REPUBLIC OF THE PHILIPPINES )

PROVINCE OF ALBAY )
) s.s.

COMPLAINT-AFFIDAVIT

I, ----------, of legal age, single/married, Filipino citizen, a resident of

----------, Philippines and currently holding the position of ---------- with office
address at -------, after having been duly sworn to in accordance with law,
hereby depose and state that:

1. I hereby formally charge -------------, single/married, Filipino citizen

and a resident of ______________________, of the crime of Online Libel
defined and penalized under Section 4(C) 4 of R.A. No. 10175 also known as
the Cybercrime Prevention Act of 2012;

2. Respondent caused the publication of malicious, demeaning, and

defamatory imputations, published for all to see through her Facebook
account, by posting and/or commenting the following:

“Dito nga po sa LTFRB region ----- noong 2017 tinanggal na

itong sa -------------- dahil sa kurapsyon ngayong 2023 ibinalik na
naman nagumpisa naman mangutong dito sa LTFRB RO---.”
xxx
“Sir Mar sana magkausap tayo kahit sa CP kc dito sa LTFRB
region---- talamak din ang kurapsyon dito pati ung tinanggal dito na
empleyado noong 2017 na si ------- dahil currupt ibinalik na naman
dito ngayon.”
xxx
“Dito po sa LTFRB region------ 1,000 pesos ang presyo ng PA per
unit ang special permit out of line 1,500.”
xxx
“Ung tinanggal na employee dito sa LTFRB region ----- noong
2017 na si --------- dahil napaka currupt ibinalik na naman dito at
nagumpisa na naman mangutong dito sa amin ngayon.”
xxx
“Tama sir dito sa LTFRB region --- marami nyan. Ito ngang si
---------- ang ipinapakain sa pamilya ay ung kinurakot sa mga
operator ng POV. Tinanggal na ito dito noong 2017 dahil sa
kurapsyon nagpalit lang ng presidente nakabalik na naman.”

3. The foregoing posts and/or comment published by the respondent

contained malicious imputations with devious design and evil motives,
purposely made to malign, dishonor, discredit, and insult my character and
reputation as a respectable person and public officer, as well as to my
neighbors and colleagues;

4. As can be gleaned from the above-quoted posts and/or comment,

the respondent was clearly and ultimately motivated with the evil design in
putting my “complete name” in opprobrium, disgrace or dishonor. In fact,
the respondent is the same person who instituted a false and baseless
administrative case and is now pending before the Office of the
Ombudsman. Clearly, the respondent has the intention to injure my
reputation as a public officer;

5. The afore-quoted excerpts of online posts and/or comments

authored and published by the respondent cast aspersion in the minds of
the readers, such as (name of witness 1 and 2), that I am a corrupt and a
terrible public officer. A copy of the Sworn Statement of Witness is hereto
attached and made an integral part hereof and marked as Annex “__”;;

6. Moreover, the said posts and/or comments posted and published

by the respondent, and so with the administrative case filed before the
Office of the Ombudsman, are highly speculative and contains false
statements consciously and deliberately made to destroy my reputation,
integrity and character as a person as well as to my family and the
Government office, LTFRB, where I am working with. The respondent is
motivated by bad faith in publishing the said posts online to defame,
embarrass and discredit me to the public, to my colleagues, friends, family,
and to the readers and patrons of Facebook;

7. Assuming without admitting that I committed any undesirable acts

whatsoever against the respondent, the same was based on legal and
moral ground such as but not limited to unheeded illegal demand or
request of the respondent from the office, LTFRB. This alone should not be
a license for respondent to destroy my name and my reputations as well.
The respondent has no good intention or any justifiable motives
whatsoever when he repeatedly posted and/or commented online the said
defamatory imputations;

8. The libelous posts and/or comments having been published

through Facebook, a social media website accessible to and is made
available to the public was in fact read by many, including my colleagues,
friends, and family, among others. The same was, without any taint of
doubt, directly imputed by the respondent against me when he made
mentioned of my complete name. The said posts and/or comment earned
numerous likes and comments as shown in the foregoing annexes;
 9. Owing to the said malicious public imputations by the respondent,
I, and my family, suffered and continue to suffer serious anxiety,
besmirched reputation, mental anguish, sleepless nights, not to mention
the damage he has caused to my reputation and honor as a good and
respectable public officer of LTFRB among the readers, patrons of Facebook
and the public;

10. Because of the unbearable effects of the malicious imputations

caused by the respondent against me, I reported the matter to the
Philippine National Police Anti-Cybercrime Group, Regional Anti-
Cybercrime Unit in Legazpi City. Copy/ies of the police blotter under Entry
#_______ and Entry #_________ are hereto attached and made an integral
part hereof and marked as Annexes ______, respectively;

11. Police officer ____________ of the Philippine National Police

Anti-Cybercrime Group, Regional Anti-Cybercrime Unit confirmed that the
libelous posts and/or comment were indeed authored and originated from
the Facebook account of the respondent “_______________” with
URL:________________. A copy of the ______________________ is hereto
attached and made an integral part hereof and marked as Annex “___”;

12. Due to such grossly unjustified malicious and libelous

imputations, I therefore pray that the respondent is made to pay the
damages I was made to suffer because of the online published article in
whatever amount the Honorable Office or Court deems sufficient and
proper together with the attorney’s fees and the cost of this suit;

13. I have read and understood the allegations in this Complaint-

Affidavit, the same being true and correct of my own personal knowledge
and based on authentic records herein attached; and

14. I hereby execute this affidavit to attest to the truth of the

foregoing facts and hereby request the investigating officer to file the crime
of Online Libel under R.A. 10175 and other crime or crimes committed
against the herein respondent who may be served with a subpoena and
other processes of this Honorable Office at __________________.

IN WITNESS WHEREOF, I have hereunto set my hand this

_______________ in____________________, Philippines.

___________________________
------------
Affiant/Complainant
 SUBSCRIBED AND SWORN to before me this _____________
at__________________. I hereby certify that I have examined the affiant
and that I am fully satisfied that he has voluntarily executed and
understood the contents of his Complaint-Affidavit.

Administering officer