Republic of the Philippines

National Prosecution Service

Department of Justice
OFFICE OF THE PROVINCIAL PROSECUTOR
Alabel, Sarangani Province
-oooOooo-

HECTOR G. SALMON NPS DOC. NO. __________________

Complainant,

-versus- -for-

JOEL ARAGANCILLO ,
JEFFREY LAGEGO alias Pit Pit QUALIFIED THEFT
INDAY ARAGONCILLO LAREGO
ESTONG MAKARUNGALA and his wife
JAN JAN MAKARUNGALA
MATEAS MAKARUNGALA
GAGAL MAKARUNGALA
Alias FLOR and JOHN DOES
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HECTOR G. SALMON NPS DOC. NO. __________________

Complainant,

-versus- -for-

JOEL ARAGANCILLO ,
JEFFREY LAGEGO alias Pit Pit GRAVE THREATS
INDAY ARAGONCILLO LAREGO
ESTONG MAKARUNGALA and his wife
JAN JAN MAKARUNGALA
MATEAS MAKARUNGALA
GAGAL MAKARUNGALA
Alias FLOR and JOHN DOES
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COMPLAINT AFFIDAVIT

I, HECTOR G. SALMON, Filipino, of legal age, single, resident and with

postal address at FELICIANO DELOS SANTOS Compound, Brgy. Pangyan,
Glan, Sarangani Province after having been duly sworn to in accordance with
law depose and say.

