Republic of the Philippines

REGIONAL TRIAL COURT

Angeles City, Pampanga
Branch 1, Angeles City

PEOPLE OF THE PHILIPPINES

Criminal Case No: 12345
-versus- For: RAPE (Article 266-A, paragraph 1
of the Revised Penal Code, as amended)
Juan Manyak,
Accused.
x------------------------------------x

INFORMATION

The undersigned City Prosecutor accuses Juan Manyak, a resident of

1234 Sampaguita St., Salapungan, Angeles City, Philippines of the crime of
RAPE, defined and penalized under Article 266-A, par. 1, as amended,
committed as follows:

That on January 12, 2019, at the accused’ apartment unit at 1234

Sampaguita St., Salapungan, Angeles City, Philippines, the above-named

accused, did then and there, willfully, unlawfully and feloniously raped the
person of Amanda Paige, by inserting his penis into the complainant’s vagi-
na while the complainant is sleeping/unconscious.
That the accused invited the complainant to drink some beer along
with a few friends to celebrate his promotion and after a few shots the com-
plainant felt dizzy and she decided to lie down on his bed. That the com-
plainant woke up due to the painful sensation in her vagina and there saw
accused undressed and having sexual intercourse with her and due to the

Accused’ superior strength all she was able to do was to clutch tightly and

painfully pull complainant’s hair with his other hand, while he performs the
sexual act.
 That the accused placed a kitchen knife directly on the complainant’s
throat and warned her not to tell anyone about the incident or else he would
come back to kill the complainant.
That as a result of said rape, the victim suffered actual and moral
damages in the amount as may be awarded by Honorable Trial Court under
the Provisions of the New Civil Code.

CONTRARY TO LAW.
Angeles City, Pampanga, Philippines, January 18, 2019

Atty. Ivan Manaligod

City Prosecutor

I hereby certify that a preliminary investigation have been conducted

in this case, the witnesses having been examined under oath; that on the ba-
sis of the sworn statement and other evidence submitted before me, there is
reasonable ground to believe that the offense charged was committed.

Subscribed and sworn to before me this 19th day of January 2019, in

Angeles City, Philippines.

WITNESSES:

Rochelle Pangilinan – Angeles City, Philippines

Jopay Paguia – Angeles City, Philippines
Police Chief Inspector Rodrigo C. Dela Cruz- Angeles City Police Station 1,
Philippines
BAIL RECOMMENDED: TWO HUNDRED THOUSAND PESOS (PhP
200,000.00)
 APPROVED
City Prosecutor Roll No. 12345
MCLE Compliance No. IV - 000555

Address of Accused: 1234 Sampaguita St., Salapungan, Angeles City, Phil-

ippines

CERTIFICATE OF PRELIMINARY INVESTIGATION

I
I hereby certify that a preliminary investigation in this case was successfully
conducted by me in accordance with law; that I examined the Complainant
and her witnesses; that there is reasonable ground to believe that the offence
charged had been committed and that the accused is probably guilty thereof;
that the accused was informed of the Complaint and the evidences submitted
against him and was given the opportunity to submit controverting evidence;
and that the filing of this information is with the prior authority and approval
of the City Prosecutor.

Atty. Ivan Manaligod

City Prosecutor

SUBSCRIBED AND SWORN TO BEFORE ME this 19th day of January

2019 in Angeles, Philippines.

