ZAPANTA, IVAN EARL B.

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE

OFFICE OF THE PROSECUTOR

MANILA

THE PEOPLE OF THE PHILIPPINES,

Complainant,

-versus-

Gregorio N. Pilay

Accused.

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

CRIMINAL COMPLAINT AFFIDAVIT

I, Mary Ann B. Roxas, the undersigned, of legal age, and a resident of

#25 Sisa Street, Sampaloc Manila, accuses Gregorio N. Pilay of the
violation of RA 11479 otherwise known as The Anti-Terrorism Act of
2020 as follows:

1. At around 11:30PM of Saturday, July 21, 2020, I, Mary Ann

Roxas was browsing Facebook, when I saw the post of Gregorio
Pilay.

2. The post of Pilay states that “Bukas, sa kaarawan ni Mayor Joric

Gacula, atin pong sunugin ang Munisipyo sa oras na 1 ng hapon!
Hindi na tayo dapat nakikinig sa pinagsasasabi ng gungong na
yan!”
ZAPANTA, IVAN EARL B.

3. That because my sister works for the mayor, I feared for her life
and the lives of other people working there.

4. Later, I went to the Police station located near the old municipal
hall. I reported the post of Pilay to the authorities.

5. That I spoke to PO1 Mendel Reyes and showed him the

screenshot of the post and the post itself. The screenshot is
attached as Annex A.

6. My complaint was logged in the police blotter as Report No.

8945. A copy of the report is herein attached as Annex B.

7. That on the morning of July 22, 2020, Maritess Nunez, a

neighbor of Pilay, saw the latter carrying a two gallon jugs. She
mentioned that Pilay smelled of gasoline. Images of the gallon
jugs that were confiscated are attached as Annex C.

8. Another witness, Marko Gener, a staff at Petron Taytay, was the

one who assisted Pilay in filling up the gallon jugs with gasoline.

9. That on 12 noon of July 22, 2020, police officers raided the home
of Pilay and confiscated the gasoline, together with a bolo.

10. That all these stated herein are true and were stated freely
without any force or intimidation done against me.

11. To attest to the truthfulness of the foregoing, I, Mary Ann

Roxas, complainat, attaches my signature below.

_________________________

Mary Ann B. Roxas

Complainant
ZAPANTA, IVAN EARL B.

SUBSCRIBED AND SWORN to before me, in the municipality of

Taytay, this 22nd day of August 2020, the affiant exhibiting to me her
Passport issued by Department of Foreign Affairs Manila on 15th of
April 2017 at Roxas Blvd, Manila.

___________________________

Antonina J. Apacionado
Assistant City Prosecutor
ZAPANTA, IVAN EARL B.

ANNEX A:
ZAPANTA, IVAN EARL B.

Annex B:
ZAPANTA, IVAN EARL B.

Annex C:
Sample of Affidavit of Witness

Republic of the Philippines )

____________, ________ ) s.s.
x- - - - - - - - - - - - - - - - - - - - - -x

AFFIDAVIT OF WITNESS

I, MARITESS NUNEZ, 39 years old, married, resident of 50

Leon Ginto Street, Brgy. San Hulyo, Taytay, Rizal, after having sworn in accordance with
law, do hereby depose and state THAT:

01. I was present and personally saw that accused, Gregorio Pilay, carrying two
1-gallon jugs of gasoline in his property;

2. That as the next door neighbor of Pilay, I smelled gasoline coming from
his property.

3. That I saw Pilay was acting strangely and has a bolo with his person.

I executed this affidavit to attest the truthfulness of the foregoing facts and to support the
filing of Criminal Cases against GREGORIO PILAY for violations of THE ANTI-
TERRORISM ACT OF 2020.

AFFIANTS SAYETH NAUGHT.

IN WITNESS WHEREOF, I hereunto affixed my signature this 24TH day of AUGUST at

TAYTAY, RIZAL.

MARITESS NUNEZ
Affiant

SUBSCRIBED AND SWORN to before me this 22nd day of August at

Taytay, Rizal. I HEREBY CERTIFY that I have personally examined the herein affiants and
I am satisfied that they voluntarily executed and understood their given affidavit.

______Gener Gozum________
Notary Public
Sample of Affidavit of Witness

Republic of the Philippines )

____________, ________ ) s.s.
x- - - - - - - - - - - - - - - - - - - - - -x

AFFIDAVIT OF WITNESS

I, MARKO GENER, 19 years old, married, resident of 19 Leon

Ginto Street, Brgy. San Hulyo, Taytay, Rizal, after having sworn in accordance with law, do
hereby depose and state THAT:

01. I was present and personally saw that accused, Gregorio Pilay, buy two 1-
gallon jugs of gasoline from our store, Petron Taytay;

2. That as the attending staff of Petron Taytay, I was the one who personally
assisted Pilay in filling up his jugs with gasoline.

3. That I saw Pilay was acting strangely and has a bolo with his person.

I executed this affidavit to attest the truthfulness of the foregoing facts and to support the
filing of Criminal Cases against GREGORIO PILAY for violations of THE ANTI-
TERRORISM ACT OF 2020.

AFFIANTS SAYETH NAUGHT.

IN WITNESS WHEREOF, I hereunto affixed my signature this 24TH day of AUGUST at

TAYTAY, RIZAL.

MARKO GENER
Affiant

SUBSCRIBED AND SWORN to before me this 22nd day of August at

Taytay, Rizal. I HEREBY CERTIFY that I have personally examined the herein affiants and
I am satisfied that they voluntarily executed and understood their given affidavit.

______Gener Gozum________
Notary Public