NAME: Ben M.

Maliga BSC-3B Davao Oriental State University

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE

OFFICE OF THE CITY PROSECUTOR

DAVAO OTRIENTAL

CARIDAD M. PALACIO
Plaintiff Criminal Case No. 2436
-versus- For: R.A 4136 and Article 257
of RPC
ROMEO T. JOSE
Defendant
COMPLAINT-AFFIDAVIT

I, CARIDAD M. PALACIO, 30 years old, residing in the municipality of Manay, after

having been sworn to in accordance with the law, do hereby state:

1. Mr. Romeo T. Jose, 40 years old, is the driver of an Isuzu truck with the plate
number LAV-123 and resides in Rizal, St. Mati City. While Mr. Romeo was on the road to the
municipality of Manay, Davao Oriental, he accidentally bumped into a calesa and was
thrown behind, where Mrs. Caridad was the passenger of that calesa and was thrown from
the passenger seats. She is in her sixth month of pregnancy. Around 6:30 PM that evening,
after the accident, there was blood that came out of Mrs. Caridad Palacio's vagina.

2. She needed a medical professional to assess and treat her. Her illness was
identified by Dr. Lito Molina, who also threatened an abortion. Three days later, on April 28,
2021, she underwent an abortion. Additionally, the cochero, Victor Gonzalo, 45, a resident
of the caseta Manay, had injuries to various bodily parts.
3. It was eventually revealed that Romeo T. Jose, the Isuzu truck's driver, voluntarily
turned himself in to the virtual police station.