Republic of the Philippines….

)
City of Tagum………………………)S.S.
Province of Davao del Norte)
X------------------x

COMPLAINT-AFFIDAVIT

I, _________________, of legal age, single/married, Filipino, and

a resident of__________________, Philippines, under oath, hereby
depose
and say, THAT:

1. I hereby formally charge______________, Filipino married and a

resident of _____________for the crime of Libel under section 4, (c)
paragraph 4 of R.A. 10175 also known as the Cybercrime
Prevention Act of 2012;

2. Respondent caused the posting and publication of malicious,

demeaning, and defamatory imputations published for all to
see through her Facebook account, to wit:
“________________________________”
3. The foregoing posts published by the respondent contained
malicious imputations with devious design and evil motives,
purposely made to malign, dishonor, discredit, and insult my
character and reputation as a person and as a practitioner of my
profession as__________, to the public as well as to my neighbors,
and colleagues;

4. As can be gleaned from the above-quoted posts, the respondent was

clearly and ultimately motivated by the evil design of putting my name
in opprobrium. In fact, one of my clients informed me that the
respondent told her to join with her in filing an administrative case
before the Professional Regulation Commission against me. Since the
said client did not conform with the respondent’s cajolery, she used
her influence to scrutinize the whereabouts of my client’s building
permit. Clearly, the respondent has the intention to injure my
reputation as an________. A copy of the Affidavit of Witness to form
an integral part hereof is hereto attached as Annex “F”.

5. The afore-quoted excerpts of online posts authored and published by

the respondent cast aspersion in the minds of the readers that I am a
deceitful and a terrible contractor;

6. Moreover, the said posts written and published by the respondent are
highly speculative and contain false statements consciously and
deliberately made to destroy my reputation, integrity, and character as
 a person as well as to my family. The respondent is motivated by
bad faith in publishing the said posts online to defame,
embarrass, and discredit me to my colleagues, friends, family, and to
the readers and patrons of Facebook;

7. Assuming without, however, admitting that I committed any

undesirable acts whatsoever against the respondent, the same should
not be a license for her to destroy my name and my family’s
reputations as well. The respondent had no good intention or any
justifiable motives whatsoever when she posted online the said
defamatory imputations;

8. The libelous posts that have been published through Facebook, a social
media website accessible to, and made available to the public were in
fact read by many, including my colleagues, friends, and family, among
others. The same was, without any taint of doubt, directly imputed
by the respondent against me when she stated_________. The said
posts earned numerous likes and comments as shown in the
foregoing annexes;

9. Owing to the said malicious public imputations by the respondent, I,

and my family, suffered and continue to suffer serious
anxiety, besmirched reputation, mental anguish, sleepless nights, not
to mention the damage she has caused to my reputation and honor as
an _________among the readers, patrons of Facebook, my clients,
and the public;

10. Because of the unbearable effects of the malicious imputations caused

by the respondent against me, I reported the matter to the Philippine
National Police Anti-Cybercrime Group, Regional Anti-Cybercrime
Unit in__________. Copies of the police blotter under Entry
#_______ and Entry #_________ are hereto attached as
Annex______, respectively, to form an integral part hereof;

11. Police officer ____________ of the Philippine National Police

Anti-Cybercrime Group, Regional Anti-Cybercrime Unit confirmed
that the libelous posts were indeed authored and originated from the
Facebook account of the respondent “_______” with
URL:________________. A copy of the Affidavit of Witness
is hereto attached as Annex “___”.

12. Due to such grossly unjustified malicious and libelous

imputations, I therefore pray that the respondent is made to pay the
damages I was made to suffer because of the online published article
in whatever amount the appropriate court deems sufficient and proper
together with the attorney’s fees and the cost of this suit;

13. I hereby execute this affidavit to attest to the truth of the foregoing
facts and hereby request the investigating officer to file the crime of
Libel under R.A. 10175 and other crime or crimes committed against
 the herein respondent ________who may be served with a subpoena
and other processes of this Honorable Office at__________________.
IN WITNESS WHEREOF, I have hereunto set my hand
this____________ in____________________, Philippines.

___________________
Affiant/Complainant
Valid ID No: ______________

SUBSCRIBED AND SWORN to before me this _____________

at_________. I hereby certify that I have examined the affiant and that I
am fully satisfied that he/she has voluntarily executed and understood the
contents of his Complaint-Affidavit.