Republic of the Philippines

Professional Regulations Commission

ESMERALDA G. TOMBAGA,
Complainant Case No. ________________
-versus-

Glen Cawaywayan,
Respondent

AFFIDAVIT-COMPLAINT

I, ESMERALDA G. TOMBAGA, of legal age, married, with residence at

Blk 27 Gordon Heights, Olongapo City, solemnly swear the following
statements:

1. That the complainant, ESMERALDA TOMBAGA, is married, 56

years old, a Master Teacher in Gordon Heights I Elementary School,
and a resident of Blk 27 Ext. Gordon Heights, Olongapo City;

2. That the Respondent GLEN CAWAYWAYAN, is a medical doctor in

James L. Gordon Memorial Hospital, where he may be served with
summons and other court processes;

3. That on October 27, 2019 at 11:00 AM in order to aid the Police

Officers in finalizing their Police Report, the complainant Mrs.
Tombaga accompanied her son John Mark Tombaga, along with
Judith Singapan and Jonas Singapan, minor, to the James L. Gordon
Memorial Hospital for Medico Legal Examination. They were
accompanied by Police Officer Ryan Garcia of Station 3/ Station B of
the Olongapo City Police Office;

4. The parties to the incident giving rise to the need of a Medico Legal
certificate have already made peace with each other and all of them
are no longer interested in pursuing a cause of action against each
other;

5. But on October 27, 2019 on or about 11:00 AM, the respondent

GLEN CAWAYWAYAN, while servicing the complainant and her
company, with ill intent, malice and severe animosity, acting over and
beyond his duty as a medico-legal officer, meddled with the issues of
the incident, shouted and pointed a finger at the Complainant saying
“Ikaw, titser ka pa naman, hindi mo alam ang ginagawa mo.
Pangaralan mo yang anak mo. Tingnan mo ang ginawa nyang
pananakit sa kawawang bata.”
 6. When the Police Officer Ryan Garcia Interjected the word
“allegedly”, the respondent grabbed the arms of the two minor
children, Jonas Singapan and John Mark Tombaga, and dragged them
to another room.

7. The complainant being a concerned parent, followed and asked if she

can participate in the discussion;

8. Without any warning, the respondent slammed the door on the face of
the complainant leaving her humiliated in front of many witnesses;

9. This affirmed that the respondent CAWAYWAYAN bore ill motive

and animosity in uttering insulting words to the complainant;

10.Immediately, upon advice of her counsel, she reported the incident to

the nearest Police Station, and also filed a Barangay Report to be
entered in the Barangay Log Book.

11.Copy of the said reports is attached as Annex A and B respectively.

12.That due to the incident, the complainant Esmeralda Tombaga

suffered sleepless nights, anxiety, besmirched reputation as a Master
Teacher, and loss of appetite.

13.That the Complainant Esmeralda Tombaga spent a total of 25, 000

pesos in Atty’s Fees.

IN WITNESS WHEREOF, I have hereunto affixed my signature

th
this 5 day of November 2019 in the City of Olongapo, Philippines.

ESMERALDA TOMBAGA
Affiant
ID No. ______________

SUBSCRIBED AND SWORN TO BEFORE ME, this 5th day of

November 2019, in the City of Olongapo, Philippines. This is to certify that
I have personally examined herein affiant and that I am convinced that she
freely and voluntarily executed the foregoing and has read and understood
the contents of the same.

ADMINISTERING OFFICER