REPUBLIC OF THE PHILIPPINES)

CITY OF PASAY ) s.s.

COMPLAINT-AFFIDAVIT

I, Philip A. Santos, Filipino, 60, male, widower, and a resident of 42 Dalandanan St. City
of Pasay, Philippines, after being sworn to in accordance with law, depose and state:

1. That I know the person of Hero L. Santos, who is my son residing at the same house
at No. 42 Dalandanan St. City of Pasay, Philippines;

2. That, at around 7:00 in the evening of January 15, 2018, I was at home, eating
dinner with my wife and son, Hero Santos;

3. That, while eating dinner, the accused asked for money and permission to go out with
his friends;

4. That, upon asking, the deceased refused: stating it was late and they don’t have any
money.

5. That, after being refused, the accused got furious and stormed off to his room;

6. That, a few moments later, the accused returned armed with a “balisong” and rushed
toward the deceased, stabbing her multiple times at her back.

7. That, I called the police hotline, which provided the medical assistance. Upon
reaching the Adventist Medical Center, my wife was declared dead on arrival;

8. I am therefore executing this Complaint-Affidavit in support of the charges of

violation of Art. 246 Revised Penal Code for Parricide against the said Hero L.
Santos, who may be served with subpoena and other processes of this Honorable
Office at his residence at 42 Dalandanan Street, City of Pasay, Philippines;

IN WITNESS WHEREOF, I have hereunto set my hand this 17th day of January, 2018 at the
City of Pasay, Philippines.

PHILIP SANTOS
Affiant-Complainant

SUBSCRIBED AND SWORN to before me this 17th day of January 2018, affiant
exhibiting to me his Passport No. issued on November 3, 2016, at the City of Manila.

CERTIFICATION

This is to certify that I have personally examined the affiant and I am satisfied that he
understood this complaint-affidavit and that he voluntarily executed the same.

JESSA MAE B. ABRENICA

ASST. CITY PROSECUTOR

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
City of Pasay
 Branch 100

THE PEOPLE OF THE PHILIPPINES,

Plaintiff,

CRIMINAL CASE NO. C-1000-20

-versus- for violation of Art. 246 of Revised Penal Code
(Parricide)

HERO SANTOS,
Accused.

X--------------------------------------X

INFORMATION

The undersigned Assistant City Prosecutor of the City of Manila, upon prior written
authority of the City Prosecutor, France Dela Rosa, accuse HERO L SANTOS of crime
punishable under Art. 246 of the Revised Penal Code, committed as follows:

That on or about the 15th day of January, 2018, in the City of Pasay,
Philippines, and within the jurisdiction of this Honorable Court, the said accused, did then
and there wilfully, unlawfully and feloniously commit violation of Art. 246 of Revised Penal
Code on the person of HERO SANTOS, by stabbing his mother, the complainant’s wife Mrs.
Gemma L. Santos without provocation her death.

CONTRARY TO LAW.

City of Pasay, January 20, 2018.

JESSA MAE B. ABRENICA

Assistant City Prosecutor

BAIL RECOMMENDED: NONE

JESSA MAE B. ABRENICA

Assistant City Prosecutor
 REPUBLIC OF THE PHILIPPINES
DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
MANILA

Philip A. Santos
Complainant,

- versus - I.S. No. I-123-456

For: Violation of Art. 246 Revised Penal Code

(Parricide)

HERO L. SANTOS
Respondent.
x----------------------------------------------------x

COUNTER – AFFIDAVIT

I, HERO L. SANTOS, of legal age, single, Filipino and with resident address at, 42
Dalandanan Street, Pasay City, Philippines, however, for purposes of this instant criminal
complaint, notices and other processes are requested to be served at the Law Firm’s address
of his lawyer, LLENA MALOTA YBANEZ AND QUIAMCO LAW OFFICE, Unit 111, Avida
Towers Prime Taft, Pasay City, after having been duly sworn in accordance with law, do
hereby depose and state, that:

