REPUBLIC OF THE PHILIPPINES

OFFICE OF THE CITY PROSECUTOR

TAGAYTAY CITY

IMMANUEL JOHN EVARISTO,

Complainant

IS NO. 20010121
- versus - For: Violation of
Republic Act No. 10175 or
the “Cybercrime Prevention Act
of 2012”.

JOHN POSERIO
Respondent.

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COMPLAINT

COMES NOW IMMANUEL JOHN EVARISTO y POSERIO, Plaintiff in the above-styled

and numbered cause, by and through his attorneys, and files this his Complaint against
Defendant, JOHN EVARISTO, IJPE CORPORATIONS Inc., and in support thereof
would show unto the Court the following matters and facts:

1. I, IMMANUEL JOHN EVARISTO y POSERIO of legal age, single, Filipino

Citizens and a resident of PERIDO STREET, SAN PEDRO ROAD, BUKAL,
MENDEZ, CAVITE, PHILIPPINES .

2. IJPE CORPORATIONS is a corporation organized and existing under the laws of

the state of PHILIPPINES , with its principal office located at PERIDO STREET,
SAN PEDRO ROAD, BUKAL, MENDEZ, CAVITE, PHILIPPINES, 4121, and may be
served with process and other writs of this Court at KAYBAGAL NORTH, TAGAYTAY
CITY, PHILIPPINES.
3. On MAY 24, 2022, Defendant's agents wrote the following about Plaintiff:
SPREADING FALSE RUMORS ABOUT HIS APPOINTMENT AS NEWLY CHIEF
EXECUTIVE OFFICER.

4. Said writing contained the following false and defamatory matter: In the absence of
any right or privilege, the defendant has violated the right of IMMANUEL JOHN
EVARISTO y POSERIO, CAVITE, PHILIPPINES to be appointed as the Chief
Executive Officer of the Company, a matter said to defame plaintiff.

5. In the present case, plaintiff has been the target of a deliberate campaign, which
includes publishing a libel on the defendant's website.

6. On MAY 22, 2022, defendant's website published the foregoing defamatory matter
which was delivered by way of a hyperlink to said website from the following web page:,
and said website was hosted by the website software firm of (state), who maintain and
operate said website and who have the authority and technical expertise to provide said
website with a safe, secure and reliable internet connection.

7. In the absence of any right or privilege, plaintiff has been subject to a reasonable risk
of physical bodily harm caused by defendant's libel by virtue of his act or inaction in the
delivery of a libel to the plaintiff, and such action shall not be dismissed, as a matter of
law, simply because the defendant does not have physical contact with plaintiff.