REPUBLIC OF THE PHILIPPINES}

CITY OF __________________}

COMPLAINT-AFFIDAVIT
I, MARILYN SENSANO AGUSTIN, of legal age, Filipino, married, with address at Blk. 27
Lot 14 Mt. Carmel Road, Montevista Heights, Barrio Dolores, Taytay, Rizal, after having been
duly sworn to in accordance with law, hereby depose and state that:

1. I am executing this Complaint-Affidavit to cause the criminal prosecution of my

legal husband FERNANDO B. AGUSTIN, with address at Blk. 27 Lot 14 Mt. Carmel Road,
Montevista Heights, Barrio Dolores, Taytay, Rizal and his concubine ANNALIZA DURAN
SENSANO, a legally married woman who is also my sister-in-law, with address at Blk. 27 Lot 14
Mt. Carmel Road, Montevista Heights, Barrio Dolores, Taytay, Rizal for the crime of
Concubinage as defined under Article 334 of the Revised Penal Code.

2. The facts of the case are as follows.

3. On May 14, 1999, Fernando B. Agustin and I got married. Attached herewith is a
copy of our Certificate of Marriage as Annex “A” and made an integral part of this Complaint-
Affidavit.

4. Sometime in 2021, I called my brother, Roque G. Sensano and his wife Annaliza
D. Sensano and asked them if Annaliza can work as a Kasambahay in my house at Blk. 27 Lot 14
Mt. Carmel Road, Montevista Heights, Barrio Dolores, Taytay, Rizal. Annaliza will also take care
of my youngest child. The house in Taytay, Rizal is our conjugal dwelling of my husband
Fernando.

5. My brother and his wife Annaliza agreed because they are very close to me and
they wanted to help because I am an Overseas Filipino Worker (OFW) at Kuwait and I only go
back to the Philippines twice a year.

6. While Annaliza was working as a Kasambahay and at the same time taking care
of my daughter, my husband, Fernando B. Agustin, hired Annaliza as a Secretary in the Dental
Laboratory that I own. I was working in Kuwait at this time so it was my husband Fernando
who was supervising the dental laboratory. I did not object to the hiring of my sister-in-law,
Annaliza, as a Secretary in my dental laboratory.

7. The Dental Laboratory was in a building that I also own and is just beside my
house.

8. Since Annaliza was already in Taytay, Rizal, my brother Roque decided to send
his son, Ian Angelo D. Sensano, to study in Manila so that his mother can oversee his studies.
My nephew Ian will also stay in my house. My nephew Ian was enrolled at De Ocampo
Memorial College and is taking up Dental Tech.

9. For some reason, Annaliza was hesitant to allow his son Ian to study in Manila
and instead wanted him to study in Cagayan.

10. While my nephew Ian was living in my house in Taytay, Rizal with her mother
Annaliza, and his Uncle Fernando B. Agustin and my daughter, Ian noticed that his mother

1
Annaliza and my husband Fernando were very close to each other and they were displaying
love and affection towards each other.
11. My nephew Ian also observed that his mother Annaliza and my husband
Fernando were very affectionate with each other as if they are husband and wife. They were
always together, talking to each other, going out and drinking. Their closeness was very
obvious.

12. I was worried because years ago, I suspected that my husband had an affair with
another woman.

13. I told my nephew to continue to observe what his mother Annaliza and my
husband Fernando were doing.

14. My nephew Ian decided to buy a small video camera and install it under a table
inside the master’s bedroom which is our conjugal room so he can see if his mother Annaliza
was sleeping with my husband Fernando and if they were having sexual intercourse.

15. My nephew could remotely access the hidden camera using his cell phone.
Based on the video footage that he was able to recover and some photos, it was confirmed
that my sister-in-law Annaliza was staying and sleeping in the master’s bedroom with my
husband Fernando. This is the same master’s bedroom that my husband and I consider as our
conjugal room and the very bed where Annaliza and Fernando sleep is our conjugal bed.

16. Since my nephew placed the video camera under a table beside our conjugal
bed, there were times when only the leg or the foot can be seen but I can still identify the leg
or foot of my husband Fernando just by looking at it and the slippers or shoes that he was
wearing.

17. In one video footage dated April 16, 2023, at around 9:35 p.m., it can be seen
that my sister-in-law Annaliza entered our conjugal room. My husband Fernando was also
inside our conjugal room.

