REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE PROSECUTOR
MANILA

THE PEOPLE OF THE PHILIPPINES, NPS NO.

Complainant,
FOR: KIDNAPPING
AND FAILURE TO
RETURN MINORS
(VIOLATION OF ART.
270 OF THE RPC)

-versus-

Joshua Chu,
Accused,
x-------------------------------------x

CRIMINAL COMPLAINT AFFIDAVIT

I, Jason Lopez, the undersigned, of legal age, and a resident of 24

Carissa Gardenville Condominium Sta. Mesa, Manila, accuses
Joshua Chu, of the crime of Kidnapping and failure to return a minor,
committed as follows:

1. That I am married to Dianna Lopez y Chu, who is also the sister

of the respondent.
 A copy of our Certification of Marriage issued by the Republic of
the Philippines, City of Manila is hereto attached as Annex A

2. That during our marriage, we gave birth to our wonderful daughter,

namely, Elise Lopez.

A copy of the Certification of Birth issued by the City of Manila is

attached hereto as Annex B

3. That on September 23, 2017, as me and my wife will celebrate our

anniversary, the respondent offered to take care of our 12 year old
daughter while we were out of the house, but he would take her
out rather than stay at the house. We agreed to his request, since
he is the brother of my wife and the uncle of my daughter.

4. Upon returning late at night to our residence, we found that our

daughter was not home yet. We immediately tried to contact the
respondent, but to no avail, there was no response.

5. We immediately filed for a police blotter, reporting that our

daughter, Elise Lopez and the respondent, Joshua Chu is
missing.

A copy of the Police blotter No.1738 is attached hereto as Annex

C

6. Three days after the filing of the police blotter, there were still no
report of the missing people. This caused our worries to escalate
and hope that both them are fine and well.

7. A week has passed since the missing persons incident, a report

was filed to the police stating that they saw a man that looked like
the respondent enter a building, addressed at Padre Campa street
Sampaloc, Manila.

8. After receiving the report, police officers immediately took action

and entered the building, where they found our daughter along
 with the respondent.

9. Elise was immediately taken to the hospital for physical and

psychological examination, it was revealed that she is physically
unharmed but is clearly traumatized from being taken away from
her parents.

10. Upon seeking legal consultation with my lawyers. I was

informed that the respondent should be placed on trial for
committing the crime of Kidnapping and failure to return a minor as
provided for under Article 270 of the Revised Penal Code of the
Philippines.

11. Accordingly, the crime of kidnapping and failure to return a

minor has to essential requisites:

a) The offender is entrusted with the custody of a minor person;

and
b) The offender deliberately fails to restore the said minor to his
parents or guardians.

12. Pursuant to the aforementioned elements, the respondent was

entrusted with the custody of my daughter, who is a minor person.

13. The respondent deliberately failed to restore my daughter, a

minor person, to me or my wife, who are her parents.

14. I am executing this sworn statement for the purpose of charging

the respondent with having violated Article 270 of the Revised
Penal Code of the Philippines.

IN WITNESS HEREOF, I have hereunto affixed my signature on OCTOBER

7, 2017 Manila City, Philippines.
Jason Lopez
Complainant/Affiant
 SUBSCRIBED AND SWORN to before me, the undersigned
prosecutor, this 7th day of October 2017, in the City of Manila, Philippines.

The undersigned Prosecutor certifies that he personally examined the

affiant and that he is satisfied that he voluntarily executed and understood
his complaint-affidavit.

Atty. Harvey Specter

Assistant City Prosecutor