Republic of the Philippines

REGIONAL TRIAL COURT

Angeles City, Pampanga
Branch 1, Angeles City

PEOPLE OF THE PHILIPPINES

Criminal Case No: 12345
-versus- For: RAPE (Article 266-A, paragraph 1
of the Revised Penal Code, as amended)
Juan Manyak,
Accused.
x------------------------------------x

INFORMATION

The undersigned City Prosecutor accuses Juan Manyak, a resident of 1234

Sampaguita St., Salapungan, Angeles City, Philippines of the crime of RAPE, defined
and penalized under Article 266-A, par. 1, as amended, committed as follows:
That on January 12, 2019, at the accused’ apartment unit at 1234 Sampaguita St.,
Salapungan, Angeles City, Philippines, the above-named accused, did then and there,
willfully, unlawfully and feloniously raped the person of Amanda Paige, by inserting his
penis into the complainant’s vagina while the complainant is sleeping/unconscious.
That the accused invited the complainant to drink some beer along with a few
friends to celebrate his promotion and after a few shots the complainant felt dizzy and she
decided to lie down on his bed. That the complainant woke up due to the painful
sensation in her vagina and there saw accused undressed and having sexual intercourse
with her and due to the Accused’ superior strength all she was able to do was to clutch
tightly and painfully pull complainant’s hair with his other hand, while he performs the
sexual act.
That the accused placed a kitchen knife directly on the complainant’s throat and
warned her not to tell anyone about the incident or else he would come back to kill the
complainant.
That as a result of said rape, the victim suffered actual and moral damages in the
amount as may be awarded by Honorable Trial Court under the Provisions of the New
Civil Code.

CONTRARY TO LAW.
Angeles City, Pampanga, Philippines, January 18, 2019
 Atty. Ivan Manaligod
City Prosecutor

I hereby certify that a preliminary investigation have been conducted in this case,
the witnesses having been examined under oath; that on the basis of the sworn statement
and other evidence submitted before me, there is reasonable ground to believe that the
offense charged was committed.

Subscribed and sworn to before me this 19th day of January 2019, in Angeles
City, Philippines.

WITNESSES:

Rochelle Pangilinan – Angeles City, Philippines

Jopay Paguia – Angeles City, Philippines
Police Chief Inspector Rodrigo C. Dela Cruz- Angeles City Police Station 1, Philippines
BAIL RECOMMENDED: NONE

APPROVED
City Prosecutor Roll No. 921122
MCLE Compliance No. IV - 0000126

Address of Accused: 1234 Sampaguita St., Salapungan, Angeles City, Philippines

CERTIFICATE OF PRELIMINARY INVESTIGATION

I
I hereby certify that a preliminary investigation in this case was successfully conducted
by me in accordance with law; that I examined the Complainant and her witnesses; that
there is reasonable ground to believe that the offence charged had been committed and
that the accused is probably guilty thereof; that the accused was informed of the
Complaint and the evidences submitted against him and was given the opportunity to
submit controverting evidence; and that the filing of this information is with the prior
authority and approval of the City Prosecutor.

Atty. Ivan Manaligod

City Prosecutor
SUBSCRIBED AND SWORN TO BEFORE ME this 19th day of January 2019 in
Angeles, Philippines.

Atty. Ivan Paul J. Manaligod

City Prosecutor

Bail Recommended: 0
 Republic of the Philippines
REGIONAL TRIAL COURT
Angeles City, Pampanga
Branch 1, Angeles City

PEOPLE OF THE PHILIPPINES

Complainant

Criminal Case No: 12345

-versus- For: RAPE (Article 266-A, paragraph 1
of the Revised Penal Code, as amended

JUAN MANYAK
Respondent

X-----------------------------------------------------x

COMPLAINT - AFFIDAVIT

I, Amanda Paige, of legal age, Filipino citizen, Single, residing at 123 Dahlia St.
Baranggay Lourdes Sur, Angeles City, Pampanga, Philippines, after having duly sworn to
in accordance with law do hereby depose and say:

(1) That I am the complainant in this case;

