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CASE:
MURDER
GROUP: UWWU
Lynard Aquino
Lester Alvarez
Chyna Klein de Guzman
Jaressa Abitan
Mark Aldous Langeg
John Bryan Abaya
Ryan Rodas
Republic of the Philippines
Regional Trial Court
Branch 10
CORDILLERA ADMINISTRATIVE REGION
PEOPLE OF THE PHILIPPINES,
Plaintiff, CRIM. CASE NO. 12345-01
-versus- FOR:
MURDER
Michael Lebron,
Accused,
x--------------------x
JUDICIAL AFFIDAVIT
This Judicial Affidavit of Michael L. Lebron, the Petitioner, is executed to serve as her
direct testimony in the instant case.
This Judicial Affidavit is being offered to prove:
A) All the allegations in the Petition including all annexes appended thereto and which
were already marked as exhibits during the Pre-Trial of this case;
B) All other related matters, facts and circumstances relevant and material to this case.
IN WITNESS WHEREOF, I have hereunto affixed my signature, this 8th day of August
year
2021 at Baguio City, Philippines.
Michael L. Lebron
Affiant
Republic of the Philippines)
City of Baguio )
x------------------------------------x
COMPLAINT-AFFIDAVIT
That WE, NORITA ABAYA & LINDA ALVAREZ, 52 years of age both, US citizen
and a resident of Barangay Bulag, Baguio City, Philippines, after having duly sworn to in
accordance with law, I hereby depose and say, THAT:
1. That We are voluntarily making this Affidavit Complaint for the purpose of
formally filing a murder case or violation of Article 248, paragraph 1 (b);
paragraph 2 (a) of the Revised Penal Code of the Philippines or any appropriate
case against JOHN BRYAN ABAYA and LESTER ALVAREZ, likewise of legal
age, Filipino and presently employed as the both baggers in a shopping mall at
Baguio City;
b. As time passes by, the three enjoyed chatting about things then
suddenly, Michael told the three how beautiful their girl co-worker is
and he has a huge crush on her. Michael was also aware that Lester
and John also have their eyes on the same lady. The three boasted
about how the interact with the same woman;
c. As the evening went old, the good chats became an argument, the
two-man decided to walk away because Michael was already shouting
and hitting the table hard still saying the lady’s name. While both of
them is walking away unaware that Michael silently followed them,
Michael suddenly hit them both in the head using the glass bottle of
beer. Both of them went down, that was the time Michael used the
broken glass bottle and stabbed them brutally till their last breath.”
SUBSCRIBED AND SWORN to before me this 23rd of October, 2021 in Baguio City,
Philippines. I certify that the complainant
read and understood the contents of
their Affidavit Complaint and that she
voluntarily executed the same.
Republic of the Philippines
Regional Trial Court
Branch 10
CORDILLERA ADMINISTRATIVE REGION
PEOPLE OF THE PHILIPPINES,
Plaintiff, CRIM. CASE NO. 12345-01
-versus- FOR:
MURDER
PITONG PEDRO,
Accused,
x--------------------x
DEPOSITION OF WITNESSES
We, Kobe Irving and Kyle Bryant after having been duly sworn to testifies, as
follow:
Q. How did you know that Michael L. Lebron was the one who really kill
Lester Alvarez and John Bryan
A- We saw it in our two eyes and we see the whole crime
Judge
Republic of the Philippines )
Province of Baguio City ,
) s.s. x---------------------------------x
We, PO1 JARESSA ABITAN and PO1 CHYNA DE GUZMAN, both members
of the Philippine National Police, presently assigned at the Baguio Police Station,
after having been duly sworn to in accordance with law, do hereby depose and state
THAT:
1. We are among the members of the Regional Operation Division of Baguio Police
Station who conducted arrest at Di Makita Street. Barangay Bulag, Baguio City;
3. Upon receipt of their said complaint, our office planned out an Entrapment
operation against the suspect. At about 3:30 in the midnight of 8th of August 2021
4. Upon arrival thereat, complainants waited for the suspect to arrive while we
the undersigned seated near the table of the complainants. At about 5:00 in the
morning suspect arrived and approached the complainants
5. Suspect together with the seized and recovered evidence was brought to the
Regional Operation Division of Baguio Police Station for booking and proper
disposition. Likewise, the arrested person was apprised of their rights as provided
for under the Constitution of the Philippines.