18. In another video footage dated April 16, 2023, at 10:25 p.m., my sister-in-law
Annaliza entered our conjugal room. My eldest daughter, Kimberly S. Agustin, was knocking on
the door. My husband Fernando could not open the door because Kimberly will see Annaliza.
What Annaliza did was to hide inside the bathroom of our conjugal room. When Annaliza was
inside the bathroom, that was the time when Fernando opened the door.

19. My daughter Kimberly went inside our conjugal room to say good bye to his
father, Fernando, because she was leaving. My daughter Kimberly was accompanied by her
boyfriend who also said good bye to Fernando. My daughter Kimberly and her boyfriend
executed a letter attesting to the fact that the feet that were seen entering our conjugal room
was the feet of Kimberly and that of her boyfriend. Attached herewith is the Letter as Annex
“B”.

20. In another video footage dated April 30, 2023, at around 11:45 p.m., it can be
seen that my husband Fernando was lying down on our conjugal bed and my sister-in-law
Annaliza was lying right next to him. This time, the face of Fernando can be seen.

21. In another video footage dated May 1, 2023, at around 12:45 p.m., it can be
seen my sister-in-law Annaliza entered our conjugal room with only a green towel on that was
wrapped around her body and thereafter, turned off the light. Annaliza slept in our conjugal
room that night.
2
 22. One time, my nephew Ian told me that he saw her mother Annaliza inside our
conjugal room and she was massaging my husband Fernando while he was lying down on our
conjugal bed. Fernando was not wearing a shirt. This happened at 11:30 in the evening.

23. My sister-in-law Annaliza and my nephew Ian share the same room at the
second floor of my house which my husband and I consider as our conjugal dwelling. However,
there are times when my nephew will sleep in a room at the third floor of the building which I
also own beside our conjugal dwelling together with the dental technicians who works at my
dental laboratory and who are stay-ins.

24. One night, my nephew Ian checked if her mother Annaliza was in their room.
Annaliza was not in the room so my nephew decided to go down to the ground floor to check
if Annaliza was there.

25. The lights at the kitchen and sala were turned off but my nephew could still see
his surroundings.

26. While my nephew Ian was standing beside the kitchen window, he heard some
moaning sound of sexual pleasure from the master’s bedroom which is our conjugal room.
After a few minutes, a lady wearing white came out of the master’s bedroom. This lady who
came out of the room was my sister-in-law, Annaliza. My husband Fernando was inside our
conjugal room.

27. My nephew Ian saw her mother Annaliza go to the kitchen sink to spit several
times and she gargled several times too.

28. When Annaliza came out of our conjugal room, she was tip-toeing so that no one
could hear her.

29. Annaliza was so worried that someone might see or hear her, she never noticed
that her son Ian was standing right next to the kitchen sink. Annaliza probably thought that
because the lights were turned off, she did not expect anyone to be at the kitchen or sala at
that time.

30. After spitting and gargling repeatedly, Annaliza went up to her room at the
second floor.

31. My distant relative, Soledad G. Quines, also witnessed my sister-in-law Annaliza

come out of the master’s bedroom which is our conjugal room wearing only a white sando and
a thin blanket that was wrapped around her thighs. This happened around 9:30 p.m. of March
10, 2023. Only Annaliza and Fernando were inside our conjugal room at that time. Attached
herewith is the Sinumpang Salaysay of Soledad G. Quines as Annex “C”.

32. In the Sinumpaang Salaysay, Soledad G. Quines also made a statement under
oath that she noticed the closeness of Annaliza and Fernando and that they were showing love
and affection to each other as if they were husband and wife.

33. There was also a time when Fernando asked my nephew Ian to buy “pulutan”.
Thereafter, my nephew Ian saw her mother Annaliza and my husband Fernando drinking
alcohol inside the master’s bedroom which is our conjugal room and showing love and
affection to each other.

3
 34. On another occasion, my nephew and his classmates went to my house to do a
school project. They decided to stay in the room where Annaliza and my nephew Ian sleep.
When Annaliza saw his son Ian and his classmates, she told his son that they can use the room
and she will sleep in another room at the second floor of the house.

35. At around 1:00 a.m., my nephew Ian decided to check on his mother Annaliza if
she was sleeping in the other room. When he entered the room, Annaliza was not there.

36. My nephew Ian decided to go down to the ground floor to check if his mother
Annaliza was there.

37. When my nephew Ian was at the ground floor, he did not turn on the lights but
instead, he turned on the flash light of his cell phone. When he turned on the flash light, he
saw something at the sofa that appears to be a person covered by a blanket. My nephew
approached the sofa and decided to take a look at what is under the blanket. When he
removed the blanket, he did not see his mother Annaliza and there were several pillows under
the blanket and was arranged in such a way to make it appear that a person was covered by a
blanket and sleeping. Annaliza made I appear that she was the one sleeping so that my
nephew will not suspect her of sleeping in the master’s bedroom with Fernando.