. 1. That I am one of the heirs of the late ALFREDO M. SALMON, the

owner, and possessor of a certain parcel of land situated at Sitio Tikang, Brgy.
Big Margus, Glan Sarangani Province as evidenced by Tax Declaration No. 02-
0005-00525 containing an area of FIFTY (50) HECTARES, more or less fully
planted with coconuts. Hereto attached is the machine copy of the Tax
Declaration No. 02-0005-00525 as Annex “A”;
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 2. That the said property was acquired by our late father ALFREDO M.
SALMON from the late WILLIAM YOUNG on February 15, 1965 by virtue of the
DEED OF TRANSFER OF RIGHT AND INTEREST OF A PARCEL OF LAND
WITH IMPROVEMENTS duly entered in the Notarial Registry of ANTONIO
DOCTOLERO, Notary Public for the Municipality of Glan, Cotabato, now
Sarangani Province per Doc. No. 1766, Book No, VII, Page 32, Series of 1965.
Hereto attached is the machine copy of DEED OF TRANSFER OF RIGHT AND
INTERESTS OF A PARCEL OF LAND WITH IMPROVEMENTS as Annex “B”;
3. That the aforesaid property was formerly claimed by JUSTINA M.
ARAGONCILLO but as early as February 11, 1963, she already executed a
QUITCLAIMED DEED with the conformity of her husband ISAIAS
ARAGONCILLO in favor to REV. WILLIAM YOUNG before ATTY. ALREDO D.
BARCELONA, Notary Public of Glan, Cotabato, now Sarangani Province
entered in his Notarial Registry as Doc. No. 22; Page No. 7; Book No. 3; Series
1963. Hereto attached is the machine copy of the QUITCLAIM DEED as Annex
“C” and “C-1”;
4. Thus, WILLIAM YOUNG, the former owner sold the said property to my
father ALFREDO M. SALMON by virtue of the said document and the said
document was annotated in the Old Tax Declaration No. 6365 of MR. WILLIAM
YOUNG. Hereto attached is the machine copy of the Tax Declaration No. 6365
as Annex “D”;
5. That since 1965 up to the present or for FIFTY TWO (52) long years, we
are in the peaceful possession of the property enjoying the fruits of the coconuts
planted thereon and religious paying our real estate taxes over the said property.
Hereto attached is the machine copy of OFFICIAL RECEIPTS issued by
Provincial and Municipal Treasurers indicating the real property taxes paid
from 1965 until April 2007 as Annexes “E” and series;
6. That our parents were already both deceased so on November 10, 2010
we executed an Extrajudicial-Settlement of the Estate of the Late Spouses
ALFREDO M. SALMON and ADELINA GITAN before ATTY. EDSEL S. DERIS-
LIM, Notary Public for General Santos City entered in her Notarial Registry as
Doc. No. 212; Page No. 43; Book No. XXIII; Series of 2010. Hereto attached is
the machine copy of the Extrajudicial Settlement as Annex “F”;
7. That during the lifetime of my father, our late land administrator, REV.
REINHART B. MAKARUNGGALA, an Evangelical Church Pastor and an
Indonesian National was the one who managed in the regular harvest of our
coconuts and remitted the proceeds of the harvest to my father ALFREDO
SALMON;
8. There was a time when our land administrator was not able to remit the
income of the copra to my father, my father received a letter dated May 30, 1995
informing my father that he used the money. Hereto attached is the machine
copy of the letter as Annex “G”;
9. That on March 20, 1997, our late administrator sent a handwritten letter
remitting the income of our said property. Hereto attached is the machine copy of
the hand written letter as Annex “H”;
10. That on November 11, 2010, we designated OLIPIO S. LIM, JR. as our
ADMINISTATOR over the said property through a JOINT SPECIAL POWER OF
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ATTORNEY and the said document was notarized before ATTY. MINVELLES
BELONCIO-GULLE per Doc. No. 93; Page No. 19; Book No. 72; Series of 2010.
Hereto attached is the machine copy of the Joint Special Power of Attorney as
Annex “I”;
11. That on May 22, 2017, we were surprised because our land
administrator OLIPIO S. LIM JR. informed us that he personally reported to the
Police Station that a group of persons namely, JEFFREY LAREGO popularly
known as PET-PET together with his wife INDAY ARAGONCILLO LAREGO,
JOEL ARAGONCILLO and JAN JAN MAKARUNGALA harvested the matured
coconuts inside our coconut plantation at Sitio Tikang, Brgy. Big Margus, Glan,
Sarangani Province on May 18, 2017 at around 8:00 o’clock in the morning and
processed the said ripe nuts come up with six and half (6 ½) sacks of copra and
sold at P40.00 per kilo in the total gross amount of Php13,000.00 without any
authority and consent from the land owners. Hereto attached is the copy of the
INCIDENT RECORD FORM issued by the Philippine National Police of Glan,
Sarangani Province as Annexes “J”;
12. That another incident happened on June 26, 2017 at around P10:00
o’clock in the morning, a group of persons namely JEFFREY LAREGO alias
“PETPET”, JOEL ARAGONCILLO, ESTONG MAKARUNGGALA and his wife
harvested again our coconuts and processed into copra and sold in the
estimated amount of P20,000.00 worth of the ten (10) sacks of copra. Hereto
attached is the copy of INCIDENT RECORD FORM recorded in the Municipal
Police Station of Glan, Sarangani Province as Annexes “K”;
13. That not contented of their unlawful acts, just recently on August 16,
2017 at around 3:00 o’clock in the afternoon, our land administrator OLIPIO S.
LIM, JR. went to our coconut plantation and he personally saw and identified a
group of persons headed by JOEL ARAGONCILLO, ESTONG
MAKARUNGALA together with his wife, MATEAS MAKARUNGALA, GAGAL
MAKARUNGALA, and a certain FLOR, and others not identified conspiring and
confederating with one another with intent to gain did then and there and
unlawfully, deliberately took harvested and gathered coconut fruits inside our
coconut plantation and processed the same into copra in the total estimated
amount of SIXTY (60) sacks at an average of 50 kilos per sack and sold at
P40.00 per kilo with the gross amount of ONE HUNDRED TWENTY
THOUSAND PESOS (P120,000.00) and said incident was immediately reported
by our land administrator to the Office of the Philippine National Police, Glan,
Sarangani Province on August 17, 2017 at 4:00 o’clock in the afternoon. Hereto
attached is the copy of the INCIDENT RECORD FORM as Annex “L”;
14. That our land administrator OLIPIO S. LIM, JR. personally took
pictures of the coconuts stolen by the said persons JOEL ARAGONCILLO,
ESTONG MAKARUNGGALA and his wife, MATEAS MAKARUNGGALA,
GACAL MAKARUNGALA, and a certain FLOR and other unidentified persons.
Hereto attached is the copy of the pictures taken inside our coconut plantation as
Annexes “I” and series;
15. That when our land administrator OLIPIO S. LIM, JR. asked them why
did they harvest the coconuts, JOEL ARAGONCILLO while holding a piece of
round wood bravely answered and threatened him in a vernacular saying that
“AYAW GYUD ME KUHAI UG PICTURES KAY BASI MAHITABO TA. (DO
NOT TAKE PICTURES FROM US, OTHERWISE SOMETHING WILL HAPPEN
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TO US.) Hereto attached is the Affidavit of Witness executed by of our land
administrator OLIPIO S. LIM, JR. as Annex “M” and “M-1”;
16. That JOEL ARAGONCILLO further threatened and warned our land
administrator OLIPIO S. LIM, JR. by calling in his cellular phone in vernacular
“LAST NA NIMONG TAMAK DIRI SA TIKANG, KUNG MOBALIK PA KA, NAA
NAY MAHITABO SA IMO” (THAT WILL BE YOUR LAST TO STEP ON
TIKANG, IF YOU WILL COME BACK SOMETHING WILL HAPPEN TO YOU);

