REPUBLIC OF THE PHILIPPINES}

DONE: IN THE CITY OF SANTIAGO } S.S.

X =========================== X

COMPLAINT-AFFIDAVIT

I, RICHARD PIAGA an Investigating Prosecutor, have good reason to believe that, Mario
Marcelo, who is hereafter called “Defendant”, on or about the 11th day of January, 2013, and before
the making and filing of this complaint, in the City of Santiago, did unlawfully commit the offense
of Murder, to wit, did then and there intentionally and knowingly cause the death of , “Rodel
Manalang” by the Defendant contrary to the Aricle 248 of the Revised Penal Code.
Affiant has learned the following facts:
1. I Richard Piaga and I am a commissioned Investigating Prosecutor in Santiago City, since
May 2001. I am employed by the City of Santiago Prosecutors Office.

2. January 11th 2013, at approximately 12:00 midnight the Police Department responded to a
medical call involving a stabbing incident at Dizon Subdivision located within the City of
Santiago.

3. During the interview on January 15, 2013 I conducted to witness Christopher Sunga, a
copy of the Sworn Statement is hereto attached as “Annex A”, Mario Marcelo a resident
of 76 Dizon Subdivision Santiago City, is charged of murder and committed as follows:
a. At about 6:00 pm of January 11, 2013, Christopher Sunga and his friends Rodel
Baustista, Rodelio Manalang, Arsenio Madrigo, and Ednor Cabrera were in the
huse of Dominador Sunga, Christpher’s father located at 38 Dizon Subdivision,
Santiago City. They were having a drinking spree in celebration of Christopher’s
birthday.
b. At about 8:00pm Dominador arrived with Marcelo. The latter joined Christopher
and his friends in their drinking and merrymaking. After sometime, a commotion
ensued when Marcelo created trouble and challenged Ednnor Cabrera to a duel.
Christopher’s mother tried to cal, When she failed, Dominador intervened and
succeeded in bringing Marcelo home.
c. At about 11:00 pm, Christopher and his friends agreed to call it a night. Christopher
told his parents that he, along with Madrigo and Baustista would accompany
Manalang to their house.
d. As they were passing by the house of Marcelo, the latter sneaked from behind
Manalang and stabbed him at the back. Bautista tried to restrain the appellant, but
the latter stabbed him on the right arm.
e. Marcelo continued to stabbed Manalang as Christopher and Madrigo ran to the
Bantay Bayan Office for help.
f. When they met Dominador on the way, they informed him of the stabbing incident.
g. Dominador, together with some barangay tanods, proceeded to the place of the
incident to conduct an investigation. On their way, Dominador saw Baustista who
was then fleeing to their house and notice the wound on the latter’s right arm.
Bautista told Dominador that he and Manalang were stabbed by Marcelo.
Dominador then rushed to the house of Marcelo, and saw the bloddied body of
Manalang lying by the roadside.

4. Eduardo T. Vargas, Medico-Legal Officer of the National Bureau of investigation,

performed an autopsy on the cadaver of Manalang and signed his Autopsy report, attested
that indeed Manalang cause of death was due to the several stabbed wounds one of which
was from his back. A copy of the Postmortem Findings is hereto attached as “Annex B”;

5. Based on the foregoing, it is beyond cavil that respondent Mario Marcelo committed the
crime of Murder, qualified by treachery under Article 248 of the Revised Penal Code.
There is treachery in the commission of the crime when (a) at the time to attack, the victim
 was not in a position to defend himself; (b) the offender consciously and deliberately
adopted the particular mean, method and form of attack employed by him.

IN WITNESS WHEREOF, I have affixed my signature this 14th day of February 2013 in
Santiago City, Philippines.

RICHARD PIAGA
Affiant

SUBSCRIBED AND SWORN to before me in the City of Santiago this 14th day of
February 2013. I hereby certify that I have personally examined the above named affiant and that
I am the foregoing statements were given by her voluntarily and of her own free will.

_______________________
Investigating Prosecutor
Republic of the Philippines
City of Tacloban s.s.

AFFIDAVIT-COMPLAINT

I, RIZA A. MALATE, 35 years old, married, and a resident of Block 30, Lot 11, New
York Street, Phase 4, V&G Subdivision Tacloban City, after having been duly sworn to in
accordance with law, hereby deposes and says THAT:

1. I am the mother of Rhyzza Mae A. Malate, 12 years old, enrolled as a Grade Six Pupil
at Liceo Del Verbo Divino, Tacloban City. A machine copy of the birth certificate of
Rhyzza Mae A. Malate is hereunto attached and made as an integral part hereof as
Annex “A”;

2. Last July 1, 2013, on or about 9:30 P.M., my daughter Rhyzza Mae A. Malate with her
cousin Angelyn A. Gonzaga, asked for my permission to attend the funeral of their
grandmother, the late Ruby Azucena.

