Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
Tarlac City

JOANNA DAVID
Complainant,

-versus-

MILDRED BILDAN
Respondent,
x-----------------------------------------x

COMPLAINT-AFFIDAVIT

I, JOANNA DAVID, of legal age, Filipino, and a resident of Tibag,

Tarlac City, Tarlac, after having been sworn in accordance with law, hereby
state that:

I Hereby Formally Charge:

MILDRED BILDAN, of legal age, Filipino Citizen, and with present

residence at Brgy. Care, Tarlac City, Tarlac ---------------- for violation of
Article 282 of the Revised Penal Code which defines and penalizes Grave
Threats, or any other offense which the Hon. Public Prosecutor may deem
proper to file committed as follows, and further state:

MATERIAL ALLEGATIONS

1. That I am a frequent user of online selling sites for my personal

needs such as clothes, dresses, health/hygienic needs, etc., and as such, I
normally receive calls confirming my address as well as the delivery of my
parcels;

2. That sometime in April 2022, I ordered a parcel from an online

shop (Elana Online Shop) who is partnered with Entrego which was
delivered on April 20, 2022. Prior to such delivery, as part maybe of their
standard operating procedure, the delivery driver, who I later on got to
know as Christian Paul B. Protacio, contacted me, hence his number

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appearing in my call logs, a print-out of said call log is hereto attached and
marked as “ANNEX A” and made an integral part hereof;

3. Due to an unintentional dialing of the number of the Christian Paul

B. Protacio after he had successfully delivered my order/parcel, his live-in
partner/ wife, respondent MIDLRED BILDAN, called my number and
continuously harassed me;

4. As respondent continuously called my number, I answered her call

and explained that dialing of his lover’s number was unintentional and I
did not personally know Christian Paul B. Protacio. However, due to her
rage, she uttered insults towards me that made me decide to just end our
conversation as respondent’s reasoning was already distorted with rage.

5. However, even after the call, respondent was not contented with
the insults she hurled against me. After a minute, she started sending texts,
hurling insults to my woman hood and worse, threatening my well-being.
She called me “Hayop ka”, “Malandi ka pokpok ka”, “Yung puke mong yan
hayop ka papasukan ko ng tubo para hnd mangati”, “Putang ina mo”, “Putang
ina mo ma tyempuhan kita sa daan”, “Babasagin ko bungo anak puta ka” etc.

6. Respondent likewise said that she will look for my address thru the
shop I ordered and will defame me in our neighborhood. Even worse,
respondent threatened to shoot me in the head if we happen to have a
chance encounter. A print-out of the text messages sent to me is hereto
attached and marked as “ANNEX B and series” and made an integral part
hereof;

7. Because of the imminent fear implanted to my mind because of the

threats and insults hurled against me, I contacted Entrego’s customer
service support to report the incident. Thereafter, I got to know the name of
the delivery man and subsequently, that of the respondent’s.

8. I likewise reported the incident at Brgy. Care, Tarlac City for my

safety and the barangay initiated a conciliation proceedings. During the
three (3) conferences by the Lupong Tagapamayapa assigned to our case,
no settlement was reached. Worse, the respondent was even unremorseful
for the unsettling threats and vexing insults that she hurled against me.
Thus, after the third (3rd) unsuccessful conciliation conference with the
Barangay, it issued a Certificate to File Action and the same is hereto
attached as “ANNEX C” and made an integral part hereof.

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 9. In her fit of rage, respondent was unmindful of the fact that her
texts not only lambasted and insulted my whole being but likewise
amounted to a threat of killing me for a simple unintentional dialing of her
lover’s number. Clearly, her threats that she will “shoot me in the head”,
“put a pipe in my vagina” and/or “kill me inside my own home” are
constitutive of the crime of Grave Threats as penalized under the Revised
Penal Code.

10. I am executing this Affidavit to attest to the truthfulness of all the

foregoing facts and circumstances and for whatever legal purposes it may
serve and to support my complaint against the Respondent, for the crime
of GRAVE THREATS, and other offenses that this Honorable Office may
deem appropriate under the circumstances.

IN WITNESS WHEREOF, I have hereunto set my hand this ___ day

of ____________ 2022, at Tarlac City, Tarlac, Philippines.

JOANNA DAVID
Affiant

SUBSCRIBED AND SWORN, to before me ___ day of _____________

2022, at Tarlac City, Tarlac, Philippines. I hereby certify that the affiant had
executed the said complaint, freely and voluntarily and understood the
contents of the same.

__________________________
ADMINISTERING OFFICER

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COPY FURNISHED:

MILDRED BILDAN

With mailing address at Brgy. Care, Tarlac City, Tarlac.

EXPLANATION

A copy of the foregoing pleading was sent through registered mail

due to lack of time, distance, and messengerial services.

JOANNA DAVID

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