Pelagio, Graciela May R.

Trial Technique
2015-MJD-025 Judge TitaAlisuag

Republic of the Philippines

City of Manila s.s

COMPLAINT-AFFIDAVIT

I, Mrs. X, 35 years old, married to Mr. X, the deceased, a resident of 1321 Almar, Rlk. 4 Tondo, Manila hereby depose that:

1. Mr. X, the deceased is 40 years old, married to Mrs. X and a resident of 1212 LaongLaan, Tondo Manila.
The Defendant, Mr. Y, is of legal age, single, residing at 1321 Almar, Rlk. 4 Tondo, Manila.
2. Last September 14, 2010, on or about 9:30 P.M husband Mr. X was at the house of his officemate, Mr. A
and was having a drinking spree to celebrate the latter’s birthday.
3. Mrs. X, was informed by Mr. X through a text message that he will arrive home late because the drinking
spree had not yet started and they are still waiting for their other visitors to be at Mr. A’s house namely,
Mr. W, Mr. Y and Mr. Z who were Mr. A’s former employees.
4. One of Mr. A’s friends who came later was Mr. Y who is a security guard of Mr. A’s previous work place.
Mr. Y is not a stranger to Mr. X because Mr. A would often invite the former to certain occasions.
5. According to the statement by Mr. A, while having their drinking session, at around 1 AM, he asked his
visitors who among them will go home and who will spend the night in his house, since everyone was
already intoxicated by alcohol. Mr. X, told Mr. A that he will needs to go home since he informed Mrs. X
that he will be home late. Mr. Y and Mr. W also informed Mr. A that they need to go due to their duty the
following morning. Mr. A’s Affidavit is attached and marked as ANNEX “1A”
6. At around, 1:30 AM, Mr. X, Mr. Y and Mr. W bid their good byes to Mr. A and went out of the house.
7. According to the statement of Mr. W, while the three of them were walking towards Mr. X’s car, Mr. Y
told them that he needs to pee. Several minutes have passed when Mr. Y appeared and unexpectedly shot
Mr. X using the latter’s gun. Mr. W’s affidavit is attached and marked as ANNEX “B"2
8. Mr. Y then hurriedly fled and Mr. W shouted “Bumalikkadito, bakitmosyabinaril?”

9. Thereafter, Mr. S, a tanod roaming at the area during that time heard Mr. W’s outrage. Mr. S then called
the policeman and the ambulance.
10. Moments later, Mr. X was brought to Wayadi Hospital but he was dead on arrival due to severe blood loss
because of the 3 gun shots in located in his upper right arm, as evidenced by the medical report conducted
by the attending physician Dr. Kenneth Ilagan which is attached as Annex “3C”.
11. After Mr. X’s death, the policemen had several operations to locate Mr. Y but he was nowhere to be found.
12. Mr. W immediately reported the incident at Marasbaras Police Station which is the nearest police station.
The original copy of the excerpt of the police blotter duly issued by Senior Police Inspector
VirgilioGuimaras III of Marasbaras Police Station is hereunto attached and made as an integral part hereof
as Annex “4D” of the complaint;
13. Mrs. X is executing this affidavit freely and voluntarily in support filling a case for MURDER and/or the
appropriate criminal case against Mr. Y.

1
Affidavit of Mr. A
2
Affidavit of Mr. W
3
Medical Report
4
Blotter Report
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Pelagio, Graciela May R. Trial Technique
2015-MJD-025 Judge TitaAlisuag

IN WITNESS WHEREOF, I have hereunto affixed my signature for and in behalf of the complainant Mrs. X, Tondo, Manila this
22th day of September 2010, at Tondo, Manila, Philippines.

Mrs. X

Affiant

SUBSCRIBED and SWORN to before me this 22nd day of Sptember 2010, at Tondo, Manila. I hereby certify that I have
personally examined the above-named affiant and that I am satisfied that the foregoing statements were given by him voluntarily
and of his own free will.

Azrifa A. Mamutuk

Associate Prosecution Attorney II

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