Republic of the Philippines

Third Judicial Region

Department of Justice
City Prosecution Office
Angeles City

YNA BANDONA
Complainant,

-versus- CRIM. CASE NO. 135-14

For CONCUBINAGE

BABY GIRL and TOTOY MOLA

Respondents.

x______________________________x

COMPLAINT-AFFIDAVIT

I, YNA BANDONA, of legal age, married and a resident of 127 Catherine St.,
Villa Angelina Subd., Barangay San Jose. Angeles City, Pampanga, under oath,
declare that:

1. On May 10, 2014, Totoy Mola, the respondent, and I got

married.
2. On 15 November 2021, I saw the respondents Totoy and Baby
in Starbucks Nepo Quad, eating together. Having doubts of my husband’s
fidelity, I decided to investigate. I left the establishment, stayed in my car
and saw them leaving the establishment after Totoy gave Baby a kiss on the
cheek.
3. On April 25, 2022, I saw store receipt in my husband's pants
which shows jewelry, a necklace, bought from Pandiego by Totoy. I also
saw the same jewelry referred in the receipt in a box beside my husband’s
suitcase inside the closet. A copy of the credit card receipts is hereto
attached as Annex “A.”
4. When I opened my husband’s suitcase, I saw a used roundtrip
plane ticket for MNL-SIN-MNL. The tickets were issued under the names
of respondents, for the period of March 18-19, 2022. A copy of the roundtrip
plane tickets is hereto attached as Annex “B”.
5. Upon further investigation, I also found receipts showing that
respondents had stayed together in one suite at the Mahal Kita Hotel on
April 29, 2022. Their stay together at a hotel has also persuaded me that they
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have already had carnal knowledge of one another. A copy of the receipts
showing proof of their stay at the Mahal Kita Hotel is hereto attached as
Annex “C.”
6. Lastly upon following my husband in his recent trip to Capas,
Tarlac last May 1, 2022, it came to my knowledge that he had rented an
apartment with an address at Block 1 Lot 55 Brgy. Dolores, Capas, Tarlac,
Philippines for Baby Girl and had been meeting with her every weekends
posing as her husband to their neighbors. And that they have been renting
the said apartment since October 10, 2021.
7. In addition, it is most unlikely that Ms. Baby Girl had not been
aware of my husband’s current status as a married man seeing as this affair
has been going on for more than half of the year. They have been meeting
together discreetly as well as leaving on trips together abroad, meeting with
another at hotels and cohabiting in another municipality.
8. Based on the foregoing facts, I have logical reason to believe
that the respondents have committed the crime of concubinage punishable
under Art. 334 of the Revised Penal Code. There is concubinage when a
married man, such as my husband, shall keep a mistress in the conjugal
dwelling, or shall have sexual intercourse, under scandalous circumstances,
with a woman who is not his wife, or shall cohabit with her in any other
place, such as Ms. Baby Girl, not his wife.
9. I am executing this sworn statement for the purpose of charging
my wife and her paramour with violating Art. 334 of the Revised Penal
Code which penalizes the crime of adultery.

Angeles City, Pampanga, Philippines. May 4, 2022.

Yna Bandona
Complainant

SUBSCRIBED and SWORN to before me, the undersigned

prosecutor, this 4th day of May, 2022 at Angeles City, Pampanga,
Philippines. I hereby certify that I have personally examined the above-
named affiant and that I am satisfied that the foregoing statements were
given by him voluntarily and of his own free will.

Atty. Luke D. Wandasan

Prosecutor