REPUBLIC OF THE PHILIPPINES}

QUEZON CITY } S.C.

X =========================== X

COMPLAINT-AFFIDAVIT

I, WINNIE TORRES, of legal age, single, Filipino and a resident of 78 Paterno Street,
Downtown, Tacloban City, Leyte, Philippines, after having been sworn to in accordance with
law do hereby depose and state:

1. That I am instituting this CRIMINAL COMPLAINT against LESLIE MENDOZA, of

legaL age, single, Filipino, and a resident of Paterno Ext, Downtown, Tacloban City,
Leyte Philippines for CYBERLIBEL as defined and penalized under Article 355 of the
Revised Penal Code of the Philippines in relation to Section 4 (c) (4) of the
Cybercrime Prevention Act of 2012 (RA 10175)

2. That the acts complained of were committed as follows:

a. On January 2011, petitioner wrote and published on The Juicy Scoop an

article entitled “Police Cracks Down Child Trafficking Ring; Rescues 176
Minors And Recovered Vehicles Owned by a Local Politician;

b. On February 2011, former Tacloban City Mayor Winnie Torres (complainant)

filed a criminal complaint for libel against the petitioner but was
subsequently acquitted;
c. In April 2014, The Juicy Scoop launched its website
(www.thejuicyscoop.com.ph) to digitize all of its articles and make them
accessible to the public online;

d. On May 21, 2014, the Juicy Scoop uploaded on its website an article it
published in 2011, changing only the latter part of the title to read: “Police
Cracks Down Child Trafficking Ring; Rescues 176 Minors And Recovered
Vehicles Owned by the Former City Mayor;

e. That I found an injurious and defamatory article in the Juicy Scoop Website
accessible in Quezon City, which I accessed in a hotel in said city;

3. That by reason of the foregoing, I suffered sleepless nights, wounded feeling,

moral and social embarrassment which Leslie Mendoza should compensate by
way of moral damages which is the natural, proximate and necessary result of the
malicious publication in the amount of not less that One Hundred Thousand Pesos
(Php100,000.00).
 4. That I am executing this affidavit to attest to the truth of the foregoing averments
and for the purpose of criminally prosecuting said Leslie Mendoza for
CYBERLIBEL as determined by the Prosecution Office.

IN WITNESS WHEREOF, I have affixed my signature this 4th day of October 2017 in
Quezon City, Philippines.

WINNIE TORRES
Affiant

SUBSCRIBED AND SWORN to before me in the City of Santiago this 4th day of October
2017. I hereby certify that I have personally examined the above named affiant and that I am
the foregoing statements were given by her voluntarily and of his own free will.

_______________________
Investigating Prosecutor