Republic of the Philippines )

City of Dumaguete ) S.S

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COMPLAINT-AFFIDAVIT

I, IVANA ALAW-ALAW, of legal age, Filipino with home address at

Door 1 Alilaen Apartment, Brgy. Daro, Dumaguete City, after being sworn
to in accordance with law, hereby depose and state that:

1. I am the mother of Junnieboy Alaw-Alaw, 26 years old,

employed at Foundation University. A copy of the birth certificate of
Junnieboy Alaw-Alaw is hereunto attached and made as an integral
part hereof as Annex “A”;

2. The accused, CONG VASQUEZ, is a family friend residing at Brgy.

Looc, Dumaguete Cty;

3. On March 1, 2020, around 8:00 p.m., my family and I were at our

Restaurant located at Barangay Daro, Dumaguete City to celebrate the
birthday of my husband, Luonyo Alaw-Alaw;

4. At around 10:00 p.m. on said night, the celebration was interrupted by

the arrival of Cong Vasquez who alighted from a motorcycle in front
of the restaurant;

5. Cong shouted for Junnieboy to come out saying that he will kill him
because of a gambling debt that Junnieboy failed to pay;

6. I tried to prevent Junnieboy from approaching Cong, but Junnieboy

did not heed my warning and approached Cong to try to reason with
him;

7. While Junnieboy was approaching Cong, the latter suddenly pulled

out a gun and, without warning, shot Junnieboy multiple times;

8. Junnieboy fell to the ground and Cong continuously fired upon him
even after he was sprawling on the ground;

9. Upon arrival at the Silliman University Medical Center, Dr. Kyle

Tapia, immediately attended to my son and after a thorough
examination, declared him dead on arrival. The medico-legal autopsy
report, the NSO death certificate, and a certification from the City
Civil Registrar of Junnieboy Alaw-Alaw hereunto attached and made
 an integral part of the complaint as Annex “B” , “ C”, and “D”,
respectively;
10. I immediately reported the killing incident on or about 12:00 o’clock
midnight at the Dumaguete Police Station which is the nearest police
station. The original copy of the excerpt of the police blotter duly
issued by Senior Police Inspector Beau Inato of Dumaguete Police
Station is hereunto attached and made as an integral part hereof as
Annex “E” of the complaint;

11. I am therefore executing this affidavit freely and voluntarily in

support of my intent to file a case for MURDER qualified by
treachery, premeditation, and abuse of superior strength and/or the
appropriate criminal case against CONG VASQUEZ, who is 48 years
of age and a resident of Barangay Looc, Dumaguete City.

To the truth of the foregoing, I have signed this Complaint-Affidavit on

March 2, 2022 at Dumaguete City, Philippines.

IVANA ALAW-ALAW
Affiant

SUBSCRIBED AND SWORN to before me this 2nd day of March

2022 at Dumaguete City, Philippines and I FURTHER CERTIFY that I have
personally examined the affiant and I am satisfied that she has read and
personally understood the contents of her foregoing “Complaint-Affidavit”.

KARL HEINZ TAPIA

Prosecutor II
Roll No. 82937-0298
IBP No. 019283-1/3/23
PTR No. 009822- 1/3/23; Dumaguete
MCLE Compliance III No. 0092874
Issued on February 2, 2022