Republic of the Philippines REGIONAL TRIAL COURT 15th Judicial Region Branch 2 BUKIDON ARJEAN MARIE BELCO Plaintiff

-versusCivil Case No. 882313 For: RACIAL DISCRMINATION and DAMAGES

KLM AIRLINES(KUALA LUMPUR AIRPORT) Defendants *********************************************************************** COMPLAINT PLAINTIFF, through counsel and unto this Honorable Court, most respectfully states : 1. Arjean Marie Belco,plaintiff is of legal age, Filipino, single, and residing at Tinaytayan, San Miguel, Talakag, Bukidnon. Plaintif is a tribe member of Talaandig 2. That defendant KLM airlines is a foreign owned corporation, an International airport located in Malaysia. 3. Arjean Marie Belco, a member of the Talaandig tribe of Bukidnon, was on her way to Brazil for the World Youth Day, when she was stopped at the Kuala Lumpur Airport. Belco was not allowed to board her KLM Airlines connecting flight to Rio de Janeiro via Amsterdam July 20, at the Kuala Lumpur Airport where she arrived from Manila. 4. A KLM employee, whom the group identified as Mr. Shawa, claimed that Belco was not ready to travel and that he was doubtful despite Belcos documents. Shawa reportedly asked Belco why her passport was so new, why her ticket was cheap and purchased the day earlier and how much money she had. He also asked why

Belco was flying through Malaysia given direct flights to Rio de Janeiro in Brazil from Manila. 5. Belco, as well as Goodxorg, which phoned in, explained that it was her first trip abroad, and that she took a connecting trip because it was cheaper than a direct flight but while Goodxorg was explaining the situation, MR SHAWA was laughing and it was perceived as a possible case of discrimination based on appearance, gender, ethnicity, nationality, age or social status. 6. The incident left Belco stranded in Malaysia for two nights. It also prodded a Goodxorg official to fly to Kuala Lumpur from Manila to make sure that Belco will be allowed to fly out and treated properly. She was only able to fly out on JULY 22. 7. The plaintiff now seeks relief and indemnification for such delay caused plaintiff public humiliation, mental anguish, and sleepless nights that she suffered. She was deprived of her right to travel without justifiable cause.

PRAYER WHEREFORE, it is respectfully prayed that judgment be rendered in favor of plaintiff and against defendants: 1. Ordering defendant to pay plaintiff moral damages in the sum of P50,000.00 and exemplary damages of P30,000.00; 2. Ordering defendant to pay plaintiff attorneys fees in the sum of 20,000 and 3. Ordering defendant to pay the litigation expenses and cost of suit. Plaintiff prays for other relief just and equitable. Bukidnon, Philippines, july 28, 2013.

ARJEAN MR. ARJEAN MARIE BELCO Plaintiff

ASSISTED BY COUNSEL ;

Santuyo
ATTY. Santuyo Kenneth D 35 CAPADOCIA UNIT 3, MULTINATIONAL VILLAGE SUCAT, PARANAQUE CITY PTR NO888522-0324 IBP LIFE MEMBER ROLL NO. 253595

Republic of the Philippines) City of Bukidnon..)ss. VERIFICATION AND CERTIFICATION I, Arjean Marie Belco, of legal age, and resident Tinaytayan, San Miguel, Talakag, Bukidnon. upon my oath declare : That I am the plaintiff in the above-entitled case. That I have caused the preparation of the foregoing Complaint. That I have read and understood the contents thereof, and they are true and correct in my own knowledge and belief. That I hereby certify that, I (a) have not theretofore coomenced any other action or proceeding involving the same issue in the Supreme Court, Court of Appeals, or any tribunal or agency; (b) to the best of my knowledge, no such action or proceeding is pending in the Supreme Court, Court of Appeals, or any other tribunal and or agency; (c) if there is any such action or proceeding which is either pending or may have been terminated, I must state the status thereof; and (d) if I should thereafter learn that a similar action or proceeding has been filed or is pending before the Supreme Court, Court of Appeals, or any tribunal or agency, I undertake to report the same within 5 days thereform to the court or agency wherein filed. IN TESTIMONY THEREOF, I have hereunto affix our signature this _____ARJEAN_____, at Bukidnon, Philippines.

ARJEAN ARJEAN MARIE BELCO Affiant SUBSCRIBED AND SWORN to before me this 28th day of july 2013 at Bukidnon Philippines, affiants having exhibited to me their Community Tax Certificate Number 8812312 issued at Bukidnon.

Doc. No. _20__; Page No. _30__; Book No. _40__; Series of 2013.