38. My nephew Ian went to the master’s bedroom which is our conjugal room to
check if his mother Annaliza was there. He tried turning the door knob but it was locked.

39. My nephew Ian was hearing some moaning coming from the master’s bedroom
which is our conjugal room so he decided to use his cell phone to record the sound that he was
hearing. His cell phone could not record the sound because it was not loud enough.

40. So, my nephew decided to put his ear right beside the main door of the master’s
bedroom which is our conjugal room to check the moaning sound he was hearing.

41. When he placed his ear right next to the door, my nephew Ian heard a moaning
sound of sexual pleasure like “oohhhh” “aahhhh” “yeahhh” being uttered by his mother
Annaliza. My nephew also heard my husband Fernando utter the same moaning sound of
sexual pleasure. Annaliza and Fernando were also saying words to each other that my nephew
could not understand anymore. It was very obvious that my sister-in-law Annaliza and my
husband Fernando were having sexual intercourse at our conjugal room and using our conjugal
bed.

42. My nephew Ian listened to the moaning sound of sexual pleasure from Annaliza
and Fernando for more or less 20 minutes.

43. While my nephew Ian was listening, he was crying. He felt disgusted, angry and
humiliated. He took a picture of himself crying and he sent the picture to me. He also texted
his father Roque and his sister Alleiya and informed them of what he was witnessing.

44. My nephew Ian could not stand listening to the sexual acts of her mother
Annaliza and my husband Fernando so he decided to go back to his room at the second floor.
The classmates of my nephew noticed that he was crying and asked why he was crying.

45. At around 3:00 a.m., my nephew Ian decided to check again if her mother
Annaliza was sleeping in the other room in the second floor. This time, she was there.

4
 46. My nephew Ian was traumatized because he heard his own mother having
sexual intercourse with his Uncle Fernando.

47. To date, my nephew Ian told me that Annaliza still regularly sleeps in the
master’s bedroom which is our conjugal room with my husband Fernando like they are
husband and wife.

48. My nephew Ian even saw my husband Fernando sleep in the room where
Annaliza sleeps because he knows that my nephew is no longer sleeping in that room.

49. My sister-in-law Annaliza and my husband Fernando consistently have sexual

intercourse. They usually have sexual intercourse every Tuesday and Friday. My nephew Ian
can hear them every time he will stay outside the master’s bedroom.

50. I was informed by my nephew Ian that on May 3, 3023 at around 6:00 p.m., he
saw his mother Annaliza and my husband Fernando drinking alcohol at the dental laboratory.
They finished drinking at around 10:00 p.m. Thereafter, Annaliza went to the second floor to
take a shower and after taking a shower, Annaliza went to the master’s bedroom which is our
conjugal room to sleep with my husband Fernando.

51. My nephew Ian went to the ground floor to check on his mother. When my
nephew stood right beside the main door of the master’s bedroom which is our conjugal room,
he heard his mother Annaliza and my husband Fernando moaning and they were having sexual
intercourse again.

52. I was also informed by my nephew Ian that on May 4, 2023, at around 7:00 a.m.,
his mother Annaliza entered the room where he was sleeping to get clothes. His mother
Annaliza only had a thin blanket to cover her body. Annaliza was wearing nothing other than
the blanket she used. Annaliza came from the master’s bedroom which is our conjugal room
where she slept all night with my husband Fernando.

53. From the foregoing, the crime of Concubinage as defined and penalized in Article
334 of the Revised Penal Code was committed by my husband, Fernando B. Agustin and his
paramour who is also my sister-in-law, Annaliza D. Sensano.

54. The crime of Concubinage, as defined under Article 334 of the Revised Penal
Code, is committed by a married husband by (a) keeping a mistress in the conjugal dwelling; or
(b) having sexual intercourse under scandalous circumstances with a woman who is not his
wife; or (c) cohabiting with her in any other place.

55. In the present case, the crime of Concubinage was committed by my husband
Fernando and his concubine who is also my sister-in-law Annaliza D. Sensano in two ways.

56. First, my husband Fernando is keeping a mistress in our conjugal dwelling.

57. Through my hard work and perseverance as an Overseas Filipino Worker (OFW)
in Kuwait, I was able to save my earnings and purchase a lot and build our dream home in
Taytay, Rizal. My husband Fernando also helped but his contribution was only minimal. I
shouldered the bulk of the expenses. The house located at Blk. 27 Lot 14 Mt. Carmel Road,
Montevista Heights, Barrio Dolores, Taytay, Rizal is our conjugal dwelling.

