Republic of the Philippines

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
Office of the City Prosecutor
Justice Hall, Santiago City

PEOPLE OF THE PHILIPPINES,

Plaintiff, CRIMINAL CASE NO. 14344
-versus-
For: RAPE
HOMAR ALEXIUS C. DE GUZMAN,
Accused.
x------------------------------------------------x

COMPLAINT-AFFIDAVIT
I, MARICON I. LAGAYAN, 22 years old, single, and a
resident of Purok 69, Centro East, Santiago City, after having
been duly sworn to in accordance with law, hereby deposes
and says:
1. That on 18th day of August 2019, at about 10:00
o’clock in the evening, after watching the Gandang
Lola at Centro East Barangay Hall, me and my
girlfriend Nikky decided to go home. When we
parted ways and I reached our residence., I noticed
that our domestic helper Homar Aexius C. De
Guzman(accused) is inside my room, I felt nervous,
and asked him what is he doing inside my room,
Homar said “keep quite or I will kill you”, while
holding a gun and pointing at me, he then pushed
me in the bed, I try to fought back but he choked
me and said that he will kill me if I will scream for
help;

2. That, while pointing the gun at me and threaten to

kill me, he told me to remove my shorts and panty.
Then he started kissing me all over my body and told
me to lie down. He lowered her pants showing her
erected penis. Suddenly, he punched my stomach
that made me weak. He parted my thighs, and
inserted his penis into my vagina, and made push
and pull movements and I felt the intense pain and
cried;

1
 3. After satisfying his lust later he told me to get
dressed, after putting back my shorts and panty, I
managed to escape by kicking him in his stomach
and immediately I run outside and screamed for
help and fortunately I saw two Police Officers
patrolling the area which led to the immediate arrest
of Homar;

4. One of the Police Officer accompanied me to

Santiago Medical City for medical examination Dr.
Dinicio ganer then issued a Medico-Legal Report,
which showed that "physical findings of genital area
are definitive for recent penetrating injury "Annex A”;

5. While at the hospital, Police Captain Felomino Julius

M. Florentin request for my testomonies with regard
to the incident and attached it as an integral part
hereof as Annex “B” of the complaint;

6. I am therefore executing this affidavit freely and

voluntarily in support of my intent to file a case for
RAPE against Homar Guzman, who is 22 years of age
and a resident of Purok 69, Centro East, Santiago
City.

IN WITNESS WHEREOF, I have hereunto set my hand this

19th day of August 2019 at Santiago City, Philippines.

MARICON I. LAGAYAN
Affiant

SUBSCRIBED AND SWORN to before this 19th day of August

2019 at Santiago City, Philippines and I FURTHER CERTIFY that I
have personally examined the affiant and I am satisfied that
he/she has read and personally understood the contents of her
foregoing “Complaint-Affidavit”.

JIMMY I. PERU
Asst. City Prosecutor
MCLE Compliance No. 111
Valid Until December 31, 2020