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Republic of the Philippines

Department of Justice
National Prosecutor Service
Office of the City Prosecutor
Sta. Rosa, Laguna

People of the Philippines ,


Complainant,
Criminal Case No.: 12378
For: Homicide
{Art. 249 of the RPC}
-versus-

Lawrence Mark Corpuz,


Respondent,

x--------------------------------x

COMPLAINT-AFFIDAVIT

I, Malou Lomutac, 46 years old, widowed, Filipino, and a resident of


Riviera Homes, Sta. Rosa, Laguna, being duly sworn in accordance with the law,
hereby depose and state the following:
1. Marie Antoinette Tan, 20 years old, single, Filipino, and a resident of
Riviera Homes, Sta. Rosa, Laguna, was my daughter who passed away
on September 23, 2016 in a most tragic way.

2. As a mother who is deeply wounded by her sudden and unfortunate


passing, I am executing this complaint-affidavit to file a case against
Lawrence Mark Corpuz, 28 years old, single, Filipino, and a resident of
Ambrocia Subdivision, Santa Rosa, Laguna, for the offense of Homicide,
in violation of Article 249 of the Revised Penal Code (RPC) of the
Philippines.
3. On September 22, 2016, at approximately 11:00 in the evening, I was
aware that my daughter, Marie Antoinette Tan, had secretly left our house.
It was not uncommon for her to sneak out and meet her friends at that
hour, and I did not worry since she would return home promptly, usually
the next day.

4. The following morning, September 23, 2016, around 8 o'clock, I was


surprised to find Marie's boyfriend, Ronald Anthurium, sitting in our living
room, waiting for Marie. I immediately texted Marie to inform her that her
boyfriend was waiting and to inquire about her whereabouts since she had
left behind her important belongings, such as her bag and laptop, which
was uncommon since she always carried them. I tried contacting her
through her phone, but her phone was unreachable. It was during this time
that I began to feel uneasy.

5. In the afternoon, at around 3 o'clock on the same day, there was a


commotion regarding a deceased body found at Garden Villas
Subdivision, Santa Rosa, Laguna, which was approximately five (5)
minutes away from our residence. My neighbor, Niel Soriasis, showed me
pictures of the deceased, alleged to be a pregnant woman wearing a blue
shirt. I tried to dismiss the thought that it could be my daughter because I
was certain she was wearing a black shirt when she left. I continued trying
to contact Marie, convincing myself that she was simply busy. However,
deep down, I began to worry. Despite the limited evidence that confirmed
her identity, such as the anklet and watch, I clung to the slight hope that it
was not her. Unfortunately, to my dismay, the subsequent picture I was
shown unquestionably confirmed that it was indeed her. I immediately
rushed to the Memorial Home in Cabuyao, Laguna, where her body had
been taken.

6. The accused, Lawrence Mark Corpuz, was an acquaintance of my


daughter Marie, whom I was unaware of. Based on CCTV footage
obtained by the Santa Rosa Police Station, he was the last person seen
with Marie. Additionally, witnesses who testified described a person
matching Lawrence Mark Corpuz's description. The post-mortem
examination revealed that my daughter's cause of death was asphyxia by
manual strangulation, committed by the accused, who subsequently
disposed of her body in a vacant lot within Garden Villas Subdivision,
Santa Rosa, Laguna.

7. I am executing this affidavit to affirm the truthfulness of the foregoing facts,


which will support the filing of a Criminal Case against Lawrence Mark
Corpuz for the violation of Article 249 of the RPC.

IN WITNESS WHEREOF, I have hereunto affixed my signature on this


th
25 day of September 2016, at Santa Rosa Laguna, Philippines.

MALOU LOMUTAC
Affiant

SUBSCRIBED AND SWORN to before me this 25th day of September


2016 at Santa Rosa Laguna, Philippines. I HEREBY CERTIFY that I have
personally examined the affiant and that I am convinced that he voluntarily
executed the foregoing affidavit and that he understood the contents thereof.

