REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
MANILA CITY

JHEMERLYN I. LUMALABAN,
Complainant I.S. No.8080-911

FOR:VIOLATION OF
-versus- SEC. 3 RA 7877

NICHOLAS S. HOLE,JR.
Respondent.
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COMPLAINT-AFFIDAVIT

I, JHEMERLYN I. LUMALABAN, of legal age, Philippine

Citizen, resident of House 33, Hepa Subdivision, Manila
City, after having been sworn in accordance with law,
do hereby depose and state that:
1. The respondent, NICHOLAS S. HOLE,JR., is the
owner and executive producer of Spotitunes Records
Manila located at Building 456, Manila. He may be
served with notices at the said address.

2. Since I was a little girl, I have always

dreamed of becoming a singer. I entered all kinds of
singing contests where I was discovered by my agent Mr.
James Rebond sometime in 2017.

3. Mr. Rebond was the one who introduced me to

herein respondent who I knew as a music producer. Mr.
Rebond’s own affidavit is attached herewith.

4. On 27 April 2018, we set a meeting in

respondent’s studio to discuss the possible recording
of my album. The respondent expressed his outmost
interest in my music and my possible career under his
well-known record label.

5. On 15 May 2018, we signed a formal contract

stating that I was officially employed as an artist of
Spotitunes Records. The said contract is attached
herewith.

6. I began recording my music immediately. I go

to the studio five times a week to work on my album
entitled ‘Hidden Jhems’. It was set to release on
November 2018.

7. On 20 June 2018, a month after I started

working on my album, I received a call from my agent
that the management of Spotitunes were not happy with
it. Mr. Rebond told me to go to the studio immediately
to talk to them.

8. I arrived at the studio at around 10:00 am and

found the respondent, Mr. Hole, listening to my album.
Nervously, I asked if he liked my songs but, instead
of answering my question, Mr. Hole invited me to eat
lunch with him.

9. Mr. Hole brought me to Manila Hotel and said

we would be having lunch at the buffet. I did not mind
this because I was still worried about the fate of my
album.

10. During lunch, we did not talk about my album.

Instead, he kept asking personal questions about my
previous romantic relationships, and my family.

11. After eating, he finally asked me about my

album. He asked if I really wanted Hidden Jhems to be
released that year. Of course, I told him yes.

12. He then told me that he was going to show me

something in the hotel. He told me it would be helpful
for my career.

13. We went up to the ninth floor. He then pulled

out a key card and gestured to room 911. We went in.

14. I began to think this was an odd place to talk

about my album. He then told me how he wanted to have
me in his studio even before he heard my voice. He
advanced towards me and caressed my hair.

15. I froze but I told him I wanted to go home

already. He then confessed how much he has admired my
face and my body. He pulled me closer to him and kissed
me.
16. I pushed him away and ran for the door.
Thankfully, he did not follow me.

17. However, he kept calling and texting me saying

that my album might not be released unless I go back
to him.

18. Our conversation went as follows:

Mr. Hole: “Jhem, hindi ba gusto mo sumikat?”
(Don’t you want to be famous?)
Me: “Sir, nabastos po ako sa ginawa ninyo.”
Mr. Hole: “Nako Jhem, walang sumisikat sa
talent lang. Kailangan mong pasayahin kaming
mga producer.” (No one gets famous on pure
talent. You have to make the producers happy)

The print screen of the said text conversation are

attached in the annex. The phone itself may likewise
be submitted as evidence if the Court allows.

19. Mr. Hole’s acts and the sexual insinuations

rendered me to have sleepless nights, wounded feelings,
and serious anxiety.

20. I have neither been in contact with him since

the incident nor have I returned to the studio because
of fear. My album remains to be unfinished.

21. I am executing this affidavit to attest to the

truth of the foregoing facts and circumstances and
hereby most respectfully request the Investigating
Prosecutor to formally file an INFORMATION against the
Respondent Nicolas S. Hole, Jr. for violation of
Section 3(a)(1)of the Anti-Sexual Harassment Act (RA
No. 7877)and any other crime and/or offense in relation
thereto.
AFFIANT FURTHER SAYETH NAUGHT. 10 JANUARY 2019, Manila
City.

JHEMERLYN I. LUMALABAN
Affiant