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Complaint Affidavit Crimpro
Complaint Affidavit Crimpro
AMIELA SARMIENTO-SANTOS
Complainant, Criminal Case No. 2172-19
versus For
CONCUBINAGE
JOSEPH JHONLEE D. SANTOS &
QUEEN JAREMY CASTILLO
Respondent.
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COMPLAINT AFFIDAVIT
1. On March 20, 2016, JOSEPH JHONLEE D. SANTOS, the respondent, and I got
married.
3. On May 25, 2016, I saw credit card receipts in my Husbands wallet which shows
jewelry, a tennis bracelet, bought from Tiffany and Co by Jhonlee with his Mastercard. I
also saw the same jewelry referred in the receipt in a box beside my husbands suitcase
inside the closet. A copy of the credit card receipts is hereto attached as
Annex A
4. When I opened my husbands suitcase, I saw a used roundtrip plane ticket for MNL-
Hongkong-MNL. The tickets were issued under the names of respondents, for the
period of April 18-19, 2016. A copy of the roundtrip plane tickets is hereto attached as
Annex B.
5. Upon further investigation, I also found receipts showing that respondents had stayed
together in one suite at the Marco Polo Hotel. Their stay together at a hotel has also
persuaded me that they have already had carnal knowledge of one another. A copy of
the receipts showing proof of their stay at the Marco Polo Hotel is hereto attached as
Annex C.
6. That I have seen a Sex Video of My Husband Johnlee and Queen in the Cellphone of
my husband.
6. In addition, it is most unlikely that Ms. QUEEN JAREMY CASTILLO had not been
aware of my husbands current status as a married man seeing as this affair has been
going on for more than a year. They have been meeting together discreetly as well as
leaving on trips together abroad and meeting with another at hotels.
7. Based on the foregoing facts, I have logical reason to believe that the respondents
have committed the crime of Concubinage punishable under Art. 334. Concubinage.
Any husband who shall keep a mistress in the conjugal dwelling, or shall have sexual
intercourse, under scandalous circumstances, with a woman who is not his wife, or shall
cohabit with her in any other place, shall be punished by prision correccional in its
minimum and medium periods, under the Revised Penal Code.
8. I am executing this sworn statement for the purpose of charging my husband and his
concubine with violating Art. 334 of the Revised Penal Code which penalizes the crime
of concubinage. At Pasuquin Ilocos Norte, Philippines. June 25, 2017.
AMIELA SARMIENTO-SANTOS
Complainant
SUBSCRIBED and SWORN to before me, the undersigned prosecutor, this 25th day of
November, 2017 in Bangui, Ilocos Norte, Philippines.
I hereby certify that I have personally examined the above-named affiant and that I am
satisfied that the foregoing statements were given by her voluntarily and of her own free
will.
AMIELA SARMIENTO-SANTOS
Affiant
SUBSCRIBED AND SWORN to before me this 25th day of June at Pasuquin, Ilocos
Norte, Philippines.
AMIELA SARMIENTO-SANTOS
Complainant, Criminal Case No. 2172-19
versus For
CONCUBINAGE
JOSEPH JHONLEE D. SANTOS &
QUEEN JAREMY CASTILLO
Respondent.
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INFORMATION
That on or about 31 March 2016, May 25, 2016, April 18-19, 2016, in the
City/Municipality ofPasuquin, Province of Ilocos Norte and within the
Jurisdiction of this Honorable Court, the accused JHONLEE D. SANTOS who is
the husband of the undersigned Complainant, cohabited and under
scandalous circumstances with his co-accused QUEEN JAREMY CASTILLO as
husband and wife in a private dwelling, Producing a sex taped video.
Contrary to law.
Pasuquin, Ilocos Norte, Philippines, June 25, 2017
AMIELA SARMIENTO-SANTOS
COMPLAINANT
SUBSCRIBED AND SWORN to before me this 25th day of June at Pasuquin, Ilocos
Norte, Philippines.
Witnesses: