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Republic of the Philippines )

) S.s.

COMPLAINT-AFFIDAVIT

I, ____________________, of legal age, single, Filipino and


resident of ____________________, under oath, hereby depose and
say, that:

1. I hereby formally charge the following persons for the crime of


Libel under section 4, (c) paragraph 4 of R.A. 10175 also known as
the Cybercrime Prevention Act of 2012;

1.a. __________________, _____________,


and _________________, all of legal age and residents of
_____________________________, herein referred to as
RESPONDENTS.

2. On __________________, respondents by conspiring and


confederating to malign my person, character and honor caused
the posting and publication of malicious, false, demeaning, and
defamatory imputations published for all to see through their
respective Facebook accounts on even date.

Attached are the full text of libelous posts and comments hereto
collectively referred as Annex "A".

3. Said posts published by respondents contained malicious


imputations with bad intentions and unjustifiable motives,
purposely to malign, dishonor, discredit, insult and assassinate my
character and good reputation to the public as well as to my
neighbors and colleagues, an excerpt of which are hereby quoted:

4. The afore-quoted portions of the online posts authored and posted


by the respondents created in the minds of the readers that I am
liar, deceitful and a fake faithful.

5. The posts even escalated to a plot to kill me and threat to lock us


up, so we could no longer enter and exit our property as evidenced
by these posts:
6. The Facebook posts written and published by respondents have no
factual basis, are highly speculative and were all false statements
made to destroy my reputation as a person and a devout religious
servant of our Church. Respondents were motivated by bad faith
in the publishing of the said posts online to defame, embarrass and
discredit me to my colleagues, friends, family and to the readers
and patrons of Facebook;

7. The libelous posts having been published through Facebook, a


social media website accessible to and is made available to the
general public was read by the said general public, including my
colleagues, friends and family among others;

8. Due to the said malicious public imputations by respondents, I


suffered and continue to suffer serious anxiety, besmirched
reputation, mental anguish, sleepless nights, not to mention the
damage they have caused to my reputation and honor among the
read
I hereby execute this affidavit to attest to the truth of the foregoing
facts and hereby request the investigating officer to file the crime of Libel
under R.A. 10175 and other crime or crimes committed against the herein
Respondents.

IN WITNESS WHEREOF, I have hereunto set my hand this 9TH


day of May 2018 in Manila, Philippines.

Solemnizing Officer

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