Republic of the Philippines

REGIONAL TRIAL COURT

BRANCH 32
Quezon City

People of the Philippines,

Complainant,

-Versus- Criminal Case No. 74-SD (96)

For: HOMICIDE
Alejandro,
Accused,

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COMPLAINT-AFFIDAVIT

COMES NOW, the complainant, by the undersigned attorney, and unto this

Honorable Court, respectfully avers:

1. That complainant, AAA, is of legal age, Filipino, single and a resident of

Antipolo City, Philippines.

2. This complaint is being filed to charge Alejandro, a Filipino of legal age,

married, and a resident of Barangay Lagim, Quezon City, Philippines, for the

crime of Homicide under Article 249 of the Revised Penal Code.

3. That on or about the 5th day of January 2022, at Barangay Lagim, Quezon

City, Philippines, and within the jurisdiction of this Honorable Court, the

above-named accused, with intent to kill then and there wilfully, unlawfully,

and feloniously attacked, beat, and stabbed one [BBB] on different parts of
 her body with the use of a pointed instrument, thereby causing her to

succumb to her injuries.

4. On December 12, 2021, AAA joined her co-worker for a vacation as they were

both laid off from work and they stayed at the house of the latter’s 62-year-

old mother, BBB. AAA would sleep at the ‘papag’ while BBB slept on a

mattress on the floor.

5. That around 2:30 in the morning of January 5, 2022, AAA awoke to the sound

of BBB’s pleas for mercy. Aided by the kerosene lamp placed on the floor, AAA

saw BBB being mauled and stabbed to death by Alejandro. Thereafter,

Alejandro approached AAA and restrained her arms, and AAA was able to

fight back by scratching Alejandro’s back. Alejandro punched her on the left

side of her face and hit her left jaw with a piece of wood. AAA lost

consciousness and woke up in a hospital, while BBB succumbed to her

injuries.

6. That medical records show BBB's cause of death was due to "neurogenic

shock" or severe pain secondary to "multiple blunt injuries and fracture of the

mandibular and facio-maxillary bones.

7. At the hospital, AAA was interviewed by police officers who showed her

several mugshots in order for her to identify her assailant. AAA was then

able to recognize Alejandro from said mugshots and positively identified him

as the perpetrator of the crime. Medical records revealed that AAA was

indeed assaulted.

8. That the accused averred that his relationship with BBB was like that of a

mother and son, contradicting his later claims that he does not know both

AAA and BBB until the filing of the charges against him.

9. That a police blotter was filed and is brought to this Honorable Court as

evidence.
 10. The medico-legal of both AAA and BBB was brought as evidence to the

Honorable Court.

11. That a certified autopsy of BBB was brought to the Honorable Court.

12. The witnesses named Arlene P. Ramirez and Kyle Lopez will appear before

the Honorable Court to testify.

PRAYER

WHEREFORE, it is respectfully prayed of this Honorable Court, after

due proceedings, judgement be rendered finding the accused, Alejandro, guilty

beyond reasonable doubt of the crime of Homicide and imposing upon him the

penalty provided by law, and for such other relief and remedies as are just and

equitable in the premises.

Other relief and remedies are likewise prayed for. Quezon City, Metro Manila,

Philippines, April 27, 2023.

______________________

Counsel for complainant

 VERIFICATION OF CERTIFICATION

I, AAA, of legal age, Filipino, single, and a resident of Antipolo City,

Philippines, after being sworn in accordance with law, hereby depose and say:

1. That I am the Complainant in the above-entitled case; That I have caused the

preparation of the above Complaint and I have read the same and knows the

contents thereof; That the allegations contained therein are true and correct

of my own personal knowledge.

2. That I further certify that: (a) I have not theretofore commence any other

action or proceeding or filed any claim involving the same issues or matter in

any court, tribunal, or quasi-judicial agency, and, to the best of my knowledge,

no such action or proceeding is pending therein; (c) if I should thereafter

learn that the same or similar action or proceeding has been filed or is

pending before the Supreme Court, the Court of Appeals, or any other

tribunal or quasi-judicial agency, I undertake to report such fact within five

(5) days therefrom to the court or agency wherein the original pleading and

sworn certification contemplated herein have been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this 27th day of

April, 2023 at Quezon City, Philippines.

AAA,

Affiant
 SUBSCRIBED AND SWORN to before me, this 27th day of April, 2023 at

Quezon City, Philippines

NOTARY PUBLIC