(1) That I am the same respondent to the Complaint-Affidavit for alleged violation of
Article 246 of the Revised Penal Code, docketed as I.S. No. I-123-456;

(2) That, I strongly and specifically denies as downright lies the above material
allegation in said complaint-affidavit, the truth being that:

(i) At around 6:30 in the evening of 15th January 2018, I heard my

parents arguing about financial matters;

(ii) At around 7:00 in the evening of the same date, we were eating
dinner and I received a text message from my friend, Laura San Juan,
inviting me for a cup of coffee. A copy of text message is attached
hereto as Exhibit “1”;

(iii) After dinner, I said to my Mom “Ma alis ako, magkikita kami ni
Laura”;

(iv) I booked an Uber to Starbucks Harisson. A copy of Uber Receipt is

attached hereto as Exhibit “2”;

(v) We ordered drinks and desserts. We had a lengthy conversation about

investment and marketing. A copy of Official Receipt is attached
hereto as Exhibit “3”;

(vi) After our conversation, we bid each other goodbye and took a picture.
A copy of our picture is attached hereto as Exhibit “4”;

(vii) As I arrive home, I saw numerous bystanders outside our house and I
immediately enter to know the reason behind the commotion;

(viii) That I was extremely surprised that the police officer arrested me
without warrant of arrest;

(3) That the case was filed against me is motivated by bad faith and was forced to file
because of reason known to him;

(4) That the above-stated allegations of the Complainant forming the basis of this
 instant criminal complaint are mendacious, perjuries and baseless and likewise
deny the foregoing allegations as well as the material averments of the
Complainants’ statement, and assert that I am not liable for violation of Article
246 of the Revised Penal Code.

I am executing this counter-affidavit, to attest to the truth of the foregoing and for
whatever legal purpose it may serve.

Pasay City, 18th January 2018.

HERO L. SANTOS
Respondent-Affiant

Assisted by Counsel:

LLENA, MALOTA, YBANEZ AND QUIAMCO LAW OFFICE

Counsel for the Respondent
Unit 111, Avida Towers Prime Taft, Pasay City
Contact No. (02) 321-45-32

BY:

SUBSCRIBED and SWORN, to before me this 18th January 2018 at Pasay City

__________________
Investigating State Prosecutor

CERTIFICATION

I HEREBY CERTIFY that I personally examine the Respondent and I am fully convinced and
satisfied that he voluntarily executed and understood his Counter-Affidavit.

__________________
Investigating State Prosecutor

Doc No. _________;

Page No. _________;
Book No. _________;
Series of 2018.
 Republic of the Philippines
DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
City of Manila

RE: COMPLAINT OF CHUCK LIDEL

VS. CHUCK LIDEL JR. I.S. NO. E-678-456,

FOR VIOLATION OF ART. 246

REVISED PENAL CODE
(PARRICIDE)

X-------------------------------------------------X

RESOLUTION

SUBMITTED for resolution is a complaint for violation of Art. 246 of the Revised
Penal Code (Parricide) allegedly committed during the October 29, 2012, at Manila,
supported by the sworn statement of the complainant and photocopies of the police report of
the incident.

In his sworn statement, the complainant alleges that, during the afore-stated period
of time and place, the respondent without rhyme or reason stabbed the victim Mrs.
Francesca Lidel resulting to her death.

However, the respondents claim that, the filing of the complaint is without legal basis
since the there was no such act and the complainant was in his friend Lucio See’s house in 47
West Ave. Quezon city.

IN LIGHT OF THE FOREGOING, the undersigned finds sufficient cause to hold the
respondent CHUCK LIDEL JR. for VIOLATION of ART 246 OF THE REVISED PENAL
CODE (PARRICIDE).

Manila, December 1, 2012.

DANA PUTI
Assistant City Prosecutor

APPROVED:

FRANKLIN SANTIAGO
City Prosecutor