Complaint-Affidavit: Republic of The Philippines Department of Justice Office of The Prosecutor Quezon City

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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE PROSECUTOR
QUEZON CITY

PEDRO MILLENIO,
Complainant,

-versus-
I.S. No.________________
For: Serious Physical Injuries

JOHN DELA CRUZ,


Respondent.
x--------------------------------x

COMPLAINT-AFFIDAVIT

I, PEDRO MILLENIO, 27 years of age, single, a resident of Block 31

Lot 11, E. Jacinto Street, New Capitol Estates I, Diliman, Quezon City, after

having been sworn to in accordance with law, do hereby depose and state:

1. That this complaint is being filed to charge the Respondent for the

crime of SERIOUS PHYSICAL INJURIES under 263 of the Revised

Penal Code; states:

The crime of Serious Physical Injuries shall be


committed by any person who shall wound, beat, or
assault another.
STATEMENT OF FACTS

2. That I am a government employee assigned in the Bureau of Internal

Revenue – National Office at BIR Road, Diliman, Quezon City;

3. That on February 14, 2019 at around 6 o’clock in the evening while

I was heading home from work, walking in front of National Power

Corporation (NaPoCor), I met JOHN DELA CRUZ, a resident of No.

11, Timex St. Fairview, Quezon City;

4. That without warning, he suddenly attacked me with a baseball bat

while saying “Hayop ka! Ahas ka!”;

5. That despite being gripped to stop by the bystanders nearby, he still

kept on attacking me while shouting “Akin siya! Mang-aagaw ka!” ;

6. That due to the said incident, I suffered a 15 inch wound in my head, a

fractured left arm, fractured left leg and two (2) broken ribs due to the

severe beating, and has been hospitalized for 20 days and advised to a

complete rest for 4 weeks or more until my arm cast and leg brace will

be removed and my ribs will be completely healed.

7. That because of the injuries I suffered, I became incapacitated for labor

for more than 30 days.

8. I am executing this complaint-affidavit in order to file a case of Serious

Physical Injuries against JOHN DELA CRUZ.


9. All told, there is definitely probable cause to warrant the prosecution of

herein respondent. The crime is committed within the territorial

jurisdiction of Quezon City.

10. I am executing this sworn statement for the purpose of charging

respondent with having committed the crime of Serious Physical

Injuries under Article 263 of the Revised Penal Code.

Quezon City, Philippines, April 4, 2019.

JOHN DELA CRUZ


Affiant

SUBSCRIBED AND SWORN to before me this 4th day of April


2019. I hereby Certify that I have personally examined the affiant and I am
satisfied that he voluntarily executed and understood his complaint-affidavit.

EDUARDO MAGTANGGOL
Assistant Prosecutor

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