REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

National Capital Judicial Region
Manila City

ANALYN D. DIAZ
Complainant,

-versus- Docket No.________

For: Violation of R.A. 9262
Violence Against Women
and their Children
FRANCIS E. DIAZ
Respondent.

x-----------------------------------------x

COMPLAINT-AFFIDAVIT

I, ANALYN D. DIAZ, of legal age, married, Filipino, and a resident

of 123 3rd St., East Grace Park, Caloocan, with the assistance of counsel,
hereby depose and state:

1. I am the same person who is the complainant in this instant case.

2. I am charging Francis E. Diaz, who is my husband, and is a resident

of 321 Maria Payo St., Tondo, Manila, for the violation of R.A. 9262
Violence Against Women and their Children. He may be served
with the orders and other processes of the Honorable Office at the
above-mentioned address.

3. We were married on October 23, 2018, at Quiapo Church. A copy of

our Marriage Certificate is herein attached as Annex “A”.

4. Our marriage was harmonious for the first three years and we were
blessed with a beautiful daughter.

5. Our daughter Alicia was born on September 12, 2019. She is now
three (3) years old. A copy her Birth Certificate is herein attached as
Annex “B”.

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6. My husband’s behavior changed two years ago when he was laid-off
from his job at A&B Construction. He used to be an office worker in
the said construction company.

7. Our finances were okay because I also have a job at DV Mall as a

sales lady and was earning enough to sustain our everyday needs.

8. During the first nine months we were okay. He takes care of our
daughter and the house when I am my work.

9. However, he became more and more frustrated when he couldn’t find

a new job. He started drinking but still too care of our daughter.

10. On March 15, 2021, I heard my daughter crying when I entered our
house coming from work.

11. I looked for my husband but he was not there and my daughter was
left alone in our house.

12. He arrived around midnight. I confronted him about his behavior and
for the first time in our relationship even before marriage, he smacked
on the face.

13. The next morning, he never apologized for what he did and we did
not talk with each other but I saw him taking care of our daughter, so I
left for work.

14. When I went home the same day, he was drinking. I asked him if he
has cooked for dinner but then he suddenly shouted at me. Enraged he
said “Ano mayabang ka na?! Dahil ba may trabaho ka at ako
wala?!”. After saying that he shoved me and went to our room to
sleep.

15. During weekends I had no work, so I was at the kitchen with my

daughter setting the table. My husband came to the kitchen, and we
ate. While we were eating, the fish was a bit salty and overcooked, he
suddenly screamed at me saying, “Wala ka talagang kwenta!
Simpleng pagluluto lang ng isda, di mo pa magawa ng maayos.” He
then threw the food on my face, my daughter witnessing all of that.

16. Gradually, he became worse and worse, he drank all day, and he
would shove me and slap me whenever his temper goes bad, without
care even if our daughter saw him.

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17. I stayed with him for two years even if he was like that because of my
daughter and to keep our family together, believing that he can still
change.

18.However, on June 15, 2022, I went home late because of work. When
I got home, I saw my husband sitting on our couch drinking again.

19.When he saw me, he threw his beer bottle at me. He shouted, “Ba’t ka
ginabi, nanglalake ka ano?!”. He went near me and stared beating me
up. He hit me in the face, kicked me in the stomach, and pulled my
hair. When he was satisfied, he left me battered and bruised on our
living room.

A copy of the doctor’s medical examination of my wounds is hereunto

attached as Annex “C”.

20. The next morning, I immediately packed my and my daughter’s

things, and we left our house, because I can no longer bear his
violence towards me and for my daughter’s mental and psychological
well-being.

21. I went to my parents’ house and decided to move back to them.

22. R.A. 9262, “AN ACT DEFINING VIOLENCE AGAINST WOMEN

AND THEIR CHILDREN, PROVIDING FOR PROTECTIVE
MEASURES FOR VICTIMS, PRESCRIBING PENALTIES
THEREFORE, AND FOR OTHER PURPOSES” provides that:

SECTION 3. Definition of Terms. - As used in this Act,

(a) "Violence against women and their children" refers to any

act or a series of acts committed by any person against a
woman who is his wife, former wife, or against a woman with
whom the person has or had a sexual or dating relationship, or
with whom he has a common child, or against her child whether
legitimate or illegitimate, within or without the family abode,
which result in or is likely to result in physical, sexual,
psychological harm or suffering, or economic abuse including
threats of such acts, battery, assault, coercion, harassment or
arbitrary deprivation of liberty. It includes, but is not limited to,
the following acts:

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 A. "Physical Violence" refers to acts that include bodily or
physical harm;

C. "Psychological violence" refers to acts or omissions causing

or likely to cause mental or emotional suffering of the victim
such as but not limited to intimidation, harassment, stalking,
damage to property, public ridicule or humiliation, repeated
verbal abuse and mental infidelity. It includes causing or
allowing the victim to witness the physical, sexual or
psychological abuse of a member of the family to which the
victim belongs, or to witness pornography in any form or to
witness abusive injury to pets or to unlawful or unwanted
deprivation of the right to custody and/or visitation of common
children.

xxx

Section 5. Acts of Violence Against Women and Their

Children. - The crime of violence against women and their
children is committed through any of the following acts:

a.)  Causing physical harm to the woman or her child

xxx

23. Francis E. Diaz should be punished under the law for the violation of
Republic Act No. 9262.

24. His abusive actions are considered to be physical and psychological

violence under the law.

25. In view of the foregoing, I am executing this affidavit to attest to the

truth of the facts and in support of the charges for “Violation of R.A.
9262 Violence Against Women and their Children”, against my
husband Francis E. Diaz or for whatever other action may be filed
against him.

IN WITNESS WHERE OF, I hereunto affix my signature this 20th of

June 2022 at Manila City.

ANALYN D. DIAZ
Affiant

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 SUBSCRIBED AND SWORN to before me, this 20th day of June
2022 at Manila City. Affiant exhibited to me her identification document as
proof of her identity.

NOTARY PUBLIC

Doc. No.____
Page No.____
Book No.____
Series of 2022.

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