REPUBLIC O THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
SAN FERNANDO CITY, LA UNION

THI PHUONG LOAN TRAN SALANGA, a.k.a.

MARIE LOAN TRAN SALANGA,
Complainant, DOCKET NO. ____________________
FOR: Grave Coercion
-versus-
DOCKET NO. ____________________
EDMER T. SALANGA, in conspiracy with FOR: Trespass to Dwelling
RINO MIQUI and ELINOR DALIDIG,
Respondents.
X- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X

COMPLAINT-AFFIDAVIT

I, THI PHUONG LOAN TRAN SALANGA a.k.a. MARIE LOAN TRAN SALANGA, of legal age,
widow, U.S. citizen and a permanent resident of the Philippines, and a resident of and with postal
address at 744 Mabini Street, Brgy. Catbangen, San Fernando City, La Union after having been sworn
in accordance with law, hereby depose and state that:
1. I am the widow of the late Teodoro Salanga, Jr., and co-owner of the properties included in
the estate of my deceased husband by succession and I am attaching herewith our marriage
contract and herein being marked as ANNEX “A” and hereby made integral part hereof;

I may be served with summons and other processes of this Honorable Office through by
counsel to wit:
ATTY. JAIME C. GONZALES, JR.
MOSUELA - GONZALES & ASSOCIATES LAW OFFICES
Counsel for the Private Complainant
Unit 1 San Juan LGU Multi-Purpose Center
Santa Rosa de Lima Street, Ili Sur, San Juan, 2514 La Union

2. Respondent EDMER T. SALANGA, of legal age, married, holding dual citizenship as Filipino and
American citizen, owner/proprietor of CME Commercial Management Enterprise and a
resident of and with postal address at c/o ISABEL ANCHETA RESIDENCE, NORTH FORBES,
MABINI ST., CATBANGEN, SAN FERNANDO CITY, 2500 LA UNION where he could be served
summons and other processes of the Court;

3. Respondent EDMER T. SALANGA is my second child by my late husband, Teodoro, who

together with my other child, Sarifa and Nordinh Tran Salanga are both entitled to their
legitime anent the estate of my late husband;

4. I and the accused, EDMER T. SALANGA were declared both as CO-ADMINISTRATOR of the
estate of my late husband, TEODORO N. SALANGA, JR. and my Oath of Office is attached
herewith as ANNEX “B” and hereby made integral part hereof;

5. My late husband left behind an estate comprising of the following properties to wit:

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Complaint-Affidavit for Grave Coercion& Illegal Tresspass
 5.a. Cad. Lot. No. 5760-A located at Catbangen, San Fernando City, Las Union with an area of 573
square meters, covered by TCT No. T-16307 in the name of Teodoro N. Salanga, Jr., married to Tran Thi Phuong
Loan and declared under TD No. 93-022-9211 in the name of Teodoro N. Salanga;

5.b. Cad. Lot No. 398-C located at Brgy. III, San Fernando City, La Union with an area of 193 square
meters, covered by TCT No. in the name of Teodoro N. Salanga. Jr., married to Tran Thi Phuong Loan and
declared under TD No. 93-003-771-R in the name of Teodoro N. Salanga, Jr.;

5.c. Cad Lot No. 504-B located at Brgy. III, San Fernando City, La Union with an area of 246 square
meters, covered by TCT No. T-52788 in the name of Teodoro N. Salanga, Jr., and declared under TD No. 93-003-
57381 in the name of Teodoro N. Salanga, Jr.;

5.d. Cad Lot No. 504-A located at Brgy. III, San Fenando City, La Union with an area of 53 square
meters, covered under OCT No. 0-80 in the name of Teodoro N. Salanga, Jr., and declared under TD No. 93-003-
773 in the name of Teodoro N. Salanga, Jr.;

5.e. Cad Lot No. 6774-H located at Catbangen, San Fernando City, La Union with an area of 1,286
square meters, covered by TCT No. T-20162 in the name of Teodor N. Salanga, Jr., and declared under TD No. 93-
022-9254 in the name of Teodoro N. Salanga, Jr.;

5.f. Cad. Lot No. 5761-A located at Catbangen, San Fernando City, La Union with an area of 327 square
meters, covered by TCT No. 15138 in the name of Teodoro N. Salanga, Jr., and declared under TD No. 93-022-
66579 in the name of Teodoro N. Salanga, Jr., with improvement thereon classified as commercial building;

5.g. Cad. Lot No. 5760-C located at Catbangen, San Fernando City, La Union with an area of 355 square
meters, covered by TCT No. T-11398 and declared under TD No. 93-022-41608 still in the name of Miguela N.
Salanga, which is the subject of a Deed of Exchange between Teodoro N. Salanga, Jr., and his sister, Miguela,
which provides that the subject land shall pertain to Teodoro N. Salanga, Jr.; and

5.h. Parcel of land located at Catbangen, San Fernando City, La Union with an area of 530 square
meters, covered by TCT No. T-23772 still in the name of MIguela N. Salanga, which is the subject of a Deed of
Exchange between Teodor N. Salanga, Jr., and his sister, Miguela, which provides that the subject land shall
pertain to Teodoro N. Salanga, Jr.

