Republic of the Philippines) for: Violation of Article 266 of the Revised Penal Code

Quezon City, Metro Manila)

COMPLAINT-AFFIDAVIT

I, Nico Banana, of legal age, Filipino, with assistance of counsel, and resident of 26
Yellow Street, Block 1997 Batasan Hills, Quezon City, do hereby state under oath that:

1. I am executing this Complaint-Affidavit to charge PO1 Kevin Minions, PO3 Stuart

Minions and SPO2 Bob Yellowminion with Republic Act No. 7610, as defined and
penalized under Republic Act No. 7610 (AN ACT PROVIDING FOR STRONGER
DETERRENCE AND SPECIAL PROTECTION AGAINST CHILD ABUSE,
EXPLOITATION AND DISCRIMINATION, AND FOR OTHER PURPOSES).

1.1. PO1 Kevin Minions, PO3 Stuart Minions and SPO2 Bob Yellowminion are
police officers assigned at Station 6 (Batasan Hills)

2. On September August 10, 2019, on or about 8:00 P.M my son while eating some
dirty ice cream is on the way home from a school activity. Upon reaching Yellow
Street, a group of police officer come across with my son namely; PO1 Kevin
Minions (Kevin), PO3 Stuart Minions (Stuart) and SPO2 Bob Yellowminion (Bob).

3. Upon crossing the police officers, my son accidentally bumped his ice cream to
SPO2 Bob. SPO2 Bob was furious about the incident, he angrily shouted bad
words to my son.

4. Not contended, PO3 Stuart together with PO1 Kevin, punch my son that caused
him to lay down on the floor. The police officers punch and kick my son while
telling him bad words like “Ikaw kasi tatanga-tanga ka! Ayan napapala mo. Sa
suusnod tignan mo dinadaanan mo.”

5. Despite the fact that my son is begging not to inflict more injury to him, the
police officer continue to beat my son. My son keeps on telling that “Tama na po,
sorry na po, di ko na po uulitin” but the police officers ignored the plead and
continue what they are doing.

6. While the police officers are doing the crime, a passer-by, namely Jerry
Underwear (Jerry), who is known to be a teacher in their city, talks to the police
officer and asked them to stop what they are doing to the child.

7. The police officers stop and turn their attention to Jerry. SPO2 Bob told Jerry that
“Dapat tinuturuan mo tong batang to! Dapat kamo hindi siya nang-iinis ng mga
pulis kasi ganito ang mangyayari sakanya.” After saying those words, the police
officers leave.

8. Jerry brought my son to the nearest hospital. The attending physician submit a
medico legal report of my child’s injury attached as Annex A. According to the
attending physician, if my son did not get a immediate medical attention he
might have died because of the injury.

9. The aforementioned acts constituted “child abuse”, in violation of Republic Act

No. 7610 (the SPECIAL PROTECTION OF CHILDREN AGAINST ABUSE,
EXPLOITATION AND DISCRIMINATION ACT), particularly the following provision:
 Section 10. Other Acts of Neglect, Abuse, Cruelty or Exploitation and Other
Conditions Prejudicial to the Child’s Development. –

(a) Any person who shall commit any other acts of child abuse, cruelty or
exploitation or to be responsible for other conditions prejudicial the
child’s development including those covered by Article 59 of Presidential
Decree No. 603, as amended, but not covered by the Revised Penal
Code, as amended, shall suffer the penalty of prision mayor in its
minimum period. xxx

in relation to the following provision:

Section 3. Definition of Terms. –

(a) "Children" refers to person below eighteen (18) years of age or those
over but are unable to fully take care of themselves or protect themselves
from abuse, neglect, cruelty, exploitation or discrimination because of a
physical or mental disability or condition;

(b) "Child abuse" refers to the maltreatment, whether habitual or not, of

the child which includes any of the following:

(1) Psychological and physical abuse, neglect, cruelty, sexual abuse

and emotional maltreatment;

(2) Any act by deeds or words which debases, degrades or demeans

the intrinsic worth and dignity of a child as a human being;

(3) Unreasonable deprivation of his basic needs for survival, such as

food and shelter; or

(4) Failure to immediately give medical treatment to an injured child

resulting in serious impairment of his growth and development or in
his permanent incapacity or death.

Nico Banana
Complainant-Affiant

SUBSCRIBED AND SWORN TO BEFORE ME this 21st DAY OF SEPTEMBER 2019

Investigating Prosecutor

CERTIFICATION

I HEREBY CERTIFY THAT I HAVE PERSONALLY EXAMINED THE AFFIANT AND AM

SATISFIED THAT HE VOLUNTARILY EXECUTED AND UNDERSTOOD HIS AFFIDAVIT.

Investigating Prosecutor