Republic of the Philippines) S.

Quezon City ) S.

COMPLAINT AFFIDAVIT
I, JULIE ADRIANO VALLARTA, of legal age, Filipino citizen with address at Block 7 Lot 8, Susana
Lane, Diamond Village, Brgy. Kaligayahan, Novaliches, Quezon City, after being sworn according to law,
depose and state that:

1. My mother, Virginia P. Adriano, ninety (90) years old, the registered owner of a lot and
building located at Block 7 Lot 8, Susana Lane, Diamond Village, Novaliches Quezon City,
covered by Transfer Certificate of Title No. RT-96944 (340076) with an area of TWO
HUNDRED SEVENTEEN (217) SQUARE METERS, more or less with a building constructed
thereon, consisting of five (5) units, each unit consisting of 1st, 2nd, 3rd floors and a roof deck.

2. I am the attorney-in-fact and daughter of Virginia P. Adriano whose residence is at Block 7

Lot 8, Susana Lane, Diamond Village, Brgy. Kaligayahan, Novaliches Quezon City. A copy of
the said Special Power of Attorney is hereto attached as ANNEX “A”.

3. I am likewise the attorney-in-fact of my mother to act in her behalf to deal with Smart
Communications, Inc. in connection with the Leased space for cellular tower located at Block
7 lot 8 Susana Lane, Diamond Village, Novaliches, Quezon City. A copy of the said Special
Power of Attorney is hereto attached as ANNEX “B”.

4. These ANNEXES “A” and “B” effectively cancelled the Special Power of Attorney my parents
executed on 18 June 2008 in favor of their son and our brother Buenaventura P. Adriano Jr.
a copy of the said special Power of Attorney is hereto attached as ANNEX “C”.

5. To reiterate that Buenaventura P. Adriano, Jr. is no longer authorized by my parents to deal

with the Smart Communications, Inc., my mother wrote a letter on 26 January 2022 to the
company about the revocation and re-assignment of the Special Power of Attorney is hereto
attached as ANNEX “D:

6. Due to the revocation of the Special Power of Attorney in favor of Buenaventura P. Adriano,
Jr., my mother, Virginia P. Adriano and with the execution of hereto ANNEXES “A” and “B”,
I , as the new attorney-in-fact, wrote through my lawyer on 16 May 2022 three (3) separate
letters addressed to Spouses Buenaventura P. Adriano, Jr. and Evelyn N. Adriano with the
following subject matters, to wit:

a) Rentals of Units 1&2 belonging to me and my brother Virgilio P. Adriano-ANNEX “E”

b) Accounting for Rentals paid by Smart Communications, Inc – ANNEX “F”

c) Harassment, Threats, Intimidation and verbal abuse against Smart Communication

personnel tenants and family members – Annex “G”

all of which were received by the spouses.

7. In connection with ANNEX “E”, Buenaventura P. Adriano Jr., and his spouse Evelyn N.
Adriano leased out my (Unit 1) and my brother Virgilio’s unit (Unit 2) without our permission
and owned appropriated for themselves the rental payments since 2000 with the rent
payments amounting to _________________________, as of June 2022 for both my unit
and my brother Virgilio’s Unit.

8. In connection with ANNEX “F”, the spouses collected from the Smart Communications, Inc.
for the rental payments for the tower installed in the building since 18 June 2008 without
remitting the amount to my mother or to me, amounting to ______________________, as
of June 2022.
 9. In connection with ANNEX “G”, the spouses harassed and blocked the personnel of Smart
Communications, Inc. access to the tower in order for Smart personnel to service the tower
and equipment and conduct periodic maintenance work.

10. The spouses also intimidated and harassed the tenants occupying the unit owned by me and
my brother, forcing the tenants to deliver to them the rents due to me and my brother
Virgilio inflicted physical injuries to our relatives. Pictures of physical injuries inflicted to our
relatives are hereto attached as ANNEXES “________________________”

11. I executed this Complaint Affidavit to aver the truth of the foregoing and for purposes of
filling cases against SPOUSES BUENAVENTURA P. ADRIANO, JR and EVELYN N. ADRIANO for
Qualified Estafa, Serious Physical Injuries, Grave Threats, Harassment, Intimidation and
other related cases.

_______________________
JULIE ADRIANO VALLARTA
Affiant

JURAT AND CERTIFICATION

SUBSCRIBED AND SWORN to before me, the undersigned Prosecutor this _____________ day of
2022 in Quezon City. I hereby certify that I personally examined the affiant and that I am satisfied that
he voluntarily executed and understood his complaint affidavit.

___________________________
Assistant City Prosecutor