REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE PROSECUTOR
PASAY CITY

Jack B. Nicolas,
Complainant,
-versus-

I.S. 9234
For: Rape with

Homicide
George C. Harvey,
Respondent.
x--------------------------------------------------------------------------------------------------------x

COMPLAINT-AFFIDAVIT

I, Jack B. Nicolas, of legal age, Filipino and a resident of #2128 P.

Burgos, Pasay City after having been duly sworn to in accordance with law,
do hereby depose and state that:
1. I am the father of Suzie D. Nicolas, 15 years old, a Grade 11 student
at Saint Marys Academy at P. Burgos, Pasay City. A machine copy of
the registration of live birth of Suzie D. Nicolas is hereunto attached
and made as an integral part hereof as Annex A.
2. Last November 16, 2015, Suzie left for school that day but she did not
returned that afternoon. I tried to call her cellphone many times but
she never answered it, which is odd because it was not in her nature to
not answer her cellphone.
3. At 7 oclock in the evening of that same day, extremely worried of her,
I called her classmates and closest friends if they know the
whereabouts of Suzie but none of them know where she is.
4. That following day, hearing no news of her, I went to the police station
to report that my daughter, Suzie, is missing. An original copy of
certification of police blotter issued by Senior Police Inspector Joseph C.
Suarez is hereunto attached and made as an integral part hereof as
Annnex B of the complaint.
5. On that same day, I tried to look for her in our neighborhood hoping
that I can get informations of her whereabouts.
6. While roaming around, I approached a group of tricycle driver. I showed
them the photo of my daughter and asked if anyone of them saw her.
Her photo is hereunto attached and made as an integral part hereof as
Annex C.

7. One of the drivers, whose name is Ray D. Salcedo, told me that on the
day of November 16, 2015 at around 5 o clock in the afternoon, he
saw her with a man.
8. He described the man as tall, fair skinned and has a beard.
9. Further, when he saw them, it looks like they are arguing. He also
heard Suzie saying to that man Tigilan mo na nga ako!Layuan mo
ako! A copy of his sworn statement is hereunto attached and made as
an integral part hereof as Annex D.
10.
On that the same day, I asked Ray to go with me in the police
station to have a cartographic sketch of the man he saw that day. A
machine copy of the cartographic sketch is hereunto attached and
made as an integral part hereof as Annex E.
11.
After the sketched has been made, I identified the man Ray saw
that day. The man in the sketch is George C. Harvey who happens to
be our neighbor. He lives two houses away from our home.
12.
After we came from the police station, I went straight to Georges
house to ask if he saw my daughter on the day of November 16, 2015
but he told me that he never saw her that day.
13.
Suspicions grew on me that day when he told me that he never
saw my daughter so I decided to check his every move and his
whereabouts.
14.
Since that day, I never saw him going out of his house. I tried to
sneak on his garden to see if he is still there and notice that there are
signs of him inside the house because I heard a music playing inside
his house.
15.
On the night of November 20, 2015 at around ten o clock, as I
passed by at Georges house, I saw him leaving with a big luggage bag
on his hand. I got suspicious of him so I go back to our house to get my
bicycle and decided to follow him without him noticing me.
16.
As I follow him, I noticed that the road we are taking is going to a
dumpsite near our barangay.
17.
After five minutes of ride, I saw him parked in a tree and he
walked down holding the big luggage bag. I saw him that upon
reaching the pit hole, he threw the big luggage bag he was holding.
18.
After he left, I go near the pit hole to check the big luggage bag.
After I get it, I noticed that the luggage bag was stained with blood. I
got curious of what is the content of the bag so I opened it. I was
shocked that the content of the luggage bag is the lifeless body of my
daughter covered with blood.
19.
I found the lifeless body of my daughter with several hack
wounds inflicted on her face, neck and extremities, one hand and one
finger were totally severed.
20.
I immediately called the Pasay Police Station and reported what I
saw and minutes after, the police officers arrived. A copy the police
Spot Report dated November 20,2015 is attached hereunto and made
as an integral part hereof as Annex F of this complaint.
21.
The body of my daughter was brought in the nearest hospital for
post- mortem examinations.
22.
Based on the result of post-mortem examination conducted by
Dr. Luigi A. Sy, she died from loss of blood due to multiple hack
wounds. Her underwear was blood stained. Also, she had hymenal

lacerations and a whitish discharged was found on her vagina. The

whitish discharged found on the vagina of the victim is positively
matched with the DNA of George C. Harvey. The medico-legal autopsy
report and the DNA test result is hereunto attached and made as an
integral part of this complaint as Annex G and H, respectively.
23.
In a special complex crime of rape with homicide, the following
elements must concur: (1) the accused had carnal knowledge of a
woman; (2) carnal knowledge of a woman was achieved by means of
force, threat or intimidation; and (3) by reason or on occasion of such
carnal knowledge by means of force, threat or intimidation, the
accused killed a woman. Both rape and homicide must be established
beyond reasonable doubt.
24.
Based on the examinations conducted to the body of my
daughter, Suzie, it is sufficient to establish the inescapable conclusion
that the respondent committed the complex crime of rape with
homicide. When taken together, the circumstances point to the
respondent as the perpetrator of the despicable deed.
25.
That I am executing this complaint-affidavit to charge George C.
Harvey, for the special complex crime of Rape with Homicide, defined
and punished under Republic Act 8353, Article 266-A in relation to
Article 266-B of the Revised Penal Code.

IN WITNESS WHEREOF, I hereby affix my signature this 23rd

November 2015, in Pasay City.

day of

JACK B. NICOLAS
Complainant
CERTIFICATION
SUBSCRIBED AND SWORN to before me this 23 rd day of November
2015, in Pasay City. I hereby certify and examined the affiant and I am
satisfied that she voluntarily executed and fully understood this Complaint
Affidavit.

TIMOTHY C. GALANG
Associate Prosecution
Attorney II

Doc. No. 4356

Page No. 04
Book No. 2167
Series of 2015