Republic Of The Philippines )

Pasay City )SS

COMPLAINT AFFIDAVIT
I, Virginia Pascua, of legal age, Filipino citizen, and a resident of 69 Virgin Village,
Quezon City, after having been duly sworn to in accordance with law, hereby
depose and say:

1. That I am formally charging Respondents Mr. Sam Cruz, of legal age,

single and a resident of 123 Malibo, Pasay City as evidenced by Annex ‘A’
and John Yap, of legal age, single, and a resident of 321 Manyaki, Pasay
City as evidenced by Annex ‘B’ with the crime of Forcible Abduction with
Rape punished under the Revised Penal Code;

2. That on or about 10:30 in the evening of the 3rd day of November, 2016, in
the City of Pasay, the said respondents, with lewd designs, did then and
there willfully, unlawfully and feloniously abducted me while I was driving
home with my maid, Helen Darna, from the TV Studio by means of force,
violence and intimidation by pulling me and forcing me to disembark
after bumping into my car with a gun pointed against me;

3. They succeeded in bringing me into their car which is a Toyota Fortuner

with plate number ABC 321, and brought me to an abandoned and
unoccupied building somewhere in Pasay City against my will;

4. That they forced me to dance in a pole while a gun is pointed against me

threatening to throw acid into my face and kill me should I disobey their
wishes;

5. They pulled my clothes off to nakedness, started to touch my private parts

and raped me successively while I was struggling and pleading for
freedom;

6. That with the foregoing factual backdrop, herein Respondents should be

held liable for FORCIBLE ABDUCTION WITH RAPE.

WHEREFORE, premises considered, it is most respectfully prayed unto this

Honorable Court that, after hearing, judgment be rendered ordering the
defendants to:

1. Pay moral damages;

2. Pay the Plaintiff the cost of the suit;
3. Such other relief that the court may deem proper.

City of Pasay, November 6, 2016.

ILDEFONSO-RAROS LAW OFFICE
Counsel for the Plaintiff
Unit 123, Loft Tower 1
Taft Avenue, Manila

By:
Jan-Jan Ildefonso
Roll of Attorney No. 11223
IBP No. 12345/1-2-11/Manila
 CERTIFICATION OF NON-FORUM SHOPPING

Republic of the Philippines )

City of Pasay ) ss

I, Virginia Pascua, of legal age, Filipino citizen, and a resident of 69 Virgin Village,
Quezon City, after having been duly sworn to in accordance with law, hereby
depose and say that:

1. I have not theretofore commenced any other action or proceeding or

filed any claim involving the same issues or matter in any court, tribunal, or
quasi-judicial agency and, to the best of my knowledge, no such action
or proceeding is pending therein;

2. if I should thereafter learn that the same or similar action or proceeding

has been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or quasi-judicial agency, I undertake to
report such fact within five (5) days therefrom to the court or agency
wherein the original pleading and sworn certification contemplated
herein have been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this 6th day of November at
Pasay City Philippines.

VIRGINIA PASCUA
Affiant

SUBSCRIBED AND SWORN to before me, this 6TH day of November, by Virginia
Pascua who exhibited to me her driver’s license no. E03-12-001234 issued at
Quezon City, Philippines on March 1 2013.

Notary Public
Doc. No. ________;
Page No. ________;
Book No. ________;
Series of 2016.