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-versus-
FOR: RAPE
Arthur Sanggalang
Accused,
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5. That the complainant was present at that time along with her friends in one
table, while the accused was on the other table together with his friends;
6. That at around 10:30 in the evening, the complainant is already dizzy
considering that they already consumed three (3) buckets of red horse
stallion;
7. That when the party was about to end at on or about 12:30 oclock in the
morning of December 19, 2014, the accused approached the complainant
and offer to take home the complainant;
8. That at around 1:10 A.M , the Accused accompanied the complainant who is
about to lost her consciousness and rode a cab;
9. That when the complainant regain his consciousness, the accused was
already on the top of her, after being realized the complainant strongly
resisted and tries to let go of her wrist so that she can pushed the accused
away from her body but she was so helpless to do so because of accused
superior strength;
10. That the accused despite the constant refusal of the complainant,
successfully raped her, by pinning down the hands of the complainant and
inserted his penis in her vagina and did the push and pull motion;
11.That the crime was committed in Lavida George Inn, Ecoland, Davao City;
12.That after the accused finished his bestial acts against the complainant he
threatened the complaint not to tell anybody of what had happen between
them otherwise something bad will happen to the complainant as he
presented to her, her naked photos;
13.That after the incident the accused drove the complainant home, who still
shock of the incident;
14.That when the complainant arrived at home she told her mother emotionally
about the incident;
15.That after telling the complainant to her parents about the incident they
decided to report it to the authorities and went to Talomo Police Precent
about the incident.
3. Medical Certificate----------------------------------Exhibit F
WITNESSES TO BE PRENTED
1 Maine F. Gonzales her testimony will provide for the facts of the alleged rape
incident. She will detail to the court what really transpired on December 19, 2014.
2 Dr. Anne Constantino she will identify to the court the medical certificate
submitted by the complainant.
TRIAL DATES
Specifically all Fridays of the month, with the regular appearance
of the undersigned city prosecutors before this Honorable Court.
RESPECTFULLY SUBMITTED. August 2, 2015, Davao City, Philippines.
And
ATTY. GIAN ESPINA
Private Prosecutor
Roll of Attorneys No. 62042
IBP No. 976893/ Davao City/January 2, 2014
MCLE Exempt
PTR Exempt
Copy furnished:
ATTY.HASNIA BASMAN
Counsel for the Accused
Room 200,Candelaria st Davao city.
Received by:___________
Date: ___________