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Sample Complaint
A>idavit For Violation of
RA 9262
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sample complaint-abidavit
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Sample Complaint Abidavit for Violation of RA 9262
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Republic of the Philippines
Department of Justice
Share this document CITY PROSECUTION OFFICE
________________

GUIAMALIA KENENGKO Docket No: _________

Complainant ,
-versus-
Facebook
BEDO SINUMPAY Twitter or: Violation of R.A 922
Respondent. Viol!n"! A#ain$t %o&!n
an' t(!i) C(il')!n


Email
!------------------------------!

COMPLAINT * AFFIDAVIT

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GUIAMALIAuseful?
KENENGKO, of le#al a#e, ilipino,
married to the respondent, and a resident of $% Notre Dame
&venue, Cotabato Cit', after havin# been dul' s(orn in
accordance (ith la(, hereb' depose and state:
). " am and the same person (ho is the complainant in
the instant case*
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+. " kno( the person of D, bein# m' husband and
(ho is currentl' in active service in the /////////0
acolod Cit', (here he ma' be served (ith ffice
summons, notices and processes*
%. 1hat (e (ere married on ebruar' )2, +223 at
Re#ional 1rial Court 0 ranch )% before the sala of
4on. Jud#e ///////. 1he cop' of marria#e
certificate is hereto attached as &nne! 5&6*
7. 1hat out of la(ful marria#e, (e be#ot t(o8+9
children. 1he first child is ////////////// (ho
(as born on June +, +223 and our second child
/////////////// (as born on ebruar' +, +22;.
ur dau#hter <ianna is Nine 8;9 'ears old (hile our
son Corvin is si! 839 'ears old. Copies of their

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Criminal Case Case by GUAIMALIA

Page 2 of 5

Certificates of =ive irth are hereto attached and

marked as &nne!es 56 and 5C6 respectivel'*
. 1hat in the be#innin# of our marria#e, (e lived
harmoniousl' as husband and (ife and parents to
our children until later part that the m' husband had
sho(n and displa'ed irrational behaviour not
e!pected from a mature and a responsible husband
and father to our children*
3. 1hat (hile he (as in &rmed orces of the Philippines
assi#ned at Camp onifacio, 1a#ui# Cit', he used to
re#ularl' #o home and visit us*
>. 1hat (hen he transferred his service to the PNP
startin# on ?arch +2)), he did not #o home alread'
and spare sometime to visit us, (orst is he did not
even send support to us*
@. 1hat " have sent letter addressed to the former PNP
Chief PD< &lan Purisima reAuestin# for sub-allotment
of allo(ances intended for our t(o 8+9 children, cop'
of (hich is hereto attached as &nne! 5D6*
;. Be both ended up in enterin# into a ?emorandum of
&#reement (hich e!ecuted on eptember )3, +2)%
at ?anila, Philippines (ith a stipulation that m'
husband shall #ive a total amount of ive 1housand
8P,222.229 Pesos per month divided as 1(o
1housand ive 4undred 8P +,22,229 for ever' child
and additional 1(o 1housand 8P +,222.229 Pesos for
childrens education, cop' of the said ?emorandum
of &#reement is hereto attached and marked as
&nne! 56*
)2. Despite this a#reement, m' husband continuousl'
failed to compl' to his undertakin#s because he
failed to #ive the amount a#reed upon as a support*

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Criminal Case Case by GUAIMALIA

Page 3 of 5

)). " (as constrained to seek le#al assistance from

the Public &ttorne's ffice 0 //////////////
(hich immediatel' assisted me b' preparin# and
sendin# a Demand =etter reAuestin# that the amount
even 1housand 8P >,222.229 Pesos shall be directl'
deducted from the net pa' of m' husband and the
amount be sent to me in a form of a check. 1he
same reAuest is not 'et acted upon until this ver'
moment, cop' of the said letter is hereto attached
and marked as &nne! 56*
)+. 1hat his act of continuous failure to #ive support
since the 'ear +2)) tantamount to economic abuse
(hich is defined under R.& ;+3+ or Eiolence &#ainst
Bomen and their Children as:
"Economic abuse" refers to acts that make or attempt to
make a woman financially dependent which includes, but is not limited
to the following:

1. Withdrawal of financial support or preventing the victim

from engaging in any legitimate profession, occupation,
business or activity, except in cases wherein the other
spouse/partner objects on valid, serious and moral
grounds as defined in rticle !" of the #amily $ode%

xxxxxxxxx.&

)%. " have been hearin# rumors that m' husband

has been romanticall' en#a#ed and cohabitin# (ith
another (oman in acolod. ecause of this, " did an
effort to confirm the said rumors. Fntil " found out,
to m' surprised, that he is alread' married (ith
another (oman in the name of ?ar' aith . DiGon
on &u#ust +7, +2)), cop' of their Certificate of
?arria#e is hereto attached as &nne! 5<*

Criminal Case Case by GUAIMALIA

Page 4 of 5

)7. 1hat althou#h the respondent is le#all' married to

the complainant and the marria#e is le#all'
subsistin#, he contracted subseAuent marria#e (hich
is a violation of &rticle %7; of the Revised Penal
Code,pertinent provision of the la( is Auoted
hereunder, to (it:

Article 349. The penalty of prision mayor shall be imposed

upon any person who shall contract a second or subsequent marriage before
the former marriage has been legally dissolved, or before the absent spouse
has been declared presumptively dead by means of a judgment rendered in
the proper proceedings.

). 1hat this act of marr'in# another (oman and

cohabitin# (ith several (omen caused substantial
and emotional distress to me and our children (hich
is violation of para#raph 8h9 ection  of R.& ;+3+*

)3. ?oreover, (e suffer and continuousl' sufferin# of

mental and emotional an#uish, public ridicule and
humiliation (hen he had contracted subseAuent
marria#e and denial of financial support to our
children (hich is a violation of para#raph 8i9 ection
 of R.& ;+3+*

)>. 1hat this act of m' husband is a #ross misconduct

(hich tarnishes the reputation of Philippine National
Police*
)@. 1hat because of this criminal act and #ross
misconduct, m' husband deserves to suffer from
conseAuences of his act and be dischar#ed from
service so as not to allo( a person like him to tarnish
the ima#e of the entire PNP and shall serve as an

Criminal Case Case by GUAIMALIA

Page 5 of 5

e!ample that similar acts cannot be done b' other

members of the PNP*
);. 1hat this criminal complaint is (ithout preHudice of
filin# a separate criminal complaint for bi#am'* and
+2. 1hat " cause the preparation of this affidavit to
support m' complaint.

"N B"1N B4R, " have hereunto set m' hand

this ____________________ at ____________,
Philippines.

GUIAMALIA KENENGKO
Complainant-&ffiant

SUBSCRIBED AND S%ORN to before me this _______

da' of eptember +2).

_____________________
Cit' Prosecutor

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