Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch 12, Manila

EPIMACO VELASCO,
Complainant,

- versus - CRIMINAL CASE NO.

For: ROBBERY EXTORTION

NARDONG PUTIK,
Defendant.
x-------------------x

COMPLAINT-AFFIDAVIT

Complainant, by counsel, respectfully states that:

1. Complainant EPIMACO VELASCO is of legal age, single, Filipino citizen, and

a resident of España Boulevard, Sampaloc, Manila;

2. Defendant NARDONG PUTIK is of legal age, single, Filipino citizen, and a

resident of Dasmarinas, Cavite, where he may be served with Summons and other court
processes;

3. Complainant is a working law student who is bound via plane travel to Cagayan
De Oro to attend a pre-bar lecture week review.

4. On October 20, 2015, around 8:00am, Complainant arrived at NAIA Terminal 3

to check-in for his 9:00am departure to CDO.
 5. During the luggage inspection, Complainant passed the first x-ray scanners
without any problem. However on the second x-ray scanners, Complainant while waiting for
bags to come out from the x-ray conveyor, overheard the Airport Security Personnel Defendant
shouting for the owner of a black backpack.

6. Defendant instructed Complainant to pick up the bag and told to put it again in the
conveyor for another round of x-ray scan because Defendant claimed he saw something
prohibited. After that Complainant was told to unlock the backpack and take out all the contents.

7. After the Complainant took out the contents, Defendant started the inspection.
The latter placed his hand inside the bag and took out a piece of bullet.

8. Complainant felt shocked and anxious at the finding of the Defendant’s

inspection.

9. Defendant warned the Complainant of the latter’s forthcoming detention for

illegal possession of ammunition.

10. Complainant told the Defendant of the former’s willingness to cooperate with the
detention and go through the process of investigation to prove his innocence.

11. Defendant told the Complainant to keep it secretly among themselves and was
asked to sign a record book that the bullet was the Complainant’s anting-anting (amulet) and
later allowed the Complainant to board the plane without further harassment.

12. After the distressing experience at the airport, Complainant files against the
Defendant a complaint for Robbery Extortion under Article 293 and penalized under paragraph
5, Article 294 (as amended by Section 9, Republic Act No. 7659) both of the Revised Penal
Code.
 PRAYER

WHEREFORE, it is respectfully prayed that judgment be rendered ordering Defendant:

1. To pay Complainant the amount of ____________________________

2. To pay Complainant Attorney’s Fees amounting to ___________________

plus litigation expenses and costs of suit.

Other reliefs, just and equitable are likewise prayed for.

Makati City for the City of Manila, ___ December 2015.

By:

ATTY. RAPHAEL INNO B. PATAJO

Counsel for the Complainant
Roxas, Anonuevo, Patajo & Associates Law Offices
20th Flr., Ayala Alabang Bldg.
#41 Lantana St., Ayala Alabang
123-4567; 890-1234
IBP No. 04772 / Lifetime
PTR No. 8582433/01-19-07/Q
Roll No. 47553

V E R I F I C A T I O N and C E R T I F I C A T I O N OF
NON-FORUM SHOPPING

That I am the complainant in the above entitled case, that I have read the contents of the
said petition and that said contents are true and correct of my own personal knowledge.

EPIMACO VELASCO
Affiant