REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
City Of Laoag

MICHELLE PADILLA-ABRENICA    
Complainant,

- versus -

FOR: Section 5 (a), 5 (e) (2), 5(i) of R.A 9262

or The Anti-
Violence Against Women and their
Children Act

NASH CONTIS ABRENICA

       Respondent. 

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

COMPLAINT – AFFIDAVIT

I, MICHELLE PADILLA-ABRENICA, married, of legal age, Filipino, with

residence at #182 Rizal Street cor. Balintawak, Brgy. 35, Laoag City, after having
been duly sworn in accordance with law, hereby depose and state that;

1. I am the same person who is the complainant in the instant case;

2. The respondent and I were married for more than twenty-five

years.

3. We were blessed with three children, JM Abrenica aged 24,

Rubena Abrenica aged 22, and Chieno Abrenica aged 15.

4. The first 5 years of our marriage were harmonious. He was a

great provider for our family. He was a loving and caring partner
and a father.

5. However, things changed beginning 24th of November 2011,

when I had my law internship. He was always jealous and
accused me of cheating. He also prevented me from seeing my
friends. He repeatedly told me that I should instead stay in our
house.

6. On 12 October 2021, when I came home after an overtime work,

he slapped me for coming home late. He again suspects me of
cheating. He even said that I am not really at work but were in
fact hanging out with my friends. He also said that he will kill
any man eyeing me.
7. My husband admitted having an affair with a bank manager. He
even boasted his sexual relationship with the bank manager to
our house help.

8. He cursed me in front of our children when I am confronting him

about his extramarital affairs. He also beat and slapped my
daughter Rubena, when she caught him exchanging nasty text
messages with his paramour.

9. His admission of having an affair resulted in our series of fights.

In one of our quarrels, he grabbed me on both arms and shook
me with a force that caused bruises and hematoma. At another
time, he hit me forcefully on the lips that cause some bleeding.

10. There was time that I am so tired of everything that I want to

end my despair, I attempted to end my life by cutting my wrist.
My husband however didn’t even bother to care and simply fled
the house.

11. When I told him my intention to sue him and his paramour, he
got mad and told me that if I will be filing a case against him, I
will not get any centavo. He also said that he will stop paying for
all of our family’s expenses. He emphasized that I should just be
thankful that he was not leaving me and cohabiting with his
paramour.

12. On the night of October 17, 2021, we had a heated argument that
resulted in a physical fight. He pushed me and the last thing I
heard were the words he uttered “PASALAMAT KA NA LANG
UMUUWI PA AKO SAINYO. ISA PA. ITITIGIL KO NA ANG
SUSTENTO! WALA KA MAKUKUHA NI PISONG DULING.”,
then everything went blurry.

13. I later learned in the hospital that I fell on the floor and
consequently rolled down 5 steps downward our stairs. Our
house help Maine saw everything. She called my mother Dorothy
and then they rushed me to the hospital and were attended
medical attention. I got bruises on my chest, neck, right arm and
shoulder. I also got stitches on my left brow. My mother Dorothy
Padilla also filed for a Temporary Restraining Order against my
husband. (SEE ANNEX A and ANNEX B: EXHIBIT 1, 2, 3).

14.  The acts aforementioned are violative of Section 5(a), 5 (e) (2),
and 5(i) of Republic Act No. 9262 or Anti-Violence Against
Women and Their Children Act of 2004 which provides that
 "Violence against women and their children" refers to any act
or a series of acts committed by any person against a woman
who is his wife, former wife, or against a woman with whom
the person has or had a sexual or dating relationship, or with
whom he has a common child, or against her child whether
legitimate or illegitimate, within or without the family abode,
which result in or is likely to result in physical, sexual,
psychological harm or suffering, or economic abuse including
threats of such acts, battery, assault, coercion, harassment or
arbitrary deprivation of liberty. It includes, but is not limited
to, the following acts:

A. "Physical Violence" refers to acts that include bodily or

physical harm;

C. "Psychological violence" refers to acts or omissions causing or

likely to cause mental or emotional suffering of the victim
such as but not limited to intimidation, harassment, stalking,
damage to property, public ridicule or humiliation, repeated
verbal abuse and mental infidelity. It includes causing or
allowing the victim to witness the physical, sexual or
psychological abuse of a member of the family to which the
victim belongs, or to witness pornography in any form or to
witness abusive injury to pets or to unlawful or unwanted
deprivation of the right to custody and/or visitation of
common children.

