Republic of the Philippines
Department of Justice
City Prosecution Office Region IX
Hall of Justice, Sta. Barbara, Zamboanga City
ROVIE PAMO DEMAPANAG, Docket No. IX-12-135E
C FOR: Commission of the
omplainant, Crime of Homicide
-versus- under Article 249 of
the Revised Penal Code
JUAN DELA CRUZ, of the Philippines
Accused.
AFFIDAVIT OF COMPLAINT
I, Rovie Demapanag, widowed, of legal age, Filipino
citizen, and a resident of Morning Glory Drive, Putik,
Zamboanga City, Philippines, after having been duly sworn
to an oath in accordance with law, do hereby depose and
say, that:
1. I am the wife of Pedro S. Demapanag, hereinafter
referred to as “Pedro”, as evidenced by our marriage
certificate herein attached as “Exhibit A”.
2. I am executing this complaint affidavit to charge Juan
Dela Cruz for Homicide defined and punished under
Article 249 of the Revised Penal Code for the death of
my husband, Pedro. The offense was committed under
the circumstances narrated below.
3. Respondent Juan Dela Cruz, hereinafter referred to as
“Juan”, residing at Morning Glory Drive, Putik,
Zamboanga City, Philippines, is the employer of my
husband and I.
4. Respondent Juan hired my husband as a stay-in family
driver on March 2018. Two months after, Juan also hired
me as a stay-in helper.
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5. On or about 11:00 PM of January 12, 2023, I was
awakened by the sound of heavy rain. I suddenly
remembered that the window in the dirty kitchen,
which is a separate structure from the main house, was
left open. I then woke Pedro up and asked him to
quickly close the window;
6. Knowing that Pedro did what I asked for, I went back to
sleep. However, I was abruptly awakened by a loud
gunshot, moments after, I heard another;
7. Realizing that my husband was not beside me, I darted
towards the door of my room. I partially opened it when
I saw Juan closing and locking the door leading to the
dirty kitchen before running towards his room;
8. I walked forward to the door that I saw Juan lock. I
opened it and saw that the dirty kitchen door was open
and the lights were on. Thinking that my husband was
still inside, I called out his name but there was no
answer.
9. So, I decided to go inside and saw a body lying on his
side, its back facing against the entrance of the kitchen,
where I was standing on. I screamed out of shock and
went closer. Then I realized that it was my husband,
Pedro. I immediately called the authorities and waited
for them to arrive. Attached herewith is my Judicial-
Affidavit containing my testimony which is marked and
made an integral part hereof as “Exhibit B”.
10. When the authorities arrived. Pedro was declared dead
on the scene. His body was forwarded to DRA. BREN
BANC, the medico-legal officer of the Regional Crime
Laboratory Office – Zamboanga, who conducted an
autopsy on the remains of Pedro. Attached herewith are
her documents to prove that she is qualified to testify
as an expert witness marked as “Exhibit C”, “Exhibit
D”, and “Exhibit E”. The autopsy report on the
remains of Pedro Demapanag is herein attached as
“Exhibit F”. A copy of the Death Certificate is hereby
attached as “Exhibit G”. Attached herewith is Dra.
Bren Banc’s Judicial-Affidavit containing her testimony
which is marked and made an integral part hereof as
“Exhibit H”.
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11. sInvestigating officer of the City Police Station V,
ALNAIB J. MARKIN and his team conducted an
investigation of the crime scene. After coordinating with
the Forensic Unit Team Leader PMAJ Lorenzo Gonzales
as to what was initially discovered at the crime scene, a
copy of the documentation of the crime scene was
furnished to Alnaib Markin. A Report of Persons Present
at the Crime Scene; An Evidence Log; A Sketch of the
Crime Scene; and an Inventory of Evidence Collected,
are herein attached as “Exhibit I”, “Exhibit J”,
“Exhibit K'', and “Exhibit L”. Thereafter, the
investigating officer coordinated with the Firearm
Explosive Division, the repository of all registered
license firearms, through an endorsement letter herein
marked as “Exhibit M” for the cross-matching of the
firearm discovered. The Firearm Explosive Office
furnished a copy of the Certificate of License To Own
and Possess Firearms (LTOPF) and a copy of the
Firearm Registration Certification from the FEO
licensing division confirming that registered owner is
Juan Dela Cruz, attached herein as “Exhibit N'' and
“Exhibit O”, respectively. The foregoing were also
mentioned in the SPOT Report and Final Report
executed by the Investigating Officer Alnaib Markin
attached hereto as “Exhibit P” and “Exhibit Q'',
respectively. Attached herewith is Alnaib Markin’s
Judicial-Affidavit containing his testimony which is
marked and made an integral part hereof as “Exhibit
R”.
