Page 1 of 25
Republic of the Philippines ) _________________ ) S.S. COMPLAINT-AFFIDAVIT
I,
FRANCIS PANCRATIUS N. PANGILINAN
, of legal age, Filipino, married, and with address at ____________________, having been duly sworn in accordance with law, hereby depose and state that: 1.
I am an incumbent Senator of the Republic of the Philippines, and I have been serving as a Senator since 2016. 2.
I am filing this complaint against the owner/s, author/s, and person/s responsible for the creation and management of the YouTube channel, STARLET, and the libelous videos posted therein, for the crime of Libel under Section 4(c)(4) of Republic Act No. 10175, also known as the Cybercrime Prevention Act of 2012, in relation to Article 355 of the Revised Penal Code, as amended. 3.
I am also filing this complaint against MS. BERNADETTE NACARIO as country Manager of GOOGLE PHILIPPINES for violating Section 20(b)(1) and Section 30(j) of the Rules and Regulations Implementing Republic Act No. 10175, otherwise known as Cybercrime Prevention Act of 2012. 4.
STARLET is a YouTube channel that can be accessed through the following URL or link: https://www.youtube.com/channel/UCWSjQ9OHMlWXghoOq J4tkYw/featured. Based on the information on its channel, STARLET joined YouTube on 02 December 2020. 5.
On 20 May 2021, STARLET authored and posted on its YouTube channel a video entitled,
“Kiko Pangilinan, NAGMAKAAWA kay Sharon Cuneta na huwag ng ituloy ang KASONG isinampa sa kanya…”
The video may be accessed through the following URL or link: https://www.youtube.com/watch?app=desktop&v=hglEWs42lQk. A copy of the video thumbnail and screenshot are attached as
Annexes “A” and “A-1”
. 6.
The video thumbnail (
Annex “A”
) contained the following text:
“Patawarin mo ako Sharon! Hindi ko sinasadya…”