D. "Economic abuse" refers to acts that make or attempt to make a

woman financially dependent which includes, but is not
limited to the following:

1. withdrawal of financial support or preventing the victim from

engaging in any legitimate profession, occupation, business or
activity, except in cases wherein the other spouse/partner
objects on valid, serious and moral grounds as defined in
Article 73 of the Family Code;
xxxxxx

4. controlling the victims' own money or properties or solely

controlling the conjugal money or properties.

Section 5 of the same act specifically provides,

“Acts of Violence Against Women and Their

Children.- The crime of violence against women and
their children is committed through any of the
following acts:
(a) Causing physical harm to the woman or her
child;
(e) Attempting to compel or compelling the woman or
her child to engage in conduct which the woman or her
 child has the right to desist from or desist from conduct
which the woman or her child has the right to engage
in, or attempting to restrict or restricting the woman's
or her child's freedom of movement or conduct by
force or threat of force, physical or other harm or
threat of physical or other harm, or intimidation
directed against the woman or child. This shall include,
but not limited to, the following acts committed with
the purpose or effect of controlling or restricting the
woman's or her child's movement or conduct:
xxx
(2) Depriving or threatening to deprive the
woman or her children of financial support
legally due her or her family, or deliberately
providing the woman's children insufficient
financial support;
(i) Causing mental or emotional anguish, public
ridicule or humiliation to the woman or her child,
including, but not limited to, repeated verbal and
emotional abuse, and denial of financial support or
custody of minor children of access to the woman's
child/children.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of

this Honorable Court that after due notice and hearing, judgment be
rendered in favor of Complainant:

1. For the issuance of permanent protection order from respondent;

2. For the payment of support to his children
3. Other reliefs just and equitable under the premises are likewise
prayed for.

Laoag City, Philippines, 27 October 2021.

ATTY. CHON A. BELLS

Counsel for Plaintiff

Office of City Prosecutor

Marcos Hall of Justice, V. Legasca St.,
Brgy. 10, San Jose, Laoag City, Ilocos Norte

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

 Republic of the Philippines (City of Manila) S.S.

I, MICHELLE PADILLA-ABRENICA, of legal age, after having been

duly sworn in accordance with law, depose and state that:

1. I am a complainant in the above-stated case;

2. I caused the preparation of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and/or on the basis of copies of
documents and records in my possession;

4. I have not commenced any other action or proceeding involving the same
issues in the Supreme Court, the Court of Appeals, or any other tribunal or
agency;

5. To the best of my knowledge and belief, no such action or proceeding is

pending in the Supreme Court, the Court of Appeals, or any other tribunal
or agency;

6. If I should thereafter learn that a similar action or proceeding has been

filed or is pending before the Supreme Court, the Court of Appeals, or any
other tribunal or agency, I undertake to report that fact within five (5) days
therefrom to this Honorable Court.

Laoag City, Philippines, 27 October 2021. 

mpabrenica
MICHELLE PADILLA -
ABRENICA

SUBSCRIBED AND SWORN to before me on the 27th day of October 2021,

affiant exhibiting to me competent evidence of his identity by way of a
Philippine Passport with number P123467432A issued at DFA Laoag City which
is valid until February 09, 2023.

ATTY. LAL A. MOOVE

Notary Public of Ilocos Norte
Until December 31, 2022
PTR No. 1111111A / 01-05-2020 / Ilocos Norte
IBP No. 1111111 / 01-07-2020
Roll of Atty. No. 30000
 MCLE Compliance No. 0001111
TIN No. 121212121212
Ilocos Norte

Doc.  No. 112;

Page No. 11;
Book No. III;
Series of 2021