REPUBLIC OF THE PHILIPPINES

Office of the City Prosecutor

City of Tagaytay

Fatima Saquilayan,
Complainant, Criminal Case No. 3456789
For: Murder
-versus-

Aristotle Cruzate,
Respondent.
x-------------------------------------------x

COMPLAINT-AFFIDAVIT
I, Fatima Saquilayan, of legal age, Filipino, married and a resident of #123 Sesame Street,
Gen. Trias, Cavite, after having been duly sworn to in accordance with law, hereby deposes and
states THAT:
1. I am the wife of Ian Ben Saquilayan, the victim;
2. On May 7, 2019, on or about 11:35 P.M., my husband, Ian Ben Saquilayan, was about
to fetch our son, Wilbur Saquilayan who was with his friend, Aira Camille Alfaro, 21
years old, single, and a resident of #124 Sesame Street, Gen. Trias, Cavite. Ian Ben got
the keys of the car and left our house when Wilbur called him that they were almost
near at the waiting shed of our street, and he was bringing lots of his things from his
vacation and asked if his father could come and fetch him to help him bring home his
things;
3. I received a message from my husband at exactly 11:45 P.M. telling me that Wilbur
was not yet there at their meeting place and told me to cook for dinner of my son and
his friend. At 12:08 A.M. of May 8, 2019, my son then texted me that they were about
to get off from the bus and that they already saw his father waiting. Right after I
received the message of my son, I immediately left the house and planned to buy food
at the Alfamart which was two houses away from the waiting shed where my husband
and my son was about to meet up;
4. While I was on my way to Alfamart, I heard a commotion at a near distance, which
was followed by shouting and crying so I immediately went to the place. Upon my
arrival, I saw my husband lying on the ground, catching his breath, bathing in his own
blood, with my son loudly shouting and crying for help. Trembling and lost for words,
I asked Aira Camille Alfaro who was the culprit of the crime which she answered
without hesitation as one named Aristotle Cruzate, and told me that they have clearly
saw Cruzate stabbing my husband at the chest when they were about to cross the street
and approach my husband;
5. I, along with Wilbur and Aira, brought immediately Ian to Gentri Doctors. But at
around 12:28 A.M. of May 8, 2019, Ian was declared dead on arrival by one of the
physicians therein. Attached herewith is the Death Certificate of Ian and made an
integral part of this complaint as Annex A;
6. I reported the said incident to the nearest police station. A police officer from Gentri
Police Station informed me thereafter that the accused was seen at the CCTV footage,
apprehended them and they locked Cruzate in their station;
7. I am therefore executing this Complaint-Affidavit freely and voluntarily in support of
my intent to file a case for Murder against Aristotle Cruzate, who is of legal age and a
resident of #122 Sesame Street, Gen. Trias, Cavite, Philippines;
 IN WITNESS WHEREOF, I have hereunto set my hand this 10th day of May 2019 at
Gen. Trias, Cavite, Philippines.

FATIMA SAQUILAYAN
Complainant

SUBSCRIBED AND SWORN TO before me this 10th day of May 2019 at Gen. Trias,
Cavite, Philippines, and I further certify that I have personally examined the complainant and I am
satisfied that she has read and personally understood the contents of this foregoing “Complaint-
Affidavit.”

BEATRICE PRIOR
Prosecutor
 REPUBLIC OF THE PHILIPPINES
Office of the City Prosecutor
City of Tagaytay

Fatima Saquilayan,
Complainant, Criminal Case No. 3456789
For: Murder
-versus-

Aristotle Cruzate,
Respondent.
x-------------------------------------------x

COUNTER-AFFIDAVIT
I, Aristotle Cruzate, of legal age, Filipino, single and a resident of #122 Sesame Street,
Gen. Trias, Cavite, after having been duly sworn to in accordance with law, hereby deposes and
states:
1. That I am the accused in Criminal Case No. 3456789 for the crime of murder under
Article 248 of the Revised Penal Code;
2. On May 7, 2019, on or about 11:20 P.M., I left my house with my friend, Efren
Peñaflorida, to go to the wake of our best friend in Dasmariñas, Cavite. While we were
walking, Ian Ben, the victim, approached us and asked us where are we going. I told
him that we will be going to the waiting shed to ride on a jeepney to Dasmariñas. Ian
Ben told us to get on his car so that we will not get tired of walking. We rode on his car
and we asked him thereafter on where he was going. He told us, “Susunduin ko lang si
Wilbur dahil maraming dala galing sa bakasyon. May kasama siyang babae. Marami
na siyang pera kaya palagay ko ay mag-aasawa na. Pasensya ka na noong niloko ng
anak ko ang anak mo.” We were sharing stories about our son and daughter. At exactly
11:45 P.M. on the same date, Efren and I got off from his car;
3. Efren and I were waiting for a jeepney to arrive when we saw Ian Ben talking to Mark
Alfaro, the father of Aira Camille Alfaro and told him, “Walanghiya ka! Kinuha ng
anak mo ang anak ko at ngayon pati ang asawa ko kinuha mo na rin.” We hid from one
of the posts of the streets because we were afraid to be involved in their argument. We
have clearly seen that Ian punched the man and said “Hindi ko kasalanan kung hindi
ka na niya mahal.” Mark then got a knife and stabbed Ian at the chest. We immediately
approached them but Mark ran away;
4. I accidentally hold the knife as I was helping Ian and asking for help when Wilbur
shouted and called his father. He punched me and asked me, “Anong kasalanan ng tatay
ko sa’yo?” I tried to explain but Aira already called the police. Afraid that Wilbur might
do something from me because of what happened, I ran away from the streets;
5. That Mark Alfaro has a resemblance to me as we have the same build and facial features
and we were both wearing a black shirt which made the police officers caught me as
they thought I was the one at the CCTV footage;
6. That the allegations in the Complaint-Affidavit are false and it was physically
impossible for me to commit the crime charged because if I had the intention to kill
Ian, I would have done it while I was riding on his car;
7. That I am executing this Counter-Affidavit freely and voluntarily for the purpose of
attesting the truth of the foregoing statements, to inform the proper authorities of the
above facts, to support my prayer for the dropping or dismissal of the instant case
against me and for whatever purpose this may serve best.
 IN WITNESS WHEREOF, I have hereunto set my hand this 11th day of May 2019 at
Gen. Trias, Cavite, Philippines.

ARISTOTLE CRUZATE
Respondent

SUBSCRIBED AND SWORN TO before me this 10th day of May 2019 at Gen. Trias,
Cavite, Philippines, and I further certify that I have personally examined the respondent and I am
satisfied that he has read and personally understood the contents of this foregoing “Counter-
Affidavit.”

ATTY. JOHN AMBAGAN

Counsel for the Accused