12. Subsequently, PCAPT JIM CONRAD TEE, a ballistic
expert, conducted a ballistics examination on the
discovered firearm and the gathered bullets and
casings from the crime scene. Attached herewith are
his documents to prove that he is qualified to testify as
an expert witness marked as “Exhibit S”, “Exhibit T-
1”, “Exhibit T-2”, “Exhibit T-3”, and “Exhibit T-
4”. The request for the ballistics examination came
from PMAJ Lorenzo Gonzales, OIC Regional Forensic Unit
9 of the homicide case of Pedro S. Demapanag,
attached hereto as “Exhibit U”. The ballistics
examiner executed a report wherein he determined
that the bullet that caused the death of PEDRO
DEMAPANAG came from the abovementioned firearm.
This report is attached hereto as “Exhibit V”.
Attached herewith is PCAPT Jim Conrad Tee’s Judicial-
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Affidavit containing his testimony which is marked and
made an integral part hereof as “Exhibit W”.
13. Under Article 249 of the Revised Penal Code, the
elements of HOMICIDE are that a person was killed, the
offender killed him without any of the justifying
circumstances, and that the offender killed another
without the attendance of any of the qualifying
circumstances of murder. Based on the foregoing facts,
all elements of HOMICIDE are present and are a proper
basis in finding probable cause for filing a criminal
complaint against Juan Dela Cruz.
14. Accordingly, I am executing this affidavit to attest, to
the best of my knowledge and authentic records, to the
truthfulness and correctness of the foregoing facts and
to support the filing of a criminal case for HOMICIDE
against Juan Dela Cruz.
15. I attest that I have not commenced any action or filed
any claim involving the same issues in any court,
tribunal or quasi-judicial agency and, to the best of my
knowledge, no such other action or claim is pending in
them; and
16. If I should learn that the same or similar action or claim
has been filed or is pending after its filing, I shall report
that fact within five (5) days from notice to the court or
where the complaint or initiatory pleading has been
filed.
To the truth of the foregoing, I have signed this Complaint-
Affidavit on January 18, 2023.
ROVIE PAMO DEMAPANAG
Affiant
SUBSCRIBED AND SWORN BEFORE ME, this 14th day of
January 2023 at Zamboanga City.
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INNO PAOLO Q. MENDOZA
City Prosecutor
CERTIFICATION
THIS IS TO CERTIFY that I have personally examined the
above-named Affiant and that I am fully satisfied that she
has voluntarily executed and understood the contents of her
Complaint-Affidavit.
ATTY. INNO PAOLO Q.
MENDOZA
City Prosecutor
MCLE Compliance No. VI-87654321
Issued on February 14, 2019
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VERIFICATION AND CERTIFICATE OF NON-FORUM
SHOPPING
I, ROVIE PAMO DEMAPANAG, of legal age, Filipino, single,
and a resident of Morning Glory Drive, Putik, Zamboanga
City, Philippines, after having been duly sworn to in
accordance with law, hereby, depose and say:
1. That I am the complainant in this instant case and have
caused the preparation and filing of the foregoing
complaint; that I read and understood its contents
which are true and correct of my own personal
knowledge and/or based on authentic records;
2. That I have not commenced any action of proceeding
involving the same issue in the Supreme Court, the
Court of Appeals or any other tribunal or agency; that
to the best of my knowledge, no such action or
proceeding is pending in the Supreme Court, the Court
of Appeals or any tribunal or agency, and that, if I
should learn thereafter that a similar action or
proceeding has been filed or is pending before these
courts of tribunal or agency, I undertake to report the
fact to the Court within five (5) days therefrom.
IN WITNESS WHEREOF, I have hereunto set my hand this
18th day of January 2023, Zamboanga City.
ROVIE PAMO DEMAPANAG
Affiant
SUBSCRIBED AND SWORN to before me this 18th day of
January 2023, Zamboanga City, affiant exhibiting to me her
Community Tax Certificate No.123456 issued on January 15,
2023 at Zamboanga City.
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ATTY. INNO PAOLO Q. MENDOZA
City Prosecutor
MCLE Compliance No. VI-87654321
Issued on February 14, 2019
Page 7 of 7