Atty. Ivan Manaligod

City Prosecutor

Bail Recommended: P200, 000.00

 Republic of the Philippines
REGIONAL TRIAL COURT
Angeles City, Pampanga
Branch 1, Angeles City

PEOPLE OF THE PHILIPPINES

Complainant

Criminal Case No: 12345

-versus- For: RAPE (Article 266-A, paragraph 1
of the Revised Penal Code, as amended

JUAN MANYAK
Respondent

X-----------------------------------------------------x

COMPLAINT - AFFIDAVIT

I, Amanda Paige, of legal age, Filipino citizen, Single, residing at 123 Dahlia St.
Baranggay Lourdes Sur, Angeles City, Pampanga, Philippines, after having duly sworn to
in accordance with law do hereby depose and say:

(1) That I am the complainant in this case;

(2) That I am formally charging respondent Juan Manyak, with postal address at no.
1234 Sampaguita St., Salapungan, Angeles City, Philippines, for the crime of
RAPE penalized under Article 266-A, par. 1 of the Revised Penal Code, as
amended, committed as follows, to wit:

(a) That at around 7:00 pm in the evening of Saturday, January 12, 2019, I
was in my apartment at 123 Dahlia St. Baranggay Lourdes Sur, Angeles
City, Pampanga when herein accused called me and said that he was pro-
moted as a training specialist at the BPO company where he works;

(b) That after hearing the news he invited me along with two other friends for
some drinks at his apartment;

(c) That I have known the accused for 3yrs already as he and I worked on a
same BPO company before;

(d) That because of our friendship and trust in his person I complied with his
invitation and at around 8:00pm the same evening we went to a nearby
seven eleven to buy the beers;

(e) That at around 11:00pm after drinking a few bottles of beer I suddenly felt
dizzy and decided to lie down the nearby bed which is the bed of the ac-
cused;

(f) That after falling asleep I felt rather odd sensations around my body but
chose to disregard it because I was dizzy;
 (g) That after a few minutes from that incident I felt a searing pain on my vag-
inal area which caused me to wake up;

(h) That after waking up I saw the accused and myself along inside the room
along with my shirt lifted up and my underwear removed;

(i) That the next I saw was the accused on top of me penetrating my vagina
and violently humping me which caused me to struggle;

(j) That because of the accused superior strength I wasn’t able to prevent him
from having carnal knowledge with me;

(k) That after the said incident while I was gathering my clothes he pointed a
knife at my throat while uttering the words that no one should know about
anything that happened that night because if I did he will hurt not only me
but my entire family;

(l) That after the said incident I immediately went to my parents to tell them
what happened;

(m) That despite his threats I came to a decision to file a criminal case against
the Juan Manyak for RAPE.

(3) That I am executing this affidavit to attest to the truth of the foregoing statements,
and for the purpose of charging respondent JUAN MANYAK for the crime of
RAPE penalized under Article 266-A, par. 1 of the Revised Penal Code, as
amended

IN WITNESS WHEREOF, I have hereunto affixed my signature this 19th day of

January 2019, in the City of Angeles.

AMANDA PAIGE
Complaint/Affiant

SUBSCRIBED AND SWORN TO before me this 19th day of January 2019, in

Angeles City.

IVAN MANALIGOD
City Prosecutor

CERTIFICATION

I hereby certify that I personally examined the affiant and that I am satisfied that
he voluntarily executed and understood his complaint-affidavit.

IVAN MANALIGOD
City Prosecutor
 Republic of the Philippines
REGIONAL TRIAL COURT
Angeles City, Pampanga
Branch 1, Angeles City

PEOPLE OF THE PHILIPPINES,

Criminal Case No: 12345
-versus- For: RAPE (Article 266-A,
paragraph 1of the Revised Penal Code, as
JUAN MANYAK, amended)
Accused.
x------------------------------------------------x

NOTICE OF ARRAIGNMENT AND PRE-TRIAL

TO:
JUAN MANYAK,
1234 Sampaguita St., Salapungan, Angeles City, Philippines

AMANDA PAIGE
123 Dahlia St. Baranggay Lourdes Sur, Angeles City, Pampanga, Philippines

G R E E T I N G S:

Please be informed that the arraignment of the accused and the pre-trial in the
above-entitled case has been set on January 21, 2019 at 5:30 PM at the RTC Branch 1,
Angeles City, Pampanga and that the pre-trial conference may take place thereafter to
consider the following:

1. Plea bargaining
2. Stipulation of facts
3. Marking for identification of the parties
4. Waiver of objections to admissibility of evidence
5. Such other matters as will promote a fair and expeditious trial; and
6. Determination of civil liability, if any.

