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CHERRYLYN B.

SANTOS,
Complainant,

-versus

For: Homicide ( Art. 249 of the Revised Penal Code)

ARSENIO C. MASANGCAY
Respondent

. x-------------------------------------x

COMPLAINT-AFFIDAVIT

I, CHERRYLYN B. SANTOS, of legal age, Filipino and maybe served with summons at of 123 Bonifacio St.,
Tondo, Manila, after having been duly sworn to in accordance with law, do hereby depose and state
that:

1. I am the wife of Armando T. Santos. I am a teacher by profession. My husband “Mando” as he is


fondly called was killed by a stab wound on his chest on June 20, 2013 at a tricycle terminal bound to
Quiapo, Manila. A copy of our Marriage Certificate is attached as Annex “A” and made an integral part
hereof.

2. I am executing this Complaint-Affidavit to charge Arsenio C. Masangcay, for HOMICIDE, defined and
punished under Article 249 of the Revised Penal Code for the death of “Mando”. The offense was
commited under the circumstances narrated below.

3. On June 20, 2013 at around 5 p.m. while me and my husband Armando T. Santos was waiting at the
tricycle terminal bound for Quiapo, Manila, the accused Arsenio C. Masangcay suddenly arrived, mad
and drunk.

4. The accused, Arsenio C. Masangcay demanded from my husband, Armando T. Santos that he pay the
money he owes him last week and threatened to inflict physical harm if he did not do so. He said, “Di ka
marunong tumupad sa usapan, magbayad ka na kung ayaw mong masaktan!”

5. To avoid trouble my husband signalled to me that we should leave, however, he was suddenly
pushed at the back by the accused and a fight ensued between them.

6. I tried to pacify them but they cannot be restrained, when I turned and asked for help, I heard
someone say, “May sinaksak

7. I then saw my husband lying on the pavement with a stab wound on his chest and the accused ran
away. A copy of the police Spot Report dated June 20, 2013 is attached as Annex “B” and made an
integral part hereof. 8. For my part, I brought my husband to a nearby hospital however, after a few
hours of treatment he was declared dead. A copy of my husband’s Death Certificate is attached as
Annex “C” and made an integral part hereof.
9. I am executing this Complaint-Affidavit for the purpose of attesting to the truth of the foregoing facts
and events and to pave the way for the prosecution of a criminal case for Homicide against ARSENIO C.
MASANGCAY.

IN WITNESS HEREOF, I hereunto set my hand this 10th day of July 2013 in Manila.

CHER
RYLYN B. SANTOS
Affiant

SUBSCRIBED AND SWORN to before me this 10th day of July 2013 in Manila.

ABIGAIL F. EVANGELISTA
Assistant City Prosecutor
Manila

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