Grave Coercion - Business Owners

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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE (_)CITY (_) MUNICIPAL (_) PROVINCIAL PROSECUTOR
(_)CITY (_) MUNICIPALITY (_) PROVINCE OF ____________

____________________
Complainant,

- Versus - DOCKET NO. _____________


FOR: Grave Coercion

__________________
__________________
Respondent/s,

X---------------------------------x

COMPLAINT-AFFIDAVIT

I, ______________________, of legal age, (single/married) Filipino, and with address at


________________________________________________________________after having been
sworn in accordance with law, hereby depose and state:

1. I am a business owner in _______________ and the location of my business is at


____________________________________.

2. That sometime in ______________, the respondent (_) Mayor ___________________,


(_) Inter-Agency Task Force, (_) Metro Manila Development Authority issued an Order
__________ which prohibits business establishments such as that of complainant’s from
operating.

3. That the said Order is Ultra Vires as it violates my constitutional right to life under Art. II
Sec. 11 and Art. III Sec. 1. This is because, the respondent is using his office to
(_)intimidate, (_)threaten and (_)compel business owners like the complainant to close
down and be deprived of a source of income to support his life and that of his/her
family.

4. That since the pandemic has started, the protocols implemented have not been proven
effective and in fact, even with the protocols, the Covid-19 cases have continued to rise.
As such, implementing a protocol that does not help address the problem is no longer
motivated by public health but by sheer lack of sympathy to a dying economy and a
hungry population.

5. That even if there is a law which mandates vaccination, the use of (_)violence, (_)threat,
(_) intimidation to compel complainant to stop operation is violative of my
constitutional right to life under Art. II Sec. 11 and Art. III Sec. 1. It even amounts to a
systematic murder because with the denial to operate is also the clear way to kill
business owners of income to support his/her life, the life of his/her family and also the
life of the employees who rely on such business. Respondent might as well order
complainant along with his employees to be put to a gas chamber if the continued
denial to operate and have an access to a decent source of income.

6. I am therefore executing this Complaint-Affidavit in support of the charges for Grave


Coercion under Art. 286 of the Revised Penal Code against the said respondent,
__________________, who may be served with subpoena and other processes of this
Honorable Office at (his/her) last known address at
______________________________________________________, Philippines.

IN WITNESS WHEREOF, I have hereunto set my hands this _____ day of _____________, 20__
at ______________, Philippines.

__________________
Complainant

SUBSCRIBED AND SWORN to before me this ____ day of _____________, 20__ at


__________________________________. I hereby certify that I have examined the Affiant and
that I am fully satisfied that (he/she) has voluntarily executed and understood the contents of
(his/her) Complaint-Affidavit.

__________________
Administering Officer

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