(2) That I am formally charging respondent Juan Manyak, with postal address at no.
1234 Sampaguita St., Salapungan, Angeles City, Philippines, for the crime of
RAPE penalized under Article 266-A, par. 1 of the Revised Penal Code, as
amended, committed as follows, to wit:

(a) That at around 7:00 pm in the evening of Saturday, January 12, 2019, I
was in my apartment at 123 Dahlia St. Baranggay Lourdes Sur, Angeles
City, Pampanga when herein accused called me and said that he was
promoted as a training specialist at the BPO company where he works;

(b) That after hearing the news he invited me along with two other friends for
some drinks at his apartment;

(c) That I have known the accused for 3yrs already as he and I worked on a
same BPO company before;

(d) That because of our friendship and trust in his person I complied with his
invitation and at around 8:00pm the same evening we went to a nearby
seven eleven to buy the beers;

(e) That at around 11:00pm after drinking a few bottles of beer I suddenly felt
dizzy and decided to lie down the nearby bed which is the bed of the
accused;

(f) That after falling asleep I felt rather odd sensations around my body but
chose to disregard it because I was dizzy;
 (g) That after a few minutes from that incident I felt a searing pain on my
vaginal area which caused me to wake up;

(h) That after waking up I saw the accused and myself along inside the room
along with my shirt lifted up and my underwear removed;

(i) That the next I saw was the accused on top of me penetrating my vagina
and violently humping me which caused me to struggle;

(j) That because of the accused superior strength I wasn’t able to prevent him
from having carnal knowledge with me;

(k) That after the said incident while I was gathering my clothes he pointed a
knife at my throat while uttering the words that no one should know about
anything that happened that night because if I did he will hurt not only me
but my entire family;

(l) That after the said incident I immediately went to my parents to tell them
what happened;

(m)That despite his threats I came to a decision to file a criminal case against
the Juan Manyak for RAPE.

(3) That I am executing this affidavit to attest to the truth of the foregoing statements,
and for the purpose of charging respondent JUAN MANYAK for the crime of
RAPE penalized under Article 266-A, par. 1 of the Revised Penal Code, as
amended

IN WITNESS WHEREOF, I have hereunto affixed my signature this 19th day of

January 2019, in the City of Angeles.

AMANDA PAIGE
Complaint/Affiant

SUBSCRIBED AND SWORN TO before me this 19th day of January 2019, in

Angeles City.

Atty. Ivan Paul J. Manaligod

City Prosecutor

CERTIFICATION

I hereby certify that I personally examined the affiant and that I am satisfied that
he voluntarily executed and understood his complaint-affidavit.

Atty. Ivan Paul J. Manaligod

City Prosecutor
 Republic of the Philippines
REGIONAL TRIAL COURT
Angeles City, Pampanga
Branch 1, Angeles City

PEOPLE OF THE PHILIPPINES,

-versus- Criminal Case No: 12345

For: RAPE (Article 266-A,paragraph 1
of the Revised Penal Code, as amended)
JUAN MANYAK,
Accused.
x------------------------------------------------x

NOTICE OF ARRAIGNMENT AND PRE-TRIAL

TO:
JUAN MANYAK,
1234 Sampaguita St., Salapungan, Angeles City, Philippines

AMANDA PAIGE
123 Dahlia St. Baranggay Lourdes Sur, Angeles City, Pampanga, Philippines

G R E E T I N G S:

Please be informed that the arraignment of the accused and the pre-trial in the
above-entitled case has been set on January 21, 2019 at 5:30 PM at the RTC Branch 1,
Angeles City, Pampanga and that the pre-trial conference may take place thereafter to
consider the following:

1. Plea bargaining
2. Stipulation of facts
3. Marking for identification of the parties
4. Waiver of objections to admissibility of evidence
5. Such other matters as will promote a fair and expeditious trial; and
6. Determination of civil liability, if any.

The accused must be present at the arraignment and personally enter his plea. In
case of failure of the complainant to appear despite due notice, the Court may allow the
accused to enter a plea of guilty to a lesser offense with the conformity of the trial
prosecutor alone.

The accused and the complainant are further directed to bring all documents
relevant to the case.

FAIL NOT UNDER PENALTY OF THE LAW.

