Republic of the Philippines)

City of Davao . . . . . . . . .)s.s.

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COMPLAINT-AFFIDAVIT

I, MARIBEL MAYOR LANDERO, of legal age, Filipino

and a resident of Purok 8, Brgy. Tacunan, Davao City, after
having been duly sworn to in accordance with law do hereby
depose and state, that:

1. I am the same person who is the complainant in the

instant case;

2. I know the person of JESREL ELEMPROS LANDERO

(Respondent), being my husband and who is currently
residing at Purok 8, Brgy. Tacunan, Davao City where he
may be served with Office Summons, notices and
process;

3. Out of our lawful marriage, we begot two (2) children

namely, Nicole Landero, 6 years old and Donabel Landero,
5 years old;

4. In the beginning of our marriage, we lived harmoniously

as husband and wife and parents to our children until
later part particularly last year that my husband, JESREL
displayed irrational behavior not expected from a mature
and a responsible husband and father to our children.
Particularly I caught him last year of having an affair with
someone else;

5. I was hurt, however, for the sake of our children, I

forgave him and patched things up not until last April
2020 that he showed again his unfaithfulness and
irrational behavior towards me and my children;

6. I have no choice but to leave our family home together

with my children because I could no longer tolerate his
verbal, sexual and psychological abuse towards me;

7. After I left our conjugal home, my husband dared and

publicly humiliated me through social media, posting
inappropriate comments and maligning my good
reputation in connection with my business using his
account named Tata Pay. He even hacked my facebook
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 account and threw verbal, emotional and psychological
abuses just to demean my name using my personal
facebook account posting to publicly shame me and my
family; Attached herewith are copies of print out from
facebook posts and other evidences as ANNEXES “A” to
“A-11”

8. Not until I have been hearing rumors that my husband

has been romantically engaged and cohabiting with
another woman as many people would call and text me
that they saw my husband with another woman inside our
car. He even acknowledged this and belied by posting
publicly on his social media that it was either his sister or
his niece that was with him; Attached herewith is a copy
of the facebook posts using another account Concepcion
Yap and later using the complainants Account Maribel
Mayor as ANNEX “B”

9. This act of unfaithfulness which was our problem before

caused substantial and emotional distress to me and to
our children which is in violation of Section 5 of R.A.
9262;

10. Moreover, me and my children continuously suffering

mental and emotional anguish, public ridicule and
humiliation because of his blatant display of arrogance by
showing off to the public that he has an affair with
another woman and the denial of financial support to our
children which is a clear violation of Section 5 of R.A.
9262;

11. Not until last June 5, 2020, I was very angry at him
because he again hacked my account and publicly
humiliated me through social media. I went to our house
and confronted him personally and asking him to give me
the keys and turn-over the car since I am the one paying
for it;

12. Due to my frustration and emotional distress he has

caused me for the past months, I smashed the windshield
of the car because he will not return and give the car to
me. Out of his anger and frustration, he immediately
mauled me pushing me to the car, hitting the broken
glasses of the windshield and pound me to the ground
causing injuries to my hands; Attached herewith is a copy
of my medical certificate as ANNEXES “C” to “C-3”
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 13. As evidenced also to the mauling and physical abuse,
attached herewith is the affidavit of Katherine Cayonite
who also witnessed my husband’s threat to kill me and
my entire family as ANNEX D;

14. I, immediately went to the Police Station to blotter the

incident. I proceeded to go to the Barangay Tacunan to
file for Barangay Protection Order which was granted
because of his death threats; Attached herewith are
copies of the Blotter and Barangay Protection Order as
ANNEXES “E” to “E-6”

15. Because of the criminal acts of gross misbehavior,

immorality, emotional, physical, psychological and
financial abuses, my husband deserves to suffer from
consequences of his actions and be served to justice for
the sake of my children;

16. That this criminal complaint is without prejudice of

filing a separate criminal complaint which deemed fit for
actions he committed against me and my children;

17. I am executing this Affidavit to attest to the

truthfulness of the foregoing facts, to inform the proper
authorities and in order to file such criminal charge which
is deemed fit against my husband, JESREL ELEMPROS
LANDERO, of Purok 8-A Brgy. Tacunan, Davao City, for
Grave Threats and Physical Injuries as defined an
penalized under the Revised Penal Code of the Philippines
in relation to R.A. No. R.A. 9262;

IN WITNESS WHEREOF, I have hereunto set my hand this

___ at Davao City, Philippines.

MARIBEL MAYOR LANDERO

Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, this

________ at Davao City, Philippines. I hereby certify that I have
personally examined the above-named affiant and I am satisfied
that he voluntarily executed the foregoing affidavit, the contents
of which he fully understood.

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