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Republic of the Philippines }

Quezon City . . . . . . . . . . . .} ss
COMPLAINT-AFFIDAVIT
I, GUINEVERE H. DE LEON, of legal age, Filipino and presently residing at El Jardin del
President 2 Bldg., 38 Sgt. Esguerra St., South Triangle, Quezon City, after swearing according to
law, hereby depose and state that:
1. This is a complaint against DR. ARMELINDA ANDRADA RAFON, also known as Dr.
Linda Rafon, of legal age, married to Edwin Rafon and with postal address at Block 1,
Lot 10, Villa Arca 2, Project 8, Quezon City, for UNJUST VEXATION and other crimes
under the Philippine Revised Penal Code for her acts committed thus;
2. I am the lawful lessee of a parking slot denominated as Basement 3 Slot 17 at El Jardin
del Presidente 2 Bldg., 38 Sgt. Esguerra St., South Triangle, Quezon City (EJDP2 for
brevity) under a valid and existing contract with Armelinda Andrada Rafon and Edwin
Rafon since July 2012 to present. Attached is the photocopy of the Lease Contract dated
July 17, 2012 as Annex _____; Also attached is a photocopy of PNB check and PNB
bank statement for the cleared check representing rental of the parking slot for the period
April 24 to May 23, 2015, which Armelinda Rafon deposited on May 13, 2015 as Annex
____;
3. On May 23, 2015, I left my PNB check for Edwin and Armelinda Rafon as payment of
rental for period May 24 to June 23, 2015 at the EJDP2 administration office for her to
pick up per our agreed arrangement and usual practice since July 2012;
4. At or about 7:30pm of May 26, 2015, I proceeded to park at my rented parking slot but I
discovered that a car was already parked there. I took a photograph of the parked car
from my cellular phone. Attached is the copy of the photo of the parked car in my slot
with slot 17 painted on it, as Annex ____;
5. Upon inquiry on the same night and per the security log entry, logged under the
supervision of OIC Rommel Pasion of the Shooters Security Agency, Armelinda and
Edwin Rafon arrived at EJDP2 premises around 2:28pm and left the Mercedes Benz with
car plate PRD 499 at said slot, WITHOUT MY CONSENT; Attached is the copy of the
security log entry for May 26, 2015 as Annex _____; Also attached is the copy of the
LTO details of the parked car with plate PRD 499 registered in the name of Armelinda
Andrada as Annex ____;
6. Upon learning that it was Dr. Armelinda Rafons car parked on my slot, I immediately
texted Dr. Armelinda Rafon to demand that she remove her car from my rented slot and
respect our existing lease contract. Attached is the printout copy of the photo of my text
message to Dr. Armelindas cellular phone number as Annex ______;
7. Because I was denied use of my rented parking slot that night, I was forced to look for an
uncertain place where I can park my car safely or without compromising the security of
the vehicle;
8. The next night, at about 7:30 pm on May 27, 2015, upon arrival at the same parking slot
that I was renting, the car of Armelinda Rafon is still parked at the same spot, PROVING
HER MALICE AND CRIMINAL INTENTION OF DENYING ME PEACEFUL
ACCESS AND USE OF THE PARKING SLOT I AM RENTING, WITHOUT JUST
CAUSE OR LEGITIMATE REASON, TO MY DAMAGE AND PREJUDICE;

9. DR. LINDA RAFONS CONDUCT IN LEAVING HER MERCEDES BENZ CAR AT


MY RENTED PARKING SLOT SHOWS HER RECKLESS DISREGARD FOR MY
RIGHT TO USE THE PARKING SLOT AND WANTON DISRESPECT FOR A VALID
CONTRACT WITH IMPUNITY. DR. LINDA RAFON CHOSE TO ANNOY ME,
IGNORE MY DEMAND TO RESPECT OUR CONTRACT CAUSING ME GREAT
DISTRESS, TORMENT, DISTURBANCE AND WORRY SINCE I HAVE NOWHERE
TO PARK MY VEHICLE FROM MAY 26, 2015 TO PRESENT;
SHE DEPRIVED ME WITHOUT JUST CAUSE FROM USING THE PARKING SLOT
WITHOUT REGARD FOR MY CONTRACTUAL RIGHTS, SECURITY AND
SAFETY OF MY VEHICLE, MY HEALTH AND WELLBEING AS HER LAWFUL
TENANT;
10. As a result of these aggravation, I also suffered sleepless nights, anxiety, anguish,
physical stress for searching a safe place to park my vehicle EVERY TIME I ARRIVE
AT MY RESIDENCE;
11. Her acts also shows she did this OPPRESSIVELY AND WITH IMPUNITY because
despite my text messages impleading her to remove her car, DR. LINDA RAFON
NEVER RESPONDED TO MY TEXT MESSAGES NOR REMOVED HER CAR
FROM THE PARKING SLOT to this date;
12. EVEN AFTER MY LAWYERS DEMAND LETTER TO ARMELINDA RAFON FOR
HER TO VACATE THE PARKING SLOT TO ALLOW ME TO USE THE SLOT
UNDER THE LEASE CONTRACT, SHE NEVER RESPONDED NOR COMPLIED TO
DATE AND CONTINUES TO IGNORE MY RIGHTS CAUSING ME FURTHER
WORRIES, STRESS, TORMENT AND VEXATION. THIS ACT SHOWS HER
DISRESPECT FOR A LAWFUL DEMAND, DISREGARD FOR THE LAWS AND
CONTRACTS AND CLEARLY ESTABLISHES HER BAD FAITH AND OPPRESSIVE
MANNER, for which, actual, compensatory, exemplary damages be required from
offender Dr. Armelinda Rafon. Copy of the demand letter and receipt of courier service is
attached as Annex ____;
13. There is no legitimate purpose or just cause for Armelinda Rafons acts in leaving a
parked vehicle on my rented slot since all she could have decently done was to inform me
or send notice that she is terminating our lease contract within a reasonable time to allow
me to look for another space to rent. INSTEAD, SHE CHOSE A SINISTER COURSE
OF ACTIONS AGAINST ME;
14. I am executing this Complaint-Affidavit to attest to the truth of the foregoing statements.
In witness whereof, I affix my signature this __________ in Quezon City.

GUINEVERE H. DE LEON
Affiant