 WITNESS, the HON. GENIE BARON ABELEDA, Presiding Judge of this Court,
th
this 18 day of January 2018 at Angeles City, Philippines.

Kim Domingo
Legal Researcher II/OIC

1ST INDORSEMENT

Respectfully referred to the PROCESS SERVER OF THIS COURT for service

and return. Please make your return before the scheduled date of hearing.

Kim Domingo
Legal Researcher II/OIC
 Republic of the Philippines
DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
City of Angeles

PEOPLE OF THE PHILIPPINES

Criminal Case No: 12345
-versus- For: RAPE (Article 266-A, paragraph 1
of the Revised Penal Code, as amended)
Juan Manyak,
Accused.
x------------------------------------x

RESOLUTION

This resolves the complaint for RAPE against Respondent JUAN MANYAK filed
by Complainant AMANDA PAIGE.

In support of its complaint, herein Complainant attached the following documents:

1. Complaint affidavit executed by the complainant Amanda Paige. (ANNEX “A”)

2. Medico Legal Certificate showing lacerations on the complainants vaginal orifice

showing the use of force during the sexual penetration issued by Dr. Juan Manuel.
(ANNEX “B”)

3. Photos of victim’s bruises which shows that the accused forced his way into the
victim. (ANNEX “C”)

4. Photos of the vaginal Laceration that shows that the victim had sex against her
will(ANNEX “D”)

After all considerations the Office of the City Prosecutor found out that during the
evening of Saturday, January 12, 2019 at around 7:00 pm, while the complainant was in
her apartment at 123 Dahlia St. Baranggay Lourdes Sur, Angeles City, Pampanga the
herein accused called her via mobile phone and invited the complainant for some drinks
in accused’ apartment building at 1234 Sampaguita St., Salapungan, Angeles City,
Philippines along with two (2) of her friends. That same night, the herein accused forced
his way and there and then willfully, unlawfully and feloniously raped the person of
Amanda Paige, by inserting his penis into the complainant’s vagina while the
complainant is sleeping/unconscious.

In the commission of Rape as defined under Article 266-A of the Revised Penal
Code, as amended, is committed by any man who shall have carnal knowledge of a
woman under any of the following circumstances a) Through force, threat, or
intimidation; b) When the offended party is deprived of reason or otherwise
unconscious; c) By means of fraudulent machination or grave abuse of authority;
and d) When the offended party is under twelve (12) years of age or is demented,
even though none of the circumstances mentioned above be present or By any person
who, under any of the circumstances mentioned in paragraph 1 hereof, shall commit an
act of sexual assault by inserting his penis into another person's mouth or anal orifice,
or any instrument or object, into the genital or anal orifice of another person.
 Based on the foregoing, the undersigned finds that there is probable cause to
charge respondent JUAN MANYAK for RAPE under Article 266-A, paragraph 1. Juan
Manyak forced himself inside Amanda Paige and raped her while she was deprived of
reason or otherwise unconscious.

WHEREFORE, it is most respectfully recommended that an Information for

RAPE under Article 266-A, paragraph 1 be filed against JUAN MANYAK before the
Regional Trial Court of Angeles City, Philippines. No bail recommended.

Angeles City, Philippines, 18th January 2019.

IVAN PAUL J. MANALIGOD

City Prosecutor Roll No. 921122
MCLE VI-0000126/1-26-2018

Copy Furnished:
AMANDA PAIGE
123 Dahlia St. Baranggay Lourdes Sur, Angeles City, Pampanga, Philippines
 ANNEX “B”

Republic of the Philippines

Province of Pampanga
Cza Cza Padilia Health Clinic
Angeles City, Pampanga

MEDICAL CERTIFICATE

1/20/2019

To whom it may concern:

THIS IS TO CERTIFY THAT AMANDA PAIGE of 123 Dahlia St. Baranggay

Lourdes Sur, Angeles City, Pampanga, Philippines was examined and treated at the Cza
Cza Padilia Health Clinic on January 20, 2019 with the following diagnosis:
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

And would need medical attention for ________________________ days barring

complication.

Dr. Juan Manuel M.D.

Attending Physician
 ANNEX “C”

Photos of the victim’s bruises after the herein crime

ANNEX “D”

Vaginal Lacerations of the victim