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Republic of the Philippines)

Muntinlupa City )s.s.


x------------------------------x

AFFIDAVIT-COMPLAINT

I, __________, of legal age, single, Filipino and resident of


21___________, under oath, hereby depose and say, that:

1. I am the sports editor of the _________ since July 2013.


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. XXXX, Editor-In-Chief, XXXXXXXX, Columnist


and Features Editor of the ___________all of legal
age and with business address
at______________________, herein referred to as
RESPONDENTS.

2. Manila Mirror Inquirer is a newspaper of general


circulation in Metro Manila with business address at at
__________________________.

3. On_____, respondents by conspiring and confederating to


malign my person, character and honor caused the
publication through the ____________________
under the Opinion page, an article entitled “In the Absence
of Sportsmanship: A Grossly Biased Writer” written by
ColumnistXXXXX, published for all to see through their
office in Muntinlupa City on even date.

Attached is the full text of libelous article hereto referred as


Annex "A".
4. Said article published by respondents, without observing
the ethical standards of journalism, contained malicious
imputations with bad intentions and unjustifiable motives,
purposely to malign, dishonor, discredit, insult and
assassinate my characeter and good reputation to the
public as well as to my constituents, an excerpt of which are
hereby quoted:

“However, what ____ does not understand - even after


being in the field of news writing for years - is that
when one is an editor who writes articles made
available to the public, all biases should be eliminated.
His lack of proper research in writing his recent article
on the_____ shows his incompetence and
unworthiness. He wrote like an amateur, as if an
apprentice that was only recently hired to write for a
renowned paper. Unfortunately for the company he
works and writes for, Canlas has exposed his and the
company’s weakness, inefficiency and ineffectiveness
as deliverers of news which failed to be factual, actual
and truthful. His work was defamatory as against the
PBA, without him even knowing it.”

5. The afore-quoted portion of the online article authored by


respondent __________published by the herein
respondents created in the minds of the readers that I am
liar, deceitful and biased in my work as a sports editor of
Manila Star Bulletin.

6. The article written and published by respondents has no


factual basis, is highly speculative and was all false
statements made to destroy my reputation as a writer and
an editor of one of the country’s renowned newspapers.
Respondents were motivated by bad faith in the publishing
of the said article online to defame, embarrass and
discredit me to my colleagues, friends, family and to the
readers and patrons of our publication;
7. The libelous article having been published through the
___________Website, a 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
career, reputation and honor among the readers and
patrons of the Manila Star Bulletin and the general public;

9. Due to such grossly injustifed 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 Honorable 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 prosecutor to
file the crime of Libel under R.A. 10175 against the herein
Respondents.

IN WITNESS WHEREOF, I have hereunto set my hand


this 14th day of March 2016 in Muntinlupa City, Philippines

Affiant

SUBSCRIBED AND SWORN TO before me this 14th day of


March 2016 at Muntinlupa City, Philippines the following affiant
_________exhibiting to me her Government issued Non-
Professional Driver’s License no. _____19 being sufficient and
competent evidence of his/her identity in pursuant to the 2004
Rules of Notarial Practice.

Doc. No. ____;


Page No.____;
Book No. ____;
Series of 2016