NATIONAL PROSECUTION OFFICE
COTABATO CITY PROSECUTION OFFICE
Hall of Justice, BARMM Compound, Cotabato City
LIGAYA C. DELA CRUZ
#04 Governor Gutierrez St., Rosary
Heights 7, Cotabato City
Complainant For:
Murder by treachery
Art 248 (1) of the RPC
-versus-
JALIL B. CONCEPCION
#16 Poblacion 8 Kakar
Rosales St., Cotabato City
Respondent
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COMPLAINT-AFFIDAVIT
PREFATORY STATEMENT
This is the complaint-affidavit of complainant, LIGAYA DELA
CRUZ, Filipino, of legal age, widow and a resident of #04 Governor
Gutierrez St., Rosary Heights 7, Cotabato City. The statements were
taken and recorded based on the examination made by Atty. Sittie
Nurjannah S. Datuali, Assistant Prosecutor for Cotabato City, at the office
of the same lawyer on the 16th day of February 2023.
That the questions asked are in English language but are
translated in Tagalog which she speaks fluently and fully understand
and stands for their veracity. She was made aware that she made these
statements under oath and dully conscious that she may face criminal
liability for false testimony or perjury for false statements made or given
by her.
PURPOSE(S) OF THE AFFIDAVIT
This complaint-affidavit in judicial affidavit is offered pursuant to
Administrative Matter No. 12-8-8-SC for the following purposes:
Page 1 of 6
1. To establish probable cause for the filing of information for
Violation of Paragraph 1, Article 248 (Murder by treachery) in
relation to Article 6, of the Revised Penal Code (RA 8353)
against JALIL B. CONCEPCION;
2. To identify and testify on relevant and material documents; and
3. To prove other relevant matters.
The following questions and answers were asked and recorded:
1. Q: Will you please state your name, age, civil status, occupation
and present address and other personal circumstances?
A: I am Ligaya C. Dela Cruz, of legal age, widow of Juan S. Dela
Cruz, a housewife, and a resident of #04 Governor Gutierrez St.,
Rosary Heights 7, Cotabato City.
2. Q: May I know why you are here in our office?
A: I am here to make a complaint-affidavit against Jalil B.
Concepcion.
3. Q: Would you like to choose which language do you prefer your
affidavit to be made?
A: I want it to be in English but translate to me in Tagalog
whenever there is confusing statement.
4. Q: Do you know that you are only bound to tell the truth and
nothing, but the truth, and any false testimony will make you
criminally liable?
A: Yes, Atty. I am aware that I will be criminally liable for false
testimony or perjury for false statements.
5. Q: Can you tell me who Jalil B. Concepcion?
A: He is my husband’s friend. He is a habal-habal driver. I have
here with me a picture of him. (Hands picture to the examining
lawyer) He owes my husband a sum of Php50,000 since February
of 2022 because his wife just gave birth to their second child. Now,
his wife is pregnant again, yet there’s still no payment for the
money he borrowed from my husband.
Page 2 of 6
6. Q: Would you agree to attach this picture to this complaint-
affidavit as ANNEX A?
A: Yes, Atty.
7. Q: Why are you now filing a criminal case against Mr. Concepcion?
A: Because he murdered my husband, Juan S. Dela Cruz. I have
here the Death Certificate and autopsy report of my husband.
(Hands the Death Certificate and autopsy report to the examining
lawyer)
8. Q: Would you agree to attach this Death Certificate to this
complaint-affidavit as ANNEX B and the autopsy report as ANNEX
C?
A: Yes, Atty.
9. Q: Will you please tell us the victim’s name, age, and other
personal circumstances?
A: He is Juan S. Dela Cruz, 42 years of age, and a resident of #04
Governor Gutierrez St., Rosary Heights 7, Cotabato City.
10. Q: When was your husband murdered?
A: On February 14, 2023 at around 9:00 PM.
11. Q: Can you tell me what transpired on February 14, 2023?
A: On the 14th day of February 2023, at around 11:00 AM, my
husband told me Jalil B. Concepcion would not reply to his
numerous messages via messenger with regard to the money
borrowed and even blocked him. I told my husband to message
Jalil’s wife, Rojja Concepcion, which he also did. I think the
message to his wife angered Jalil which is why at around 3:06 PM
my husband received a text from Jalil which contains foul words.