17. That I am executing this Affidavit purposely to formally file three (3)
counts of QUALIFIED THEFT IN VIOLATION OF ARTICLE 10 OF THE
REVISED PENAL CODE;

18. That I am also filing GRAVE THREATS IN VIOLATION OF ARTICLE

282 OF THE REVISED PENAL CODE) against JOEL ARAGONCILLO,
JEFFREY LAGEGO alias Pit Pit, INDAY ARAGONCILLO LAREGO, ESTONG
MAKARUNGALA and his wife, JAN JAN MAKARUNGALA, MATEAS
MAKARUNGALA, GAGAL MAKARUNGALA, Alias FLOR and JOHN DOES all
of them are presently occupying inside our property at Sitio Tikang, Brgy. Big
Margus, Glan, Sarangani Province and they are putting the law into their hands.

IN WITNESS HEREOF, I have hereunto set my hand this __ day of August

2017 at Alabel, Sarangani Province, Philippines.

HECTOR G. SALMON
Affiant

SUBSCRIBED AND SWORN TO before me this __ day of August 2017 at

Alabel, Sarangani Province, Philippines and I hereby certify that I have
personally examined the herein affiant and fully satisfied and convinced that he
voluntary executed the foregoing affidavit and understood the contents thereon.

REPUBLIC OF THE PHILIPPINES)

ALABEL, SARANGANI PROVINCE) S.S
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AFFIDAVIT OF WITNESS
1. That I, OLIPIO S. LIM JR., Filipino, of legal age married and a resident of
Sitio Laying, Big Margus, Glan, Sarangani Province;

