Republic of the Philippines
Province of Ilocos Norte
CITY OF LAOAG
Barangay 22 San Andres
FRANZ NICOLE DAVID,
Complaint,
Barangay Case No. ___________
-versus- For: CYBERLIBEL AND DAMAGES
GAY ECHIVERRI PUNGTILAN,
Respondent.
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COMPLAINT
I, FRANZ NICOLE DAVID, of legal age, Filipino, single, and a resident of 76 C
P.Gomez Street, Brgy. 15, Laoag City, Philippines, hereby complain GAY
ECHIVERRI PUNGTILAN, of legal age, Filipino, and a resident of L. Ablan Street, Brgy.
22, Laoag City, Philippines, for violating my rights and interests, in the following
manner:
1. That said respondent has been spreading false rumors and malicious
information to several persons with bad intentions and unjustifiable motives
purposely to malign, dishonor, discredit, insult and assassinate my character
and good reputation to the publics, including my customers through the
social media platforms Facebook and Facebook Messenger.
2. That said respondent has been talking and convincing my supplier not to
do business with me, calling me “ahas” and “copycat” and that even
accused me of “stealing other resellers’ buyers”.
3. That she even made up a story that I am claiming to be a VIP customer of
LBC and that I am allowed to pay any amount I want because allegedly
she recommended me at the said courier services. However, upon
verification, an LBC staff denied the said allegations, and denied that I was
given a VIP/Priority status/Special Treatment as to the shipping fees at the
said courier service.
4. That the false and malicious statements of the respondent have caused
and continuous to cause me serious anxiety, besmirched reputation,
mental anguish, sleepless nights, not to mention, the damage that it has
caused to my business and reputation among my business colleagues and
customers.
THEREFORE, I pray that the following reliefs be granted to us in accordance
with law and/or equity:
a. That immediate SUMMONS be issued to respondent GAY ECHIVERRI
PUNGTILAN to appear before the Lupong Tagapamayapa of Brgy. 22 San
Andres, Laoag City;
b. That immediate BARANGAY CONCILIATION/MEDIATION meetings be held
by the Barangay Lupon;
c. That the respondent INDEMNIFY the complainant for the mental, emotional
and psychological sufferings that she has sustained by way of MORAL
DAMAGES;
d. That respondent INDEMNIFY the complainant by way of EXEMPLARY
DAMAGES to serve as a lesson to society;
e. That the respondent INDEMNIFY complainant for the attorney’s fees and
litigation expenses that she has sustained;
f. That respondent be urgently ordered, restrained and enjoined to
immediately stop her malicious destruction of complainant’s reputation as
a businesswoman and desist from further spreading false, malicious and
baseless imputations against her;
g. That the complainant reserves the right to file the proper criminal and civil
action against the respondent for Cyberlibel and such other related crimes
and or offenses punishable under the laws of the Republic of the Philippines.
Further, complainant further prays for such and other reliefs as may be
deemed just and equitable under the premises.
Laoag City, Philippines. August 21, 2020.
FRANZ NICOLE DAVID
Complainant