He also said that they should meet at 7:00 PM along Notre Dame
Avenue where he usually stays to pick-up customers as a habal-
habal driver.
My husband left our house at around 6:30 PM to meet up with Mr.
Concepcion. He waited there for hours. At around 8:45 PM, he
messaged me saying that he got stood up by Mr. Concepcion and
that he is heading home. I have screenshots of all these messages.
(Hands the printed screenshots to the examining lawyer)
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12. Q: Would you like to use the screenshots of your husband’s
conversation with Mr. Concepcion as Annex D, the conversation of
your husband with Mrs. Concepcion as Annex E, the text message
of Mr. Concepcion to your husband as Annex F, and the messages
of your husband to you as Annex G to this complaint affidavit?
A: Yes, Atty.
13. Q: How did you know that your husband was murdered?
A: I received a call from police stating that my husband was shot
along a dark area in Notre Dame Avenue. He was proclaimed dead
on arrival at the CRMC. I instantly went there and saw the body of
my lifeless husband.
14. Q: What did you do next?
A: After knowing the incident and after settling all the necessary
arrangements for my husband’s burial, I went to the police station
and requested for the incident record. Here is the incident record
that I asked from the police. (Hands the incident record form)
15. Q: Do you agree to attach this Incident Record Form as Annex H to
this complaint affidavit?
A: Yes, Atty.
16. Q: What is your plan after all these evidences?
A: I am determined to file a murder case against Mr. Concepcion
for killing my husband with treachery.
17. Q: Is there anything else that you wish to say?
A: Yes, Atty. Just earlier at the burial, the officemates of my
husband were present. One of which is Ms. Sittie Fairoudz
Abdullah. She expressed her condolences and said that before the
office hours ended on February 14, my husband received a call. It
was a heated argument of my husband and the person at the other
end of the call which lasted for a few minutes. (Attached as Annex
I is Ms. Abdullah’s affidavit)
We were also visited by a certain Mr. Mohammad Jimad
Midtimbang who heard that Mr. Jalil Concepcion might be involved
in a murder case. Mr. Midtimbang is a habal-habal driver as well.
He told me he had a weird interaction with Mr. Concepcion in the
Page 4 of 6
afternoon of February 14. (Attached as Annex J is Mr.
Midtimbang’s affidavit)
18. Q: Again, are you aware that you may face criminal liability for
false testimony or perjury if your statements are not true because
these are under oath?
A: Yes, Atty.
19. Q: Are you willing to affix your signature here in order to prove
that you have voluntarily made this affidavit and also understood
the contents therein?
A: Yes, Atty.
x-----END OF INQUIRY-----X
Republic of the Philippines …..)
Cotabato City…..) S.S
AFFIANT’S OATH AND ATTESTATION
I, LIGAYA DELA CRUZ, Filipino, of legal capacity and competence to
comprehend without any vice of consent, hereby attest to have
voluntarily and truthfully made the foregoing answers to the questions.
IN WITNESS WHEREOF, I have hereunto affixed my signature on
the 16th day of February 2023 in Cotabato City, Philippines.
LIGAYA DELA CRUZ
Affiant
SUBSCRIBED AND SWORN to before me, this 16th day of February
2023 in Cotabato City Philippines, affiant presented her Philippine
Identification Card issued on the 16 th day of September 2022 by the
Philippine Statistics Authority (PSA).
Doc. No.:____
Page No.:____
Book No.:____
Series of 2023.
EXAMINING LAWYER’S SWORN ATTESTATION
I, ATTY. SITTIE NURJANNAH S. DATUALI, Filipino, of legal age,
single, a member in good standing of the Integrated Bar of the
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Philippines, Cotabato Chapter and with office address at Quezon
Avenue, Cotabato City, hereby depose under oath that:
1. I have faithfully recorded or cause to be recorded in my laptop
computer the questions I have asked to the above witness and the
corresponding answer that the witness gave; and
2. I have not nor any person present assisted or coached the
witness regarding the latter’s answers.
IN WITNESS WHEREOF, I have hereunto affixed my signature this
day, 16th day of February, 2023 in the City of Cotabato, Philippines.
ATTY. SITTIE NURJANNAH S. DATUALI
Affiant
SUBSCRIBED AND SWORN to before me this 16th day of
February 2023, in the City of Cotabato, Philippines, affiant being known
to me through her Philippine Identification Card.
Doc. No.:____
Page No.:____
Book No.:____
Series of 2023.
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