ATTY. OLGA A. RESERVA


Assistant City Prosecutor

Additional DETAILS WERE ADDED DUE TO the lack of information in the video,
including to the succeeding affidavits.
Republic of the Philippines
Department of Justice
National Prosecutor Service
Office of the City Prosecutor
Sta. Rosa, Laguna

People of the Philippines ,


Complainant,
Criminal Case No.: 12378
For: Homicide
{Art. 249 of the RPC}
-versus-

Lawrence Mark Corpuz,


Respondent,

x--------------------------------x

COUNTER AFFIDAVIT

I, Lawrence Mark Corpuz, 28 years old, single, Filipino, and a resident of


Ambrocia Subdivision, Santa Rosa, Laguna, being duly sworn in accordance with
the law, hereby depose and state the following in response to the complaint-
affidavit filed against me by Malou Lomutac:
1. I am aware of the tragic passing of Marie Antoinette Tan, and I express
my deepest condolences to her family. However, I vehemently deny any
involvement in her untimely death.

2. On September 22, 2016, I had no interaction with Marie Antoinette Tan,


nor did I have any knowledge of her whereabouts or activities during that
period. I was engaged in my own personal affairs, unrelated to her, and
can provide corroborating evidence and witnesses to support my claim.

3. The allegations made by Malou Lomutac, accusing me of being the last


person seen with Marie based on CCTV footage, are unfounded and
misleading. I request a thorough review of the said footage to verify that I
had no contact or interaction with her on the specified date.

4. Furthermore, I dispute the claim that witnesses have identified me as a


person matching my description in relation to the events surrounding
Marie's death. I assert my innocence and request that these witnesses be
further examined to ensure the accuracy and reliability of their testimonies.

5. I am willing to fully cooperate with the investigation and provide any


necessary evidence to prove my innocence. I have nothing to hide and
believe that a careful examination of the facts will free me from the
charges brought against me.

6. It is my firm belief that the evidence presented will reveal the truth and
establish that I am not responsible for Marie Antoinette Tan's tragic
passing. I assert my right to a fair and impartial investigation, as well as a
just resolution of this case.

7. As I submit this counter affidavit, I affirm that the statements made on the
same are true and accurate to the best of my knowledge and belief.

IN WITNESS WHEREOF, I have hereunto affixed my signature on this 1 st


day of October 2016, at Santa Rosa Laguna, Philippines.

LAWRENCE MARK CORPUZ


Affiant

SUBSCRIBED AND SWORN to before me this 1st day of October 2016 at


Santa Rosa Laguna, Philippines. I HEREBY CERTIFY that I have personally
examined the affiant and that I am convinced that he voluntarily executed the
foregoing affidavit and that he understood the contents thereof.

ATTY. OLGA A. RESERVA


Assistant City Prosecutor

Republic of the Philippines


Department of Justice
National Prosecutor Service
Office of the City Prosecutor
Sta. Rosa, Laguna

People of the Philippines ,


Complainant,

Criminal Case No.: 12378


For: Homicide
{Art. 249 of the RPC}
-versus-

Lawrence Mark Corpuz,


Respondent,

x--------------------------------x

REPLY AFFIDAVIT

I, Malou Lomutac, the complainant in this case, hereby submit this reply
affidavit in response to the counter affidavit filed by Lawrence Mark Corpuz. I
solemnly affirm the following statements to be true and correct to the best of my
knowledge and belief:
1. While Mr. Corpuz expresses his condolences for the passing of Marie
Antoinette Tan, I stand by the allegations made in the original complaint-
affidavit, firmly believing that the evidence supports the charges against
him.

2. Mr. Corpuz denies any involvement in the untimely death of Marie


Antoinette Tan. However, it is crucial to note that witness testimonies and
CCTV footage provide strong indications of his presence and potential
connection to the events surrounding her death.

