REPUBLIC OF THE PHILIPPINES)

CITY OF MANILA )S.S.

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

COMPLAINT-AFFIDAVIT

I, MALAN DIDAW, of legal age, single, Filipino citizen, and a

resident of 123 Tomorrowland, Plur St., Malate, Manila, Philippines,
do hereby state under oath that:

1. I am a DJ (disc jockey) and Music Producer based in Manila,

Philippines having just accepted a contract for three (3) years under
It’s Lit Man Productions on April 23, 2016.

2. I accuse and hereby charge MS. TAK LESA, residing at 5

Badroll, Ultra St., Makati, of violating Article 358 of the Revised Penal
Code (Slander and Oral Defamation), committed against me when
she publicly, maliciously and deliberately uttered defamatory remarks
against me.

3. The acts complained were committed as follows:

a. On the evening of May 3, 2016, I had a DJ gig at The

Palasyo Bar in Taguig City. While I was busy spinning
records, Tak Lesa went to the stage and grabbed the
microphone from MC Palo and started uttering “Sarap
maging DJ, right? Is it as good as fucking around with all
of your bosses? Hands to you, girl! You’re really willing to
do anything just to be in the business. You aren’t even
that good! Now that’s what you call a fame whore!
Everyone, let’s give it up for our bad bitch DJ in town!!!”.

b. Other than the fiasco she made, I was informed by my

colleagues in the music industry that there were rumors
circulating about me being the mistress of the President of
the It’s Lit Man Productions, Mr. Music Islife. The said
rumors were purportedly started by Tak Lesa when It’s Lit
Man Productions did not renewed her contract in order to
make room for me in the production company.

4. Ms. Tak Lesa’s remarks, falsely saying that I have illicit

sexual relationships with several married men uttered in public are
clearly insulting and defamatory as they malign me and attribute to
me a criminal act, nature and predisposition. There is, moreover, no
doubt that Ms. Tak Lesa’s malicious spreading of rumors against me
was deliberate as her explanation and clarification a few utterances
thereafter would show. Ms Tak Lesa’s remarks are also very serious
as they cast aspersions on my reputation, line of business, character
and very person before my peers, fans, and fellow artists.

5. Mr. Tak Lesa’s remarks have injured my name, reputation

and character before my colleagues and fans. By reason of the
foregoing, I suffered sleepless nights, wounded feelings, moral
and social embarrassment which Ms. Tak Lesa should
compensate by way of damages which is the natural, proximate
and necessary result of the malicious utterances in the amount
of not less than Fifty Thousand Pesos (PhP 50,000.00).

6. While my name, reputation and character are incapable of

pecuniary estimation as these are the result of a lifetime’s effort to
build a name, reputation and character that my future descendants
can be proud to bear, Ms. Tak Lesa cannot be allowed to simply go
scot-free without bearing the consequences of her acts. For this
reason, I am also holding TAK LESA liable civilly for defaming
me in the amount of One Hundred Thousand Pesos
(P100,000.00) in nominal damages and Fifty Thousand Pesos
(P50,000.00) in exemplary damages;

7. That I am executing this affidavit to attest to the truth of the

foregoing averments and for the purpose of criminally prosecuting
said TAK LESA for ORAL DEFAMATION/ SLANDER as there grave
utterances as determined by the Prosecution Office in the Preliminary
Investigation.

IN WITNESS WHEREOF, I have hereunto affix my signature

this 14th day of May 2016 in Manila, Philippines.

MALAN DIDAW
Affiant

SUBSCRIBED AND SWORN to before me this 14th day of May

2016 in the City of Manila. I hereby certify that I have personally
examined the above-named affiant and that I am satisfied that the
foregoing statements were given to her voluntarily and of his own free
will.

--------------------------------------
Administering Officer
REPUBLIC OF THE PHILIPPINES)
CITY OF MANILA )S.S.
x--------------------------------------x

VERIFICATION AND CERTIFICATE

OF NON-FORUM SHOPPPING

I._____________________________________________, of legal
age, (Name) _____________________________
_______________________, and a resident (citizenship) (civil status)
of
_______________________________________________________
________, after having been duly sworn to in accordance with law,
hereby, depose and say:

1. That I am the ____________________in the above-entitled

case and have caused this
___________________________________ to be prepared;
that I read and understood its contents which are true and
correct of my own personal knowledge and/or based on
authentic records;

2. That I have not commenced any action of proceeding involving

the same issue in the Supreme Court, the Court of Appeals or
any other tribunal or agency;

3. That to the best of my knowledge, no such action or proceeding

is pending in the Supreme Court, the Court of Appeals or any
tribunal or agency, and that, if I should learn thereafter that a
similar action or proceeding has been filed or is pending before
these courts of tribunal or agency, I undertake to report that the
fact to the Court within five (5) days therefrom.

IN WITNESS WHEREFOR, I have hereunto set my hand this

____ day of __________________,20____.

_________________________
Affiant

SUBSCRIBED AND SWORN to before me this______day of

_______________, 20_____ .

Doc. No._____
Page No._____ NOTARY PUBLIC
Book No. _____
Series of 2018