Republic of the Philippines )

) S.s.

COMPLAINT-AFFIDAVIT

I, ____________________, of legal age, single, Filipino and

resident of ____________________, under oath, hereby depose and
say, that:

1. I hereby formally charge the following persons for the crime of

Libel under section 4, (c) paragraph 4 of R.A. 10175 also known as
the Cybercrime Prevention Act of 2012;

1.a. __________________, _____________,

and _________________, all of legal age and residents of
_____________________________, herein referred to as
RESPONDENTS.

2. On __________________, respondents by conspiring and

confederating to malign my person, character and honor caused
the posting and publication of malicious, false, demeaning, and
defamatory imputations published for all to see through their
respective Facebook accounts on even date.

Attached are the full text of libelous posts and comments hereto
collectively referred as Annex "A".

3. Said posts published by respondents contained malicious

imputations with bad intentions and unjustifiable motives,
purposely to malign, dishonor, discredit, insult and assassinate my
character and good reputation to the public as well as to my
neighbors and colleagues, an excerpt of which are hereby quoted:

4. The afore-quoted portions of the online posts authored and posted

by the respondents created in the minds of the readers that I am
liar, deceitful and a fake faithful.

5. The posts even escalated to a plot to kill me and threat to lock us

up, so we could no longer enter and exit our property as evidenced
by these posts:
 6. The Facebook posts written and published by respondents have no
factual basis, are highly speculative and were all false statements
made to destroy my reputation as a person and a devout religious
servant of our Church. Respondents were motivated by bad faith
in the publishing of the said posts online to defame, embarrass and
discredit me to my colleagues, friends, family and to the readers
and patrons of Facebook;

7. The libelous posts having been published through Facebook, a

social media website accessible to and is made available to the
general public was read by the said general public, including my
colleagues, friends and family among others;

8. Due to the said malicious public imputations by respondents, I

suffered and continue to suffer serious anxiety, besmirched
reputation, mental anguish, sleepless nights, not to mention the
damage they have caused to my reputation and honor among the
readers and patrons of Facebook and the general public;

9. Due to such grossly unjustified malicious and libelous

imputations, I therefor pray that respondents be made to pay
jointly and severally, the damages I was made to suffer as a result
of the online published article in whatever amount the appropriate
court deems sufficient and proper together with the attorney’s fees
and the cost of this suit.

I hereby execute this affidavit to attest to the truth of the foregoing

facts and hereby request the investigating officer to file the crime of Libel
under R.A. 10175 and other crime or crimes committed against the herein
Respondents.

IN WITNESS WHEREOF, I have hereunto set my hand this 9TH

day of May 2018 in Manila, Philippines.

________________
Affiant

SUBSCRIBED AND SWORN to before me this 9th day of May

2018.

__________________________
Solemnizing Officer