REPUBLIC OF THE PHILIPPINES . .
]
___________________]
X---------------------X
COMPLAINT-AFFIDAVIT
I, _________________, of legal age, married, Filipino and a
resident of__________________, Philippines, under oath, hereby depose
and say, that:
1. I hereby formally charge______________, Filipino, married and a
resident of _____________for the crime of Libel under section 4,
(c) paragraph 4 of R.A. 10175 also known as the Cybercrime
Prevention Act of 2012.
2. Respondent caused the posting and publication of malicious,
demeaning, and defamatory imputations published for all to see
through her Facebook account, to wit:
“________________________________”
3. The foregoing posts published by the respondent contained
malicious imputations with devious design and evil motives,
purposely made to malign, dishonor, discredit, and insult my
character and reputation as a person and as a practitioner of my
profession as__________, to the public as well as to my neighbors
and colleagues.
4. As can be gleaned from the above-quoted posts, the respondent
was clearly and ultimately motivated with the evil design of putting
my name in opprobrium. In fact, one of my clients informed me
that the respondent told her to join with her in filing an
administrative case before the Professional Regulation Commission
against me. Since the said client did not conform with the
respondent’s cajolery, she uses her influence to scrutinize the
whereabouts of my client’s building permit. Clearly, the respondent
has the intention to injure my reputation as an________. A copy of
the Affidavit of Witness to form an integral part hereof is hereto
attached as Annex “F”.
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5. The afore-quoted excerpts of online posts authored and published
by the respondent cast aspersion in the minds of the readers that I
am a deceitful and a terrible contractor.
6. Moreover, the said posts written and published by the respondent
are highly speculative and contains false statements consciously
and deliberately made to destroy my reputation, integrity, and
character as a person as well as to my family. The respondent is
motivated by bad faith in publishing the said posts online to
defame, embarrass and discredit me to my colleagues, friends,
family, and to the readers and patrons of Facebook.
7. Assuming without, however, admitting that I committed any
undesirable acts whatsoever against the respondent, the same
should not be a license for her to destroy my name and my family’s
reputations as well. The respondent has no good intention or any
justifiable motives whatsoever when she posted online the said
defamatory imputations.
8. The libelous posts having been published through Facebook, a
social media website accessible to and is made available to the
public was in fact read by many, including my colleagues, friends,
and family, among others. The same was, without any taint of
doubt, directly imputed by the respondent against me when she
stated____________. The said posts earned numerous likes and
comments as shown in the foregoing annexes.
9. Owing to the said malicious public imputations by the respondent, I,
and my family, suffered and continue to suffer serious anxiety,
besmirched reputation, mental anguish, sleepless nights, not to
mention the damage she has caused to my reputation and honor as
an _________among the readers, patrons of Facebook, my clients,
and the public.
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10. Because of the unbearable effects of the malicious imputations
caused by the respondent against me, I reported the matter to the
Philippine National Police Anti-Cybercrime Group, Regional Anti-
Cybercrime Unit in__________. Copies of the police blotter under
Entry #_______ and Entry #_________ are hereto attached as
Annex______, respectively, to form an integral part hereof.
11. Police officer ____________ of the Philippine National Police
Anti-Cybercrime Group, Regional Anti-Cybercrime Unit confirmed
that the libelous posts were indeed authored and originated from
the Facebook account of the respondent “_______” with
URL:________________. A copy of the Affidavit of Witness is hereto
attached as Annex “___”.
12. Due to such grossly unjustified malicious and libelous
imputations, I therefore pray that the respondent is made to pay
the damages I was made to suffer because of the online published
article in whatever amount the appropriate court deems sufficient
and proper together with the attorney’s fees and the cost of this
suit.
13. 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 respondent ________who may be
served with a subpoena and other processes of this Honorable
Office at__________________.
IN WITNESS WHEREOF, I have hereunto set my hand this
____________ in____________________, Philippines.
___________________
Affiant/Complainant
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SUBSCRIBED AND SWORN to before me this _____________
at_________. I hereby certify that I have examined the affiant and that I
am fully satisfied that he has voluntarily executed and understood the
contents of his Complaint-Affidavit.
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