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2. That I am the duly appointed land administrator and Attorney-in-Fact of the
coconut plantation of the heirs of the late ALFREDO M. SALMON situated
at Sitio Tikang, Big Margus, Glan, Sarangani Province by virtue of a Joint
Special Power of Attorney;
3. That on May 22, 2017 early in the morning one of my trustees an
Indonesian national in the person of LEKTOR MANDALIKA called me in
my cellular phone that that the matured coconut trees planted inside the
property of late ALFREDO SALMON were harvested by JEFFREY
LAREGO known as PITPIT with the assistance of his wife INDAY
ARAGONCILLO LAREGO, JOEL ARAGONCILLO, and JAN JAN
MAKARUNGALA without any permission from the land owners the heirs
of late ALFREDO SALMON;
4. That because of the said report, I immediately went to the area and
personally verified the incident and when I arrived thereat, I personally saw
the remains harvested coconuts such as the coconut husk, and the
charcoal and then I asked LEKTOR MANDALIKA to testify but he said to
me he was afraid to be a witness since the group of JOEL ARAGONCILLO
will hurt him and his family;
5. That on that occasion while we were talking with LEKTOR MANDALIKA,
JEFFREY LAREGO Alyas PIT-PIT passed by and I called him and asked
him who was his companion who harvested the coconuts and then he
answered to me that his wife INDAY ARAGONCILLO LAREGO and his
uncle JOEL ARAGONCILLO and I further asked him where did they sold
the dried copra, he answered in Brgy. Batulaki, Glan, Sarangani Province;
6. That I immediately went to Brgy. Batulaki, and asked the owner of the store
JOHN RAY VERGARA if indeed the copra were to their store, JOHN RAY
VERGARA confessed that he bought the six and half sacks of copra from
JEFFREY LAREGO alyas PIT-PIT, JOEL ARAGONCILLO and INDAY
ARAGONCILLO LAREGO;
7. That on June 26, 2017 at around 10:00 o’clock in the morning, I received
a call from my trustee BONG SALAYON, he told me that the matured
coconut fruits planted on the same property was harvested by JOEL
ARAGONCILLO, ESTONG MAKARUNGALA, JEFFREY LAREGO
ALYAS PIT-PIT, and others not identified, the same was reported to the
office of Philippine National Police, Glan, Sarangani Province;
8. That recently on August 16, 2017 at around 6:00 in the morning I
received a call from the matured coconuts planted on the same property
was harvested by JOEL ARAGONCILLO then I went immediately to the
area, and when I arrived there at around 3:00 in the afternoon, I used my
camera to take pictures of the newly gathered coconuts fruits and the four
(4) newly cut coconut trees and one (1) molave tree which they made into
lumber,
9. That when I went to the other corner of the area, I personally saw newly
gathered coconut fruits and the person of JOEL ARAGONCILLO,
ESTONG MAKARUNGALA and his wife, MATEAS MAKARUNGALA,
GAGAL MAKARUNGALA and a certain FLOR and others not identified,

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 10. That when I about to take pictures of their group, JOEL ARAGONCILLO
holding a piece of round wood angrily shouting at me in our vernacular
words “AYAW GYUD ME KUHAE UG PICTURES KAY BASI MAHITABO
TA. (DO NOT TAKE PICTURE FROM US OTHERWISE SOMETHING
WILL HAPPEN TO US);
11. That I was not able to take pictures of their persons out of respect to them
and to avoid further confrontation so I just immediately went to the
Municipal Police Station of Glan, Sarangani Province and reported the said
incident for record purposes;
12. That thereafter, on August 17, 2017 at around 7:00 in the morning I called
JOEL ARAGONCILLO using my cellular phone requesting him to stop
harvesting the coconut fruits but he replied by saying that he will not stop,
but instead he threatened me in vernacular “LAST NA NIMONG TAMAK
DIRI SA TIKANG, KUNG MOBALIK PA KA, NAA NAY MAHITABO SA
IMO” (THIS WILL BE YOUR LAST TO STEP ON TIKANG, IF YOU WILL
COME BACK SOMETHING MIGHT HAPPEN TO YOU);
13. That because of the said incidents all of our trustees in the area are now
afraid to get inside the property of ALFREDO SALMON;
14. That I am executing this affidavit to attest to the truthfulness of the
foregoing statement and to support to the complaint for QUALIFIED THEFT
and GRAVE THREATS against JOEL ARAGONCILLO, JEFFREY
LAGEGO alias Pit Pit, INDAY ARAGONCILLO LAREGO, ESTONG
MAKARUNGALA and his wife, JAN JAN MAKARUNGALA, MATEAS
MAKARUNGALA, GAGAL MAKARUNGALA, Alias FLOR and JOHN
DOES for whatever legal intent purposes.

OLIPIO S. LIM, JR.

Affiant

SUBSCRIBED AND SWORN TO before me this __ day of August 2017 at

Alabel, Sarangani Province, Philippines and I hereby certify that I have
personally examined the herein affiant and fully satisfied and convinced that he
voluntary executed the foregoing affidavit and understood the contents thereon.