The accused must be present at the arraignment and personally enter his plea. In
case of failure of the complainant to appear despite due notice, the Court may allow the
accused to enter a plea of guilty to a lesser offense with the conformity of the trial prose-
cutor alone.

The accused and the complainant are further directed to bring all documents rele-
vant to the case.

FAIL NOT UNDER PENALTY OF THE LAW.

 WITNESS, the HON. _______________, Presiding Judge of this Court, this 18th
day of January 2018 at Angeles City, Philippines.

Kim Domingo
Legal Researcher II/OIC

1ST INDORSEMENT

Respectfully referred to the PROCESS SERVER OF THIS COURT for service

and return. Please make your return before the scheduled date of hearing.

Kim Domingo
Legal Researcher II/OIC
 Republic of the Philippines
DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
City of Angeles

PEOPLE OF THE PHILIPPINES

Criminal Case No: 12345
-versus- For: RAPE (Article 266-A, paragraph 1
of the Revised Penal Code, as amended)
Juan Manyak,
Accused.
x------------------------------------x

RESOLUTION

This resolves the complaint for RAPE against Respondent JUAN MAN-
YAK filed by Complainant AMANDA PAIGE.

In support of its complaint, herein Complainant attached the following doc-

uments:

1. Medico Legal Certificate showing lacerations on the complainants vag-

inal orifice showing the use of force during the sexual penetration is-
sued by Dr. Juan Manuel.
2. Complaint affidavit executed by the complainant Amanda Paige.

After all considerations the Office of the City Prosecutor found out that on
That during the evening of Saturday, January 12, 2019 at around 7:00 pm,
while the complainant was in her apartment at 123 Dahlia St. Baranggay
Lourdes Sur, Angeles City, Pampanga the herein accused called her via mo-
bile phone and invited the complainant for some drinks in accused apartment
building at 1234 Sampaguita St., Salapungan, Angeles City, Philippines
along with two(2) of her friends. That at the same nights the herein accused
forced his way and there and then willfully, unlawfully and feloniously
raped the person of Amanda Paige, by inserting his penis into the complain-
ant’s vagina while the complainant is sleeping/unconscious.

In the commission of Rape as defined under Article 266-A of the Revised

Penal Code, as amended is committed by any man who shall have carnal
knowledge of a woman under any of the following circumstances a)
Through force, threat, or intimidation; b) When the offended party is de-
prived of reason or otherwise unconscious; c) By means of fraudulent mach-
ination or grave abuse of authority; and d) When the offended party is under
twelve (12) years of age or is demented, even though none of the circum-
stances mentioned above be present or By any person who, under any of the
circumstances mentioned in paragraph 1 hereof, shall commit an act of sex-
ual assault by inserting his penis into another person's mouth or anal orifice,
or any instrument or object, into the genital or anal orifice of another person.

Based on the foregoing, the undersigned finds that there is probable cause to charge re-
spondent JUAN MANYAK for RAPE under Article 266-A, paragraph 1. Juan Manyak
forced himself inside Amanda Paige and raped the her while she was deprived of rea-
son/unconscious.

WHEREFORE, it is most respectfully recommended that an Information for RAPE un-

der Article 266-A, paragraph 1 be filed against JUAN MANYAK before the Regional
Trial Court of Angeles City, Philippines. No bail recommended.

Angeles City, Philippines, 18th January 2019.

IVAN PAUL J. MANALIGOD

City Prosecutor Roll No. 921122
MCLE VI-0000461/1-26-2018

Copy Furnished:
AMANDA PAIGE
123 Dahlia St. Baranggay Lourdes Sur, Angeles City, Pampanga, Philippines