COMPLAINT AFFIDAVIT

I, Filomena Guieb, of legal age, and resident of Murong, Bagabag, Nueva Vizcaya,
hereby depose and state the following:

1. That I am filing a Criminal Complaint against Mrs. Dearly O. Quinto, a resident of

Murong, Bagabag, Nueva Vizcaya;

2. That the basis of my complaint is Article 358 of the Revised Penal Code which
states and defines the penalty for Slander or Oral Defamation;

3. The this complaint is based on the following undisputed facts:

A. That I owe a certain amount of money from Mrs. Dearly Quinto;

B. On July 6, 2019, we had a mediation at the residence of Mrs. Ritz Olano, our
Purok President, to settle the terms and payment options since I went on default
which I am aware of;

C. That I have been making remedies so I can repay my loan;

D. However, during the mediation, Mrs. Dearly Quinto willfully, unlawfully and
feloniously and with malicious intent defamed my character as a person and as
teacher employed in the public school;

E. That during the mediation, she shouted and yelled in vernacular the following:

“Ti dakkel nga bagim ket kasta met kaddakel ti ulbod mo”

“Maestra ka nga dambel”

F. Other words heard by many people, which were intended to malign, belittle
and humiliate me, were uttered by Mrs. Quinto;
 G. That the mediation hearing could have been peaceful and civil but Mrs. Quinto
intently, with premeditation, planned to tarnish my reputation only because I owe her
an amount of money;

H. That Oral Defamation is defined by jurisprudence as "the speaking of base

and defamatory words which tend to prejudice another in his reputation, office,
trade, business or means of livelihood." The elements of oral defamation are: (1)
there must be an imputation of a crime, or of a vice or defect, real or imaginary,
or any act, omission, status or circumstances; (2) made orally; (3) publicly; (4)
and maliciously; (5) directed to a natural or juridical person, or one who is dead;
(6) which tends to cause dishonor, discredit or contempt of the person defamed.”
(De Leon vs People as stated in Digna Ramos vs Republic of the Philippines, G.R. No.
226454, November 20, 2017);

I. Here, the elements of Oral Defamation stated above are all present, making Mrs.
Dearly Quinto liable for the offense of Oral Defamation;

J. This statement shall be corroborated by Mrs. Ritz Olano, Mrs. Nelly Toquero
and Mr. Richard Estabillo, all present during the mediation.

I hereby pray that a charge against Mrs. Dearly Quinto for Violation of Article
358 of the Revised Penal Code be filed and heard in the proper venue and jurisdiction.

All other reliefs, just and equitable are fervently prayed for.

Done this 16th day of July in Murong, Bagabag, Nueva Vizcaya.

FILOMENA GUIEB
Complainant