Complaint Affidavit

REPUBLIC OF THE PHILIPPINES
DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
LEGAZPI CITY, ALBAY
Karla H. De Jesus,
Complainant
vs. I.S. No. ________

For: Rape
Paulino B. Badillo,
Respondent.
x ............................................................................................................ x
COMPLAINT-AFFIDAVIT
I, KARLA H. DE JESUS, Filipino, of legal age, and with residence at No. 555
Sitio Mega, Brgy. Sardines, Legazpi City, Albay, after having been duly sworn in
accordance with law, hereby depose and state that:
(1) This complaint-affidavit is being filed to charge Paulino B. Badillo a.k.a

“Black Jack”, Filipino, of legal age and with residence at No. 69 EM's Barrio,
Legazpi City, Albay, of the crime Rape under Article (Art.) 266-A of the Revised
Penal Code (RPC), as amended, committed as follows:
(a) On 14 February 2018, at around 10:00 in the evening, while I was

walking towards home, Paulino, my classmate in law school, came up to
me in his motorcycle and asked me to accompany him to the nearest
hospital because he was not feeling well and he had no money with him.
(b) On the way to Estevez Hospital, he stopped in a narrow path and

handed me a handkerchief and told me to use it to cover my nose from
the dusts and smoke along the way. When I refused to do so, he forced
the handkerchief towards my nose which in a few seconds made me feel
dizzy and lose my consciousness.
(c) When I regained my consciousness, I was already lying in bed with

my hands and feet tied. I was in a very dark room so I had no idea where I
was and who I was with.
(d) A few minutes later a door opened and I saw a silhouette of a man
which I recognized was Paulino. As he walked towards my direction, I saw
that he was holding a small knife in his hands. He then to me, "wag kang
maingay, kung hindi sasaksakin kita hanggang mamatay ka."
(e) He started removing my clothes and undergarments. I was already

crying so hard and was begging him to stop whatever he is planning to do.
He never listened to me as if he could not hear anything. When I was
already naked, he started touching my breasts and nipples. He sucked my
nipples and said "Ang sarap mo. Dati ko pa gustong gawin sayo to."
(f) After, he removed his pants and touched his penis. He told me, "i-
lolipop mo! Wag kang umarte! Papatayin kita." I then sucked his penis
because of so much fear for my life. He then licked me vagina and inserted
his penis. He once again told me, "Ang sarap mo talaga! Gusto kong ulit-
ulitin."
(g) After satisfying his carnal desires, Paulino spat on my vagina and
said, "labas lang ako. Pagbalik ko round two tayo!" I was already very
disgusted with what happened to me so I decided to devise a plan in order
to escape.
(h) When Paulino came back, I begged to him and said, "Please
pakawalan mo na ako kasi di naman ako lalaban. Kung gusto mo i-dog style
mo pa ako. Promise di ako lalaban." Paulino then removed me from being
tied and said, "oh! Tumuwad ka na!" Instead of following his orders, I
grabbed his testicles really hard which made him fall on the ground
because of so much pain.
(i) I took the opportunity and ran as fast as I could. I saw a tricycle
moving and shouted for help. The tricycle driver drove back towards my
direction and helped me escape. He accompanied me to the nearest police
station to report the incident.
(2) The Police took my sworn statement, a copy of which is hereto attached
and made an integral part thereof as Annex “A”. Thereafter, I was examined by
their medico-legal officer. A copy of the Medico- Legal Report is likewise hereto
attached and made an integral part thereof as Annex “B”.
(3) The next day, I decided to personally file this complaint because I could no
longer wait for the Police Officer to file it on my behalf.
(4) The elements of rape are carnal knowledge, force or intimidation, and the
commission of the act without the consent or against the will of the woman, or
when the latter is under twelve (12) years of age or when she is deprived of
reason or otherwise unconscious.
(5) Based on the foregoing, it is beyond cavil that respondent Paulino

committed the crime of rape punishable under Art. 266-A of the RPC, as
amended. He had sexual intercourse with me while I was tied and against my
consent.
(6) Further, whenever the crime of rape is committed with the use of a deadly
weapon or by two or more persons, the penalty shall be Reclusion Perpetua to
death.
AFFIANT FURTHER SAYETH NAUGHT.
IN WITNESS WHEREOF, I have hereunto set my hands this 15th day of
February 2018, in Legazpi City, Albay.
Karla H. De Jesus
Complainant/Affiant
SUBSCRIBED AND SWORN TO before me, this 15th day of February 2015 in
Legazpi City, Albay.
_____________
Prosecutor
This is to certify that I have personally examined the herein affiant and that
I am satisfied that she voluntarily executed and understood her statements
herein.
____________
Prosecutor

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REPUBLIC OF THE PHILIPPINES

vs. I.S. No. ________

(1) This complaint-affidavit is being filed to charge Paulino B. Badillo a.k.a

(a) On 14 February 2018, at around 10:00 in the evening, while I was

(b) On the way to Estevez Hospital, he stopped in a narrow path and

(c) When I regained my consciousness, I was already lying in bed with

(e) He started removing my clothes and undergarments. I was already

(5) Based on the foregoing, it is beyond cavil that respondent Paulino

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