6. Despite our designation as CO-ADMINISTRATOR, accused/respondent, EDMER T. SALANGA

had wrested control and possession of all the above-mentioned properties forming the estate
of my late husband to my exclusion; especially the property Item No. 5.f, where the acts of
grave coercions were committed and perpetrated by the accused/respondent against me
(private complainant) to my prejudice and detriment.

THE CRIME OF GRAVE COERCION WAS COMMITTED BY THE RESPONDENT EDMER

T. SALANGA ON THE PRIVATE COMPLAINANT AS FOLLOWS:

7. That on ______

Copies of the Police Report dated April 27, 2021 as reported by our Lessee relating to
the foregoing incidents and the subject undertaking are being attached herewith as ANNEXES
“F” & “F-1” and hereby made integral parts hereof;

8. That as a result of the acts described in Item No. 7, I was expelled from my dwelling place by
the accused, who is my biological son, my co-administrator, and co-owner of the entire
building where my personal dwelling place is located and effectively forced me out to change
my dwelling against my will and without due process;

That such acts of expulsion committed by the accused being a private person is an act of grave
coercion under the law;

That the accused forced me out to leave my dwelling place and thereafter, prevented me
from re-entering the building and return to my specific dwelling unit in the said building;
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Complaint-Affidavit for Grave Coercion& Illegal Tresspass
 That the accused took over my unit/dwelling place for his personal use despite my being a co-
owner of the building and as a matter of fact, the building in subject is declared in my name
and in the name of my late husband, Teodoro Salanga, Jr., as part of our conjugal properties;

That the accused in expelling me from my dwelling unit inside the Salanga Bldg., threw out all
my personal belongings outside my unit to my prejudice, detriment, and suffering;

That the accused took the law in his hand in expelling me to my legitimate dwelling place in
violation of my fundamental right to liberty of abode;

THE CRIME OF CRIME OF ILLEGAL TRESSPASS TO DWELLING WAS COMMITTED BY

THE RESPONDENT EDMER T. SALANGA ON THE PRIVATE COMPLAINANT AS
FOLLOWS:

9. That in the process of expelling me from my own dwelling unit inside the Salanga Bldg.,
through stealth, without my consent, and in my absence entered illegally into my own
dwelling unit forcing open the door lock to gain entry;

That as a result of his illegal trespass to my dwelling unit, he caused the removal of all
my personal things and room fixtures and threw it outside in a condition that rendered all my
personal stuff unfit for my personal use; and even my personal room fixtures and appliances
were moved-out and now in no condition to be used as it was and some are even missing,
which I cannot account properly considering that he had ordered the building guard not to
allow my entry into the premises;

10. On I reported the matter ____

Attached herewith are pictures of the property site which was taken over by the
accused and herein marked as ANNEXES “G” & series and hereby made integral parts hereof.

11. With the situation, on April 29, 2021, I went to the property myself only to find out that I am
also being restrained from coming in or gain entry to my property by the security guard who
mentioned that he was under instructions of the accused, EDMER T. SALANGA, and as a
consequence I am now very afraid to go near my property out of fear of harm from EDMER,
who by his past behavior, unceasingly harassed, intimidated, and threatened me coupled with
acts of violence which started since 2016 until to date;

The foregoing and subsequent acts of the accused (EDMER) in conspiracy with his co-
accused/respondents caused me so much pain and feel more threatened and fearful of my
life; that I feel anytime while inside my unit/room, the accused and/or his cohorts/co-
accused/co-respondents may come to harm me; that no one will ever know what happened
to me, if ever my fear will come true. To date, whenever I am home at night, I lock all my
doors and stay inside my room until daylight comes and it has been this way since May 1,
2021, when the accused EDMER first ordered to turn off the stairways/hallway light, which
persisted until the third week of May 2021 to my detriment and prejudice.

12. That I reported the matter to the Barangay Authorities and a copy of the Barangay Report
dated May 6, 2021 on the incident is herewith attached as ANNEX “H” and hereby made an
integral part hereof;

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Complaint-Affidavit for Grave Coercion& Illegal Tresspass
 Copy of the Police Report dated May 3, 2021 on the foregoing incidents is herewith
attached as ANNEX “K”, and copies of Tax Declaration No. 12-022-89761 of the Salanga
Building in our name, SPS. TEODORO N. SALANGA, JR. AND TRAN THI PHUONG LOAN
SALANGA and Tax Declaration No. 12-022-89760 of Lot No. 5761-A where Salanga Bldg, is
situated are attached herewith as ANNEXES “K-1” & ‘K-2”, respectively and hereby made
integral parts hereof.

