Sample Complaint

MEMORANDUM

FOR

Chief Prosecutor NAME Cebu City Prosecutors Office

Hall of Justice, Cebu City

FROM

OFFICER NAME

TITLE

RANK

SUBJECT

Criminal Complaint, RA 9208

DATE

Sir:

Respectfully submitting to your good office a criminal complaint for Violation of Section 4, paragraph A and E, in relation to Section 6, paragraph A & C [minority, large scale and syndicated] of Republic Act No. 9208, otherwise known as the Anti-Trafficking in Persons Act of 2003, against SUSPECT NAME, GENDER, CIVIL STATUS, AGE, residing in _______, and SUSPECT NAME, GENDER, CIVIL STATUS, AGE, residing in _______. A. Case Summary

[Statement of operation details, including time, date, commanding agents and agencies/organizations involved, name of target establishment/persons, address of operation, details of the service and implementation of search warrant with search warrant numbers, issuing judge, issuing court and its location (city), witnesses of search warrants implementation, and statement of recovery of evidence from target establishment.] Example: On or about TIME, DATE, NAME OF AGENCY led by NAME OF OFFICER, under the direct supervision of NAME OF SUPERIOR OFFICER, Police Regional Office ___, the Ground Commander during the conduct of raid; together with AGENCY led by NAME OF OFFICIAL (if applicable), representatives from Department of Social Welfare and Development (DSWD[1]) led by NAME OF OFFICIAL and a representative from National Inter-Agency Council Against Trafficking (NIACAT), NAME OF OFFICIAL (if applicable), conducted a joint Anti-Human Trafficking Operation (Entrapment and Rescue Operation) at

NAME OF ESTABLISHMENT, ESTABLISHMENTS ADDRESS, which was immediately followed by the service and implementation of a search warrant, with Search Warrant number XXXX-XXXX-XX-XX dated DATE, issued by Honorable JUDGE NAME, Presiding Judge, COURT & LOCATION, on or about TIME of DATE. The implementation of the search warrant was witnessed by NAME AND POSITION (ex. Councilor _____, Barangay Councilor of Barangay _____, Cebu City) and NAME OF ESTABLISHMENTS counsel, Attorney ATTORNEYS NAME, which resulted in the recovery of pieces of evidence recovered within the premises of ESTABLISMENTS NAME.[2] The entrapment operation resulted in the arrest of the following respondents:

1. NAME, GENDER, CIVIL STATUS, AGE, residing in LOCATION.[3] Please see attached Joint-Affidavit of Arrest, Annex A.

The operation likewise resulted in the rescue of NUMBER OF RESCUED VICTIMS victim(s) who were immediately placed under the protective custody of the DSWD. See Annex G.

Please see attached Individual Sworn Statements of the victim(s).

B. Evidence Submitted[4] Annex A Annex B Annex C Annex D Annex E Annex F Annex G Annex H Annex I Annex J Search Warrant # XXXX-XXXX-XX-XX

Return of Search Warrant # XXXX-XXXX-XX-XX

Joint Affidavit of Arrest

Joint Affidavit of Decoy

Sworn Statement of WITNESS, GENDER, AGE

Transmittal to DSWD of Rescued Victims

Request for Powder Dusting of Marked Money

Photocopy of Marked Money

Request for Laboratory (Ultra-Violet) Examination of Suspects

Inventory of Seized Properties

Annex K Annex L Annex M Annex N Annex O Annex P

Certificate of Good Conduct of Search

Result of Dental Examination

Booking and Information Sheet of SUSPECT

Picture of Suspects

DVD Containing Video Evidence dated DATE

And Other Sworn Statements to be Annexed and Presented Later

C. Witnesses

1. RANK, OFFICER NAME, AGENCY (list all officers named in affidavit) 2. NAME, GENDER, AGE (for each victim involved) 3. NAME, the Forensic Chemist who conducted the examination for the presence of ultra-violet powder in suspects skin. A. Dr. NAME, DDM with Lic. #________ (list all DDMs that conducted medical examinations) B. Official that issued the Certificate of Good Conduct of Search (ex. Barangay Councilor) D. Status of Respondents Detained At Large

1. SUSPECT 1 (NAME, GENDER, AGE) 2. SUSPECT 2 (NAME, GENDER, AGE) Respectfully submitted,

NAME TITLE

RANK

Sample of Complaint Republic of the Philippines Metropolitan Trial Court ____________

People of the Philippines vs Accused x--------------------------------x

Criminal Case No.

COMPLAINT The undersigned, Chief of Police of ___________________, accuses _______________In the municipality of ____________________, province of _____________________________,Philippines, the said accused did then and there, willfully, unlawfully, and feloniously, with malice and aforethought, attacked _______________________ with ________, wounding the latter in the _______________, producing wounds which are necessarily fatal, thereby causing the immediate death of said _____________________________.

Contrary to law.

____________, __________________________, 20___. ____________________________ Chief of Police of ______________

SUBSCRIBED AND SWORN before me this _____________th day of ____________ 20___________ in the province of ________________________.

________________________ JUDGE