statements regarding the incident.

3. That a week later, I was informed by Sgt. Beluang that they had in their custody
two men who may have been responsible for robbing me.

4. I positively identified the two men as those who were in the motorcycle.

5. The men were later introduced as Tony Cruz (alias “Boy Rugby”) and Fred Mundin
(alias “Balbon”).

6. Thus, I am executing this affidavit to attest to the truth of the foregoing statements,
for the purpose of charging respondents Tony Cruz (alias “Boy Rugby”) and Fred Mundin (alias
“Balbon”) for the crime of Robbery With Violence Against or Intimidation of Persons, as
defined and penalized under Act No. 3815 (the REVISED PENAL CODE OF THE
PHILIPPINES), and for such other legal purpose it may serve.

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 IN WITNESS WHEREOF, I have hereunto affixed our signature this 20th day of October
2019, in the City of Makati.

__________________________
PEPAY JORNACION
Complainant

SUBSCRIBED AND SWORN TO before me this 20th day of October 2019, in Makati
City.

________________________
JAMES REID
City Prosecutor

CERTIFICATION

I hereby Certify that I personally examined the affiant and that I am satisfied that he
voluntarily executed and understood his complaint-affidavit.

_______________________
City Prosecutor