REPUBLIC OF THE PHILIPPINES)

PROVINCE OF PANGASINAN ) S.S.

MUNICIPALITY OF LINGAYEN )

COMPLAINT – AFFIDAVIT

I, ARLYN P. JABONITA of legal age, single, Filipino, Resident of Brgy Buenlag

Bugallion, Pangasinan, after having been duly sworn to in accordance with law, do hereby
depose and state:

1. That I am instituting a criminal complaint for violation of section 4(c) (4) of R.A.
10175, otherwise known as CYBERCRIME LAW ACT OF 2012 against CHARIES PAULO,
of legal age, Filipino citizen, and a resident of Brgy. Pantal, Bugallon, Pangasinan.

2. That at or about 9:30AM of July 20, 2022, my sister, Lovely Ancheta, informed me
that a Facebook Account named Seirach Paulo posted a picture of John Farinas and I with a
caption so vile as to vehemently ruin my reputation and damage my character as a human being.
The said Facebook Account is owned by Charies Paulo.

3. The said Facebook post contained the following statements in Pangasinan Dialect
along with my picture,

“Bagay, parehas kayoy eleng…

Asayet tan bwanges,
Arlyn Jabonita ya asayet
John ya bwanges…

A copy of the screen shot post is attached to this complaint as annex “A”.

4. Shortly after the incident, I went to the Police Station of Bugallon and reported what
has just transpired. Eventually it was blottered therein. Thereafter, numerous comments followed
on the post, most of which were comments of Charies herself using her account. Such comments
contain the following statements in the Pangasinan Dialect,

“Atan may bii ya singa aso ya magatel”

“magatel ya asayet”
“Dakel ya makapankabat sayan asayet taga buenlag tan..
paragas ni..”

A copy of the said screen shot of these comments on the post is attached to this complaint
as annex “B”
 5. Afterwards, another barrage of comments in Pangasinan Dialect by Charies transpired,
but now she was using John Farinas’ account, her husband. One of which is “Chester Cruz kabit
totan”. A copy of the screenshot of said comment is herein attached as annex “C”

The libelous post, having been published on Facebook, a website accessible to and is made
available to the general public, was read by said general public, including my colleagues, friends,
and family among others;

4. Due to the said malicious public imputations by respondents, I suffered and

continue to suffer serious anxiety, besmirch of reputation, mental anguish, sleepless nights, not
to mention the damages they caused to my reputation and honor not only to my family, but to the
general public as well.

5. Due to such grossly unjustified malicious and libelous imputations, I therefore

pray that respondents be made to pay jointly and severally, the damages I was made to suffer as a
result of the online published Facebook Post in whatever amount the Honorable Court deems
sufficient and proper together with the attorney’s fees and cost of this suit.

IN WITNESS WHEREOF, I have hereunto set my hand this ___ day of ______, 2022 in
Lingayen, Pangasinan.

____________________

Complainant

SUBSCRIBED AND SWORN TO BEFORE ME this ___ day of _________ 2022 in

Lingayen, Pangasinan. I further certify that I personally examined the herein affiant and I am
convinced that he voluntarily executed the foregoing affidavit and he fully understood the
contents thereof.