3. The claim that Mr. Corpuz had no interaction with Marie Antoinette Tan on
September 22, 2016, is disputed based on the evidence gathered. The
thorough examination of the CCTV footage clearly shows him in the
vicinity of the Garden Villas Subdivision, Santa Rosa, Laguna where the
dead body of Marie had found.

4. The allegations made against Mr. Corpuz are not unfounded or


misleading. The identification of his presence by witnesses and the
corresponding description provided by them solidify the connection
between Mr. Corpuz and the events surrounding Marie's tragic passing.

5. I personally and respectfully requests the court to thoroughly examine the


evidence and testimonies presented in this case, ensuring a fair and
unbiased determination of the truth. The pursuit of justice for the untimely
death of Marie Antoinette Tan is of utmost importance in this trying times.

6. I am executing this affidavit to attest, to the best of my knowledge, the


truthfulness and correctness of the foregoing facts and to support my
claims on my Complaint-Affidavit.

IN WITNESS WHEREOF, I have hereunto affixed my signature on this


11th day of October 2016, at Santa Rosa Laguna, Philippines.

MALOU LOMUTAC
Affiant

SUBSCRIBED AND SWORN to before me this 11th day of October 2016


at Santa Rosa Laguna, Philippines. I HEREBY CERTIFY that I have personally
examined the affiant and that I am convinced that he voluntarily executed the
foregoing affidavit and that he understood the contents thereof.

ATTY. OLGA A. RESERVA


Assistant City Prosecutor
Republic of the Philippines
Department of Justice
National Prosecutor Service
Office of the City Prosecutor
Sta. Rosa, Laguna

People of the Philippines ,


Complainant,
Criminal Case No.: 12378
For: Homicide
{Art. 249 of the RPC}
-versus-

Lawrence Mark Corpuz,


Respondent,

x--------------------------------x

REJOINDER AFFIDAVIT

I, Lawrence Mark Corpuz, the respondent in this case, hereby submit this
rejoinder affidavit in response to the reply affidavit filed by Malou Lomutac, after
having been duly sworn in accordance with the law, hereby depose and state the
following:
1. While I express my condolences for the passing of Marie Antoinette Tan, I
maintain my assertion of innocence and deny any involvement in her
untimely death. I appreciate the seriousness of the allegations against me
but firmly believe that the evidence does not support the charges brought
forth.
2. Lomutac stands by the allegations made in the original complaint-affidavit,
emphasizing that the evidence supports the charges against me.
However, it is crucial to note that the evidence presented is circumstantial
and lacks direct proof of my involvement in the events surrounding Marie's
death.
3. The claim that I had a potential connection to the events based on witness
testimonies and CCTV footage as what had mentioned in Paragraph 4 of
the Reply Affidavit is disputed. Before and on the day of the incident, I was
staying at my friend’s house in Makati City. It is essential to consider the
possibility of mistaken identification and the potential influence of external
factors on witness testimonies.

4. I acknowledge the petitioner's request for a thorough evaluation of all


evidence, including witness testimonies, CCTV footage, and other relevant
information. I fully support a fair and unbiased determination of the truth,
as it is crucial to ensure that justice is served for the tragic passing of
Marie Antoinette Tan.

5. The pursuit of justice requires a careful examination of the facts, and I


trust that the court will exercise its duty to ensure a just resolution based
on the evidence presented.

6. I am providing this affidavit to affirm that, to the best of my understanding


and belief, the facts aims to address allegations against me and that the
above mentioned are truthful and unbiased.

IN WITNESS WHEREOF, I have hereunto affixed my signature on this


st
21 day of October 2016, at Santa Rosa Laguna, Philippines.

LAWRENCE MARK CORPUZ


Affiant

SUBSCRIBED AND SWORN to before me this 21st day of October 2016


at Santa Rosa Laguna, Philippines. I HEREBY CERTIFY that I have personally
examined the affiant and that I am convinced that he voluntarily executed the
foregoing affidavit and that he understood the contents thereof.
ATTY. OLGA A. RESERVA
Assistant City Prosecutor

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