3. Because of the assurance of Angelyn that she will be looking and taking care of Rhyzza
Mae, I allowed them to go ahead of me as I was also planning of going there and that
the place of the wake was only a few houses away. While I was on my way to the
wake, I heard a commotion at a near distance, which was followed by shouting and
crying so I hurriedly went to the place. Upon my arrival, I saw my daughter lying in
the ground, bathe in her own blood, with Angelyn hoarsely shouting and crying for
help. Trembling and lost for words, I asked Angelyn who was the culprit of the crime
which she answered without hesitation as one named Dino Q. dela Cruz. I asked her
where Dino is and she replied, “dumalagan na tita” ( he has already fled auntie). Crying
for help, I asked and begged the people around us to help me bring my daughter to the
nearest hospital which was responded to with haste by Alan Burt Altar and other
relatives who were around. The sworn statement of Alan Burt Altar is hereunto attached
and made an integral part of this complaint as Annex “B”;

4. Upon arrival at the Tacloban City Hospital, Dr. Pia Gomez, immediately attended my
daughter and after a thorough examination, declared her dead on arrival. The medico-
legal autopsy report, the NSO death certificate and a certification from the City Civil
Registrar of Rhyzza Mae A. Malate is hereunto attached and made an integral part of
the complaint as Annex “C” , “ D”, and “E”, respectively;

5. While at the hospital, I inquired Angelyn if the said Dino Q. dela Cruz was the same
Dino Q. dela Cruz who is our neighbor and who came to our house earlier that day to
borrow money from me which she positively identified as the same person. The sworn
 statement of Angelyn A. Gonzaga is hereunto attached and made an integral part of this
complaint as Annex “F”;

6. I denied the request of said Dino Q. dela Cruz because of his notorious character in our
neighborhood as a drunkard, gambler and without a permanent job and that after the
said refusal to lend money, he mumbled and uttered to me that I would surely regret
my decision which statement I took for granted.

7. I immediately reported the stabbing incident on or about 12:00 o’clock midnight at the
Marasbaras Police Station which is the nearest police station. The original copy of the
excerpt of the police blotter duly issued by Senior Police Inspector Virgilio Lentejas
III of Marasbaras Police Station is hereunto attached and made as an integral part hereof
as Annex “G” of the complaint;

8. I am therefore executing this affidavit freely and voluntarily in support of my intent to

file a case for MURDER and/or the appropriate criminal case against Dino Q. dela
Cruz, who is 30 years of age and a resident of Block 30, Lot 9, New York Street, Phase
4, V&G Subdivision, Tacloban City.

IN WITNESS WHEREOF, I have hereunto set my hand this 2nd day of July, 2013 at
Tacloban City, Philippines.

RIZA A. MALATE
Affiant

SUBSCRIBED AND SWORN to before me this 2nd day of July 2013 at Tacloban City,
Philippines and I FURTHER CERTIFY that I have personally examined the affiant and I am
satisfied that he/she has read and personally understood the contents of her foregoing “Complaint-
Affidavit”.

HAROLD B. LACABA
Prosecutor II
Roll No. 51379-2006
IBP No. 808787-1/3/11
PTR No. 4128464- 1/3/11; Leyte
MCLE Compliance III No. 0013601
Issued on April 22, 2010
REPUBLIC OF THE PHILIPPINES )
City of Iloilo ) S.S.
x---------------------------------------------x

AFFIDAVIT-COMPLAINT

I, UJELL GRECIA, of legal age, Filipino, single and a resident of San Isidro, Jaro, Iloilo
City, after having been sworn to in accordance with law, hereby depose and say that:

1. I am a friend and co-worker of Greg Oro at Teletech Iloilo;

2. On July 13, 2015 at around 9:32 p.m, I, along with Marc Arcilla and Greg Oro, went
to It’s Okey KTV Bar In Diversion Road, Mandurriao, Iloilo City to sing and have
some drinks;
3. At around 10:15 p.m of the same date, while Marc Arcilla was singing, Oro excused
himself from us and went to the restroom;
4. At around 10: 40 p.m., I saw Oro walking towards our direction and upon reaching
our table, Oro grabbed the microphone from Arcilla and started singing;
5. Then later on, I heard a gunshot and saw Oro falling on his knees while holding his
chest. I looked around to know who had shot Oro, then I saw the accused standing on
the other table near us with a gun pointing towards Oro;
6. A few moments after the first shot, another shot was then made by the accused to Oro.
I immediately look ran towards the counter of the KTV bar to hide from the accused.
Then, I heard the accused shouting “Amo ni makwa niyo kung magdiskarte kamo sa
nobya ko”;
7. Upon ensuring that the accused left the KTV Bar, I immediately went to where Oro
was lying unconscious with lots of blood pooling on the floor;
8. That I, along with Arcilla and other people who were also there, brought immediately
Oro to Doctors’ Hospital Inc. But at around 11:20 p.m. of the same date, Oro was
declared dead on arrival by one of the Physicians therein. Attached herewith is the
Death Certificate of Oro and made an integral part of this complaint as Annex “A”;
9. A police officer from Mandurriao Police Station had just informed me thereafter
that the accused was apprehended them and was already locked-up in their station;
and
10. I am therefore executing this affidavit freely and voluntarily in support of my intent
to file a case for Murder against Jose Judhill Gelito, who is of legal age and a
resident of Brgy. San Isidro, Jaro, Iloilo City.
 IN WITNESS WHEREOF, I have hereunto set my hand this 15th day of July 2015 at
Iloilo City, Philippines.

UJELL GRECIA
Affiant

SUBSCRIBED AND SWORN TO before me this 15th day of July 2015 at Iloilo City,
Philippines and I further certify that I have personally examined the affiant and I am satisfied
that he has read and personally understood the contents of his foregoing “Complaint-
Affidavit”.

VICTORY O. HELER
Prosecutor II
Roll no. 12345
IBP No. 8-8767- 1-23-15
PTR No. 42189837- 1-23-15/ Iloilo City
MCLE Compliance No. IV-0000123876
Issued on April 22, 2015