Pelagio, Graciela May R.

Trial Technique
2015-MJD-025
Judge Tita Alisuag

Republic of the Philippines

City of Manila s.s

COMPLAINT-AFFIDAVIT

I, Mrs. X, 35 years old, married to Mr. X, the deceased, a resident of 1321 Almar, Rlk.
4 Tondo, Manila hereby depose that:

1. Mr. X, the deceased is 40 years old, married to Mrs. X and a resident

of 1212 Laong Laan, Tondo Manila. The Defendant, Mr. Y, is of legal
age, single, residing at 1321 Almar, Rlk. 4 Tondo, Manila.
2. Last September 14, 2010, on or about 9:30 P.M husband Mr. X was at
the house of his officemate, Mr. A and was having a drinking spree to
celebrate the latters birthday.
3. Mrs. X, was informed by Mr. X through a text message that he will
arrive home late because the drinking spree had not yet started and
they are still waiting for their other visitors to be at Mr. As house
namely, Mr. W, Mr. Y and Mr. Z who were Mr. As former employees.
4. One of Mr. As friends who came later was Mr. Y who is a security
guard of Mr. As previous work place. Mr. Y is not a stranger to Mr. X
because Mr. A would often invite the former to certain occasions.
5. According to the statement by Mr. A, while having their drinking
session, at around 1 AM, he asked his visitors who among them will go
home and who will spend the night in his house, since everyone was
already intoxicated by alcohol. Mr. X, told Mr. A that he will needs to
go home since he informed Mrs. X that he will be home late. Mr. Y and
Mr. W also informed Mr. A that they need to go due to their duty the
following morning. Mr. As Affidavit is attached and marked as
ANNEX 1A

1 Affidavit of Mr. A

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Pelagio, Graciela May R.
Trial Technique
2015-MJD-025
Judge Tita Alisuag

6. At around, 1:30 AM, Mr. X, Mr. Y and Mr. W bid their good byes to
Mr. A and went out of the house.
7. According to the statement of Mr. W, while the three of them were
walking towards Mr. Xs car, Mr. Y told them that he needs to pee.
Several minutes have passed when Mr. Y appeared and unexpectedly
shot Mr. X using the latters gun. Mr. Ws affidavit is attached and
marked as ANNEX B"2

8. Mr. Y then hurriedly fled and Mr. W shouted Bumalik ka dito, bakit
mo sya binaril?

9. Thereafter, Mr. S, a tanod roaming at the area during that time heard
Mr. Ws outrage. Mr. S then called the policeman and the ambulance.
10. Moments later, Mr. X was brought to Wayadi Hospital but he was dead
on arrival due to severe blood loss because of the 3 gun shots in
located in his upper right arm, as evidenced by the medical report
conducted by the attending physician Dr. Kenneth Ilagan which is
attached as Annex 3C.
11. After Mr. Xs death, the policemen had several operations to locate Mr.
Y but he was nowhere to be found.
12. Mr. W immediately reported the incident at Marasbaras Police Station
which is the nearest police station. The original copy of the excerpt of
the police blotter duly issued by Senior Police Inspector Virgilio
Guimaras III of Marasbaras Police Station is hereunto attached and
made as an integral part hereof as Annex 4D of the complaint;
13. Mrs. X is executing this affidavit freely and voluntarily in support
filling a case for MURDER and/or the appropriate criminal case
against Mr. Y.

2 Affidavit of Mr. W

3 Medical Report

4 Blotter Report

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Pelagio, Graciela May R.
Trial Technique
2015-MJD-025
Judge Tita Alisuag

IN WITNESS WHEREOF, I have hereunto affixed my signature for and in behalf of

the complainant Mrs. X, Tondo, Manila this 22th day of September 2010, at Tondo,
Manila, Philippines.

Mrs. X

Affiant

SUBSCRIBED and SWORN to before me this 22nd day of Sptember 2010, at Tondo,
Manila. I hereby certify that I have personally examined the above-named affiant and
that I am satisfied that the foregoing statements were given by him voluntarily and of
his own free will.

Azrifa A. Mamutuk

Associate Prosecution Attorney II

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Pelagio, Graciela May R.
Trial Technique
2015-MJD-025
Judge Tita Alisuag

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