Republic of the Philippines)

Province of Nueva Ecija) S.S.

City of Cabanatuan )

COMPLAINT-AFFIDAVIT

I, JELAI ANDRES, of legal age, single, and with residence at Sampaguita

Street, Cabanatuan City, Nueva Ecija, after having duly sworn in accordance with

law hereby depose and state that:

1. I was the former girlfriend of Jon Gutierrez with the same

residence

at Sampaguita Street, Cabanatuan City, Nueva Ecija;

2. We were former classmates at Wesleyan University and became on-

and-off sweethearts towards the end of 2004;

3. Our relationship was peaceful and harmonious in the beginning

until I found out that Jon had taken a live-in partner, whom he had

gotten pregnant, so I decided to end our relationship;

4. Before he got married, Jon tried to convince me to elope with him

saying that he did not love his live-in partner who he was about to

marry. However, I outrightly rejected his proposal and told him to

take on his responsibility to his live-in partner and their child;

5. I decided to change my cellphone number so he could not contact

me anymore but he was still able to manage to get my new number

and had been sending text messages. I only replied to ask him to

leave me alone;

6. In the early morning of June 5 2005, I received through multimedia

message (MMS) a picture1 of a naked woman with spread legs and

with my face superimposed on the picture from one of the numbers

Jon used in messaging me;

1
Hereto attached as Annex “A” is a copy of the Multimedia Message (MMS) picture;
 7. I realized he copied the picture of my face from a shot he took when

we were in Baguio in 2003;

8. Moreover, I also received other text messages from Jon wherein he

was boasting that it would be easy for him to create similarly

scandalous pictures of me;

9. He even threatened to spread the picture he sent through the

internet, to wit, “Madali lang ikalat yun, my chatrum ang Tarlac

rayt puede rin send sa lahat ng chatter.” (It’s easy to spread. There

is a chat room for Tarlac right. It can also be sent to all chatters) 2;

10. Out of fear, I seek the help of the police and had the incident

recorded in the police blotter of the PNP Cabanatuan 3;

11. I am voluntarily executing this Affidavit to attest to the truth of the

foregoing facts and for the purpose of filing criminal complaints

against my former boyfriend, for violation of Republic Act 9262 or

the Anti-Violence Against Women and Their Children and for

whatever legal purpose the same may serve;

12. In connection with this, I am praying that a Protection Order be

issued in my favor because there is very high likelihood that he

would continue the same threatening acts against me. I am also

asking for other reliefs, just, fair and equitable under the

circumstances;

IN WITNESS WHEREOF, I have hereunto set my hands this ____ day of

________ at Cabanatuan City, Nueva Ecija Philippines.

JELAI ANDRES
Affiant

2
Hereto to attached as Annex “B” is a print screen of text messages;
3
Hereto to attached as Annex “C” is a Police blotter from PNP Cabanatuan
 SUBSCRIBED AND SWORN to before me this _____ day of

______________ at Cabanatuan City, Nueva Ecija, Philippines. I hereby

certify that I have personally examined the Affiant and I am fully satisfied that

she voluntarily executed and understood the content of this affidavit.

NOTARY PUBLIC