5
 58. My sister-in-law Annaliza is the mistress of my husband. I asked my sister-in-law
to be the Kasambahay in our conjugal dwelling and take care of my youngest child. When I left
for Kuwait to work, she entered into an intimate/illicit relationship with my husband Fernando.

59. It was very convenient for Fernando and Annaliza because they live in the same
house. Annaliza is sleeping in our conjugal room and conjugal bed. There is video footage to
prove that Annaliza is sleeping with my husband in our conjugal room and conjugal bed.

60. The children of my brother Roque namely Ian Angelo D. Sensano and Alleiya D.
Sensano who are also the children of Annaliza witnessed the intimacy between Annaliza and
my husband Fernando and how they show love, care and affection to each other and they act
as if they are husband and wife.

61. While I work as an OFW in Kuwait, my husband Fernando and my sister-in-law

Annaliza are in a relationship and living like husband and wife in our conjugal dwelling. This
was witnessed not only by my nephew and my niece but by my own children. Even our distant
relative, Soledad G. Quines who stayed in our conjugal dwelling notice the relationship
between Fernando and Annaliza and how they act as if they are husband and wife.

62. When Fernando and Annaliza attended the fiesta at our home town in Cagayan,
all our relatives and friends noticed their closeness and how they show love and affection to
each other. Fernando and Annaliza were clearly not hiding their relationship anymore or
keeping it a secret. They even took a plane ride to Cagayan with no one else accompanying
them.

63. Secondly, my husband Fernando is having sexual intercourse under scandalous

circumstances with a woman who is not his wife.

64. My husband Fernando had sexual intercourse with my sister-in-law in our own
conjugal room and conjugal bed. Up to the present, they are still having sexual intercourse in
our conjugal dwelling, inside our conjugal room and using our conjugal bed and living there as
if they are husband and wife.

65. The sexual intercourse is definitely scandalous because Fernando and Annaliza
are having sexual intercourse in our conjugal dwelling. Worse, Fernando and Annaliza are
having sexual intercourse in our conjugal room and our own conjugal bed.

66. The sexual intercourse of Fernando and Annaliza is also scandalous because it
was witnessed by my nephew Ian who is the son of Annaliza. Every night, once my sister-in-law
Annaliza enters our conjugal room, my nephew Ian will check and almost always will find out
that Fernando and Annaliza are having sexual intercourse.

67. If Fernando and Annaliza are not having sexual intercourse, Annaliza is sleeping
in our conjugal room and conjugal bed.

68. Even my distant relative, Soledad G. Quines, who only stayed in our conjugal
dwelling for two weeks, witnessed Annaliza came out of our conjugal room wearing only a
sando and a thin blanket that was wrapped around her thighs. It can be assumed that by
looking at how Annaliza was dressed and the fact that she did not say anything to Soledad at
that precise moment and the day after, Annaliza and Fernando just had sexual intercourse.

69. My nephew Ian also saw her mother come out of our conjugal room and went
straight to the kitchen sink to spit and gargle. It can be assumed that by looking at how
6
Annaliza was dressed that night and the fact that she was tip-toeing just so that no one would
hear her, Annaliza and Fernando just had oral sex.

70. In support of my complaint, I am attaching herewith the Affidavit that was

executed by my nephew, Ian Angelo D. Sensano and the Affidavit that was executed by my
niece, Alleiya D. Sensano as Annex “D” and Annex “E” respectively and made an integral part
of this Complaint-Affidavit. Attached to the Affidavit of my nephew Ian is the USB where all the
video footages are saved.

71. From the foregoing, there is definitely a reasonable certainty of guilt on the part
of my husband Fernando B. Agustin and his concubine and my sister-in-law, Annaliza D.
Sensaso that they committed the crime of Concubinage under Article 334 of the Revised Penal
Code.

72. I am executing this sworn statement to attest to the truth of all the foregoing
and to cause the criminal prosecution of Annaliza D. Sensano and Fernando B. Agustin for the
crime of Adultery as defined in Article 333 of the Revised Penal Code.

AFFIANTS FURTHER SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto set my hands this __ day of _______ 2023 in
_______________.

__________________________
MARILYN SENSANO AGUSTIN
Complainant

SUBSCRIBED AND SWORN TO, before me this __ day of _______ 2023 in _________
Affiant exhibiting to me her ________________ as sufficient proof of identity.

_________________________
ASSISTANT CITY PROSECUTOR