REPUBLIC OF THE PHILIPPINES)

CITY OF XXXXXX……)S.S.
x---------------------------------------------x

COMPLAINT–AFFIDAVIT

I, Mrs. xxxxxxxxxxxxxxx, Filipino, of legal age, and with address at

Purok xx, Brgy. xxxx, xxxxx, xxxxxxxxxxxx, with the assistance of counsel do
hereby charge

Ms. xxxxxxxxxxxxxxxxxx, Filipino, of legal age and with residence at

Purok xx, Brgy. xxxxx, xxxxxxxx, Philippines

with violation of Article 171 in relation to Article 172, Paragraph 1 of the

Revised Penal Code or Falsification of Public or Official Document, and/or
such other crimes as may be deemed warranted under the circumstances, and
for said purpose, after having duly sworn to in accordance with law do hereby
depose and state that:

1. I am the spouse and one of the heirs of my late husband. We were married
on xx March xxxx at San Vicente Ferrer Church, Sta. Mesa, Cagayan
Oriental. A photocopy of our Certificate of Marriage is hereto attached as
Annex “A”. My husband died on x February xxxx. A photocopy of his
Death Certificate is hereto attached as Annex “B”.

2. My sister-in-law Ms. xxxxxxxxxxx, forged the signature of my late

husband and her brother Mr. xxxxxxxxxxxxx on a document entitled
AGREEMENT dated xx October xxxxx. Contained in the document is my
husband’s alleged signature seeming to have participated in the execution
thereof to my damage and prejudice as his spouse and one of his heirs;

3. That his alleged signature imposed therein is totally different from his
customary signature which I have personal knowledge of.

4. Contained in the said document is that XXXXXXXXX declares that he

admits and acknowledges that his name was erroneously entered as one of
the registered owners of the land and that he is holding the title and
ownership of said Two (2) hectares of Two Million Five Hundred Seventy
Five Six Hundred Forty Two (2,572,642) square meters in trust for and in
behalf of Ms. xxxxxxxxxxxxxxx. A photocopy of the AGREEMENT is
hereto attached as Annex “C”;

5. The subject of this controversy is a parcel of land which was awarded to

my husband who is being identified as XXXXXXXXXXXXXXXX, a
farmer-beneficiary in the title identified as Transfer Certificate of Title

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 No. XXXXX. A photocopy of the said title is hereto attached as Annex
“D”;
6. On 30 April xxxx, xxxxxxxxxxx executed a Deed of Absolute Sale in favor
of the Defendant xxxxxxxxxx with evident bad faith and without authority
from xxxxxxxxxxxx using the AGREEMENT forged by her. A photocopy
of the Deed of Absolute Sale is hereto attached as Annex “E”;
7. Ms. xxxxxxxxxxxxx is only one of the siblings of the late
xxxxxxxxxxxxxxx. She executed the said Deed of Absolute Sale without
the conformity of other siblings to our damage and prejudice;

8. I submit that the said document was executed contrary to law, morals, good
customs, public order and public policy. And that it was just made to
transfer the portion of the said property with dishonest purpose or moral
obliquity on the part of xxxxxxxxxxxxx;

9. Consequently, the said unlawful act is in violation of Article 171 in

relation to Article 172, Paragraph 1 of the Revised Penal Code of the
Philippines, as amended by Republic Act 10951, also known as
FALSIFICATION BY PRIVATE INDIVIDUALS AND USE OF
FALSIFIED DOCUMENTS is being punished by law;

10. Ms. xxxxxxxxxxxx is the only person who benefited from the
AGREEMENT. As a consequence, she may be presumed to be the author of
the crime;

11. I am, therefore, executing this affidavit to attest to the truth of the foregoing
facts and for the purpose of charging Ms. XXXXXXXXXXX for violation
of the provisions of Article 171 in relation to Article 172, Paragraph 1 of
the Revised Penal Code of the Philippines, as amended by Republic Act
10951, also known as FALSIFICATION BY PRIVATE INDIVIDUALS
AND USE OF FALSIFIED DOCUMENTS;

FURTHER, AFFIANT SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto set my hand this _______

day of __________ 2018 at xxxxx City.

XXXXXXXXXXXXX
Affiant

SUBSCRIBED AND SWORN to before me, this _______ day of

____________ 2018 at XXXXXX City, and I hereby certify that I have
personally examined the affiant and that I am satisfied that he freely and
voluntarily executed his affidavit and understood the same.
_________________________
Asst. City Prosecutor

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