REPUBLIC OF THE PHILIPPINES}

Cainta, Rizal, Phjlippines } S.S.

COMPLAINT-AFFIDAVIT

1. We, Antonio O. Enciso and Abraham B. Tible, both of legal ages,

married and residents of 0594 St. Christopher St, and 2040 Berkshire
St., Brookside Hills Subd., Cainta, Rizal, Philippines, after having
been sworn to in accordance with law do hereby depose and state:

2. That we are instituting this

CRIMINAL COMPLAINT against ANTONIO ESPINO, of legal age,
amrried, Filipino, and a resident of Biscayne St., Brookside Hills
Subd., Cainta, Rizal, Philippines, for ORAL DEFAMATION as defined
and penalized under Article 353 in relation to Article 358 of the
Revised Penal Code of thePhilippines;2.

That the acts complained of were committed as follows:

a. February 1, 2013 at around 5p.m. I was heading home at 56

Brookside,Santiago City when I met my neighbor, Korina
K. Manalastas, who withour saying nothing, to my surprise, he
intentionally shouted (“PUTA KA! INAGAW MO ASAWA KO,
PALAGI KAYONG NAGLALANDIAN SA ILALIM NG BAHAY
NAMIN”).You are a whore! You stole my husband! You are always
flirting with each other under our house. It was uttered a lot of times
and was heard by my neighbors and my son who is five years old.
b. That the statement was uttered by Korina K. Manalastas on
February 1, 2013 publicly and clearly prompted not by sense of
moral duty but by personal ill-will, spite and/or malice with the
object of destroying my reputation and discrediting and ridiculing
me as an individual before the bar of public opinion and contempt;
c. The ill-effects of the malicious utterances are shown by the
negative responses that I have received from my neighbors,
especially my son, expressing belief in respondent’s baseless
allegations as shameful, heinous and unequivocally barbaric-all to
my damage and prejudice;

3. That by reason of the foregoing, I suffered sleepless nights,

wounded feeling, moral and social embarrassment which Korina K.
Manlastas should compensate by way of moral damages which is the
natural, proximate and necessary result ofthe maliscios publication in
the amount of not less that One Hundred ThousandPesos
(Php100,000.00).4.

That I am executing this affidavit to attest to the truth of the

foregoing averments and for the purpose of criminally prosecuting said
Korina K.Manalastas for ORAL DEFAMATION/ SLANDER as there grave
utterances as determined by the Prosecution Office in the preliminary
investigation.
IN WITNESS WHEREOF
, I have affixed my signature this 14
th
day of February 2013in Santiago City, Philippines.
FELICIDAD I. PITA

Affiant

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