6. The report of the PNP Crime Laboratory Group Physical Identification Report No.
1234 dated August 9 2021, revealed that suspect Michael L. Lebron
was POSITIVE for the killing of Lester Alvarez and John Bryan Abaya resulting to
murder
We executed this joint affidavit to attest the truthfulness of the foregoing facts and
to support the filing of Criminal Cases against MICHAEL L. LEBRON for violations of
Republic Act No. 7659 .
Administering Officer
Republic of the Philippines
REGIONAL TRIAL COURT
Branch 10
Cordillera Administrative Region
COMES NOW, the undersigned Deputy Chief of the Investigation Branch of Baguio
Police Office, located in Baguio City, unto this Honorable Court most respectfully avers:
That the undersigned applied for issuance of search warrant in this Honorable
Court and not in any court in Barangay Bokawkan, Baguio City – where the said the offender
committed murder, bodies were found and witness were relative to his work.
That I was informed that MICHAEL LEBRON, Filipino, of legal age, married to
SUSANA LEBRON and one of the salesboy in SM Baguio is keeping in his residence located
Di Makita Street. Barangay Bulag, Baguio City, the following: committed a crime of MURDER
which act violates RA 7659;
That the undersigned caused the investigation and verification of the report.
Witnesses Police Officers; Police Patrolman Jaressa Abitan and Police Patrolman Chyna De
Guzman, who were able to gain entry in the residence of the respondent confirmed to me that the
report is absolutely true;
That based on the report of above-named witnesses, respondent is keeping in the attic and in the
room of his house, which house is actually located at #21, Di Makita Street.
Barangay Bulag, Baguio City First Street, Brgy. Bokawkan, Baguio City
WHEREFORE, the undersigned most respectfully prays that this Honorable Court issue a search
warrant against the respondent authorizing the undersigned or any police officer to search the
premises described in paragraph 4; and, to seize and bring to this Court the things or properties
enumerated in the same paragraph.
08 AUGUST 2021
Date
JAMES DURANT
Police Senior Inspector
Republic of the Philippines
OFFICE OF THE CITY PROSECUTOR
Manila
COMPLAINANT/S: RESPONDENT/S
1. Police Patrolman Jaressa Abitan 1. Michael L. Lebron
Address: Artek st. Baguio City Address: Di Makita Street. Barangay Bulag,
Baguio City,
2. Police Patrolman Chyna De Guzman .
Address: Hangover st. Baguio City
CHARGE:
MURDER
Place of Commission:
Di Makita Street. Barangay Bulag,
Baguio City
NOTE: 1. has a similar complaint been filed before any other office? NO (YES OR NO)
2. Is this complaint in the manner of a counter-affidavit? NO_ (YES OR NO)
3. Are all the above information true and correct YES (YES OR NO)
IMPORTANT!
A complainant shall be required to file his complaint in the form of an affidavit to
which must be appended affidavit of witnesses, annexes and other supporting
documents. The statements of the complainant and his witnesses, shall be, far as
practicable, be sworn to before the investigating Prosecutor. If sworn before any Officer
authorized to administer oaths, the administering Officer shall CERTIFY THAT HE HAS
PERSONALLY EXAMINED THE AFFIANT AND THAT HE VOLUNTARILY EXECUTED
AND UNDERSTOOD HIS AFFIDAVIT.
____________________________
Stenographer
Republic of the Philippines
REGIONAL TRIAL COURT
Branch 10
Cordillera Administrative Region
COMES NOW the complainant by the undersigned attorney and within the
reglementary period prescribed by the Rules of Court hereby files this motion for
reconsideration from the judgement of rendered by 13 th Day of September by virtue of
newly found evidence which was not obtained during the trial of this case and if produce
will substantially affect the decision of the Honorable Court, to wit:
PRAYER
PAULO COELHIO
(Counsel for the Accused)
EXPLANATION
(Proof of Service)
NOTICE OF APPEAL
COMES NOW the complain by the undersigned attorney and within the
reglementary period prescribed by the Rules of Court hereby files this notice of appeal
from the judgement of dismissal rendered by 17 th Day of December
PAULO COELHIO
(Counsel for the Accused)