Republic of the Philippines)

City of Baguio-----------------) S.S.

-----------------------------------x

AFFIDAVIT-COMPLAINT

I, WILLIAM L. TODCOR, of legal age, Filipino and with address at 0138 Purok
2, Dontogan, Baguio City, after having been duly sworn to an oath in accordance
with law, hereby depose and state:

1. That on November 27, 2016 while I was trying to inspect how we could pass
the pathway that was fenced by the workers of Jabeh Areola and Lydia
Areola at about 7 o’clock a.m. since we were practically imprisoned by the
high cement walls they built on our frontage and gate, I saw Marvin Albano
entering our fenced premise that we repaired four times after they
destroyed our fence on November 14 for the first time, then destroyed it
again on November 19 for the second time, again on the 24thof November
for the third time, then for the fourth time on the morning of November 27.
There was a confrontation and I told him there is a Cease and Desist Order
and that a Demolition Order is now being readied for approval. Marvin
Albano countered that Jabeeh and Lydia Areola ordered them to do
everything to prevent me from opposing them because Areola owned the
lot and we encroached on their property. At that instance, without any
provocation Marvin Albano suddenly pick up a stone to hit me but I ran
towards my house for safety,his companions immediately came to aid
Albano holding broken cement blocks to throw at me. I grabbed my camera
to take a photo of the culprits, one of them hit me with his slingshot but
luckily it missed (Exhibit 1 Photo of Albano reading the document, Exhibit
2 photo of Jabeeh and Lydia Areola’s worker with slingshot);

2. That JabehAreola and Lydia Areola who are directly responsible for all the
acts of the workers could never claim that they are acting legally when it
was ruled by competent authorities that their fence was illegal and it was
demolished last November 28, 2016 by the City Government. (Exhibit 3
Cease and Desist Order , Exhibit 4Demolition Order).

3. That I believe all the actions of the workers were dictated by Jabeh and
Lydia Areola acting in conspiracy causing damage to our property and
threats to our safety as indicated by photos and documents herein
presented. They are no ordinary workers but paid goons. (Exhibit 5 photo
of Jabeh Areola directing his workers during our confrontation, Exhibit 6
another photo of Jabeh Areola intervening during the demolition of his
illegal fence, Exhibit 7 and 7A barangay document where Jabeh Areola
acted as the complainant when the mother could not appear in the
barangay hearings);
 4. That the incident was witnessed by Nardo Pitas who came up to see what is
happening because he heard our altercations and shouting; The events
were witnessed also by my wife Olivia T Todcor.

5. That I reported what happened to the Police Station 10. (Exhibit 8 blotter
report);

6. That the complaint of Grave Threatsand Damage to Property was reported

to the barangay.(Exhibit 9 Certification to File Action);

7. That Jabeh Areola, Lydia Areola and their workers have no right whatsoever
to fence our property or to cause destruction thereat because the portion
that they encroached is part of our titled property. (Exhibit 10 Titled lot of
Sps. William L. Todcor and Olivia T. Todcor TSL No. 90785).

IN WITNESS WHEREOF, I have hereunto affixed my signature this ____ day

of February 2017 at Baguio City, Philippines.

WILLIAM L. TODCOR
Affiant

Subscribed and sworn to before me this ____ day of February 2017 Baguio
City, Philippines. I further certify that I had personally examined the affiant and I
am satisfied that he knowingly and voluntarily executed the same and that he had
read and understood the contents thereof.

____________________
Administering Officer