ANCHETA, ARTHUR F. PROF.

BILLY GABAYNO

BS CRIM E2018 CDI 8

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
TAGUIG CITY

Victoria E. Flores
Complainant
vs. I.S. No. ____________
For: Rape
Tequiero A. Santos
Respondent.

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COMPLAINT-AFFIDAVIT

I, VICTORIA E. FLORES, Filipino, Minor, and with residence at

No. 69 De Enero Road, Brgy. Central Signal Village, Taguig City,

Metro Manila., after having been duly sworn in accordance with law,

hereby depose and state that:

(1)This complaint-affidavit is being filed to charge Tequiero A. Santos

a.k.a “Boy I Love You”, Filipino, of legal age, and with residence at

No. 50 Cardones Road, Brgy. North Signal Village, Taguig City,

Metro Manila, of the crime of Rape under Article (Art.) 266 of the

Revised Penal Code (RPC), committed as follows:

(a)On August 21, 2019, at around 11:00 in the Evening, I was 17

years of age, was wearing a jacket and denim pants and

walking towards my house when Tequiero A. Santos, came by

and pulled me into a dark abandoned lot.

 (b)I screamed for help but Tequiero continued to hurt me and

started to kiss me on my lips and neck. He then pulled out his

genital organ and removed my denim pants and underwear.

(c) While I was pinned down on my back, crying helplessly,

Tequiero then inserted his genital into my genital and started to

rape me.

(d)After satisfying his lustful desires, Tequiero then said “di ka na

makakaalis dito ng buhay” and then started to put his hands

around my neck and strangle me until I passed out.

(e)Tequiero A. Santos then left, thinking I was already dead.

(2)Until now I am extremely traumatized by the said event and could

not walk outside my home for fear of being raped again.

(3)Appalled by what happened, my mother, Salvacion E. Flores, and I

went to the police station to report the crime committed by

Tequiero against my person. The police took my sworn statement,

a copy of which is hereto attached and made an integral part

hereof as Annex “A”. Thereafter, I was examined by their medico-

legal officer. A copy of the Medico-Legal Report is likewise hereto

attached and made an integral part hereof as Annex “B”.

(4)The elements of rape are carnal knowledge, force or intimidation,

and the commission of the act without the consent or against the

will of the woman, or when the latter is under twelve (12) years of

age or when she is deprived of reason or other wise unconscious.

(5)Based on the definition and elements of rape, it is beyond

reasonable doubt that respondent Tequiero A. Santos committed

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 the crime of rape punishable under Art. 266 of the RPC. He had

sexual intercourse with me by forcing himself unto me. This

constitutes rape as defined in our laws.

AFFIANT FURTHER SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto set my hand this

31st day of August 2019, in Taguig City.

Victoria E. Flores
Complainant/Affiant

SUBSCRIBED AND SWORN TO before me, this 31st day of

August 2019 in Taguig City.

Prosecutor

This is to certify that I have personally examined the herein

affiant and that I am satisfied that she voluntarily executed and

understood her statements herein.

Pros. Arthur F. Ancheta