However, for the purpose of filing this complaint, I did not secure anymore a Barangay
Certificate to File Action considering that grave coercion carries with it a correctional penalty,
such that the case is one of those exempted from the requirement to wit:

13. (iii) the crime has prescribed re: NPS Docket No. I-12-INV-210-00125-00127 (for which I
respectfully contends citing advice of counsel that the crime of grave coercion which carries
a correctional penalty prescribes in 10 years from the commission of the crime, thus
prescription does not apply to this complaint);

14. With the foregoing unconscionable acts of expulsion tantamount to grave coercion and illegal
trespass to my dwelling by the accused EDMER T. SALANGA committed directly against me
with deliberate intent to oust me from my dwelling place and possession of the same illegally
and in violation of my fundamental right to liberty of above and due process, I AM NOW
ACCUSING EDMER T. SALANGA THE CRIME OF GRAVE COERCION and ILLEGAL TRESSPASS TO
DWELLING in violation of Articles ___ and ___ of the Revised Penal Code, respectively and
committed as follows;

As advised by counsel, the crime of Grave Coercion is committed and penalized as

amended by R.A. No. 10591 as follows:

“xxx.

“Article 286. Grave coercion. – The penalty of prision correccional and a

fine not exceeding One hundred thousand pesos shall be imposed upon
any person who, without any authority of law, shall, by means of
violence, threats or intimidation, prevent another from doing something
not prohibited by law, or compel him to do something against his will,
whether it be right or wrong. (emphasis supplied as applicable to me)

xxx.”

Moreover, as further advised by counsel, illegal trespass to dwelling is committed as

follows:

“At the very instance the plotters agree, expressly or impliedly, to commit
the felony, and forthwith to pursue it actually.” (Revised Penal Code,
Article 8)

“In a conspiracy, there is a conscious design to commit an offense.

Conspiracy is not the product of negligence but of intentionality on the
part of cohorts (who decide to commit it).

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Complaint-Affidavit for Grave Coercion& Illegal Tresspass
 The criminal acts committed by the accused are aggravated by the following
circumstances to wit:

a. Insult and disregard due the offended party on account of her sex and committed in her
dwelling place. The private complainant is a widow and a woman, already ___ years old;
and in the twilight years of her life, who by any human relations standard deserves respect
from the accused and his insulting acts and disrespect were committed inside her dwelling
place;
b. Relationship. The private complainant is the biological mother of the accused; and

c. Acts of obvious ungratefulness and abuse of confidence of a son to his own mother. Res
ipsa loquitor, no other way to see it, the evidence speaks for itself.

MOREOVER, and in consideration of the damages suffered by the private complainant

relative to the acts committed by the accused and for which he is being charged with the crimes
described, HEREIN PRIVATE COMPLAINANT RESERVES THE RIGHT TO PURSUE/FILE A SEPARATE
CIVIL ACTION FOR DAMAGES AGAINST THE ACCUSED PURSUANT TO THE PROVISIONS OF THE CIVIL
CODE.

I am executing this Complaint-Affidavit to attest to the truth of the foregoing and to support
the filing of CRIMINAL CHARGES against EDMER T. SALANGA for the CRIMES of GRAVE COERCION
and ILLEGAL TRESSPASS TO DWELLING with the AGRAVATING CIRCUMSTANCES of INSULT AND
DISRESPECT as to circumstances of sex and age, committed inside my dwelling without my consent,
ABUSE OF CONFIDENCE AND UNGRATEFULNESS of a son to his own mother, and the alternative
circumstance of RELATIONSHIP; with liability to pay litigation costs, attorney’s fees, and cost of suit.

Other reliefs just and equitable under the premises are also prayed for.

FURTHER AFFIANT SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto set my hand this ___ day of ____________, 2021.

MARIE LOAN TRAN SALANGA, a.k.a.

THI PHOUNG LOAN TRAN SALANGA
Affiant / Private Complainant

SUBSCRIBED AND SWORN to before me this __ day of _______________, 2021 at

__________________, La Union Philippines, affiant exhibiting to me her competent evidence of
identity being her US Passport bearing Serial Nos. 519248743, issued by the US Department of State
on April 29, 2014, which expires on April 28, 2024.

I also attest that I have examined the affiant/private complainant and I am convinced that the
foregoing complaint is her own act and deed which she executed without being coerced by anyone.

____________________________
Prosecutor

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