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REPUBLIC OF THE PHILIPPINES )

MAKATI CITY )S.S.

COMPLAINT-AFFIDAVIT

I, LINDA M. HAPPY, 40 years of age, Filipino, single, residing at 13


Flame Tree Road Barangay Forbes Park, Makati City, after having duly sworn
to in accordance with law, hereby depose and say that:

1. I was employed by Mr. and Mrs. White in 2003 to be a maid in their


household. With the death of Mrs. White during childbirth, I was assigned
to be the personal nanny of their daughter, Snow White.

2. Mr. White remained single until he married Quennie D.V. White in 2010.
After his death in 2011, I was under the employ of Mrs. D.V. White.

3. I am filing a formal complaint for murder of Snow White by means of


poison under Article 248 of Revised Penal Code, against Quennie D.V.
White [hereinafter “Respondent”] with the postal address of 13 Flame Tree
Road Barangay Forbes Park, Makati City.

4. The murder was committed as follows:

a) On the evening of May 25, 2018, Respondent celebrated her birthday


in her residence at 13 Flame Tree Road Barangay Forbes Park,
Makati City, inviting several eligible bachelors of the country.

b) The Respondent strictly prohibited Snow White from joining the


celebration and even threatened her to be locked in her room.

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c) Despite the warning, Snow White politely asked me to help her slip
into the party. As she was already suffering from maltreatment from
the Respondent, I helped her.

d) Snow White was noticeably attractive to the bachelor guests as she


was approached by them and was asked to dance one after the other.

e) After several dances, the Respondent noticed that Snow White joined
the party. She then forcefully dragged her back to her room as I plead
her to be gentle with my ward. She said that, “You are
overshadowing my beauty and I am losing prospective eligible
bachelors to marry. Papatayin kitang bata ka pag inunahan mo pa
ako.” Afterwards, she locked her in her room.

f) I was keeping Snow White company for an hour when the


Respondent gave me the keys to her room and ordered me to let her
out. She strictly ordered Snow White not to engage in any
conversations, nor look at the guests in their eyes. I heard her
exclaim, “Kung hindi lang sila mag-aalisan dahil wala ka, hindi ka
na makakalabas sa kwarto mo (If only the guests won’t leave
because of your absence, you won’t be able to leave your room)”.

g) I left Snow White with the respondent because I needed to go to the


restroom to urinate. When I went back to the ballroom, I saw the
respondent accompany Snow White to the kitchen.

h) I was about to follow Snow White but I was interrupted by the few
guests that asked several questions about Snow White and some
asked me where the comfort room was.

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i) I saw Snow White come out of the kitchen. I asked her what
happened. She smilingly said to me, “Ma told me that she will let me
go to Siargao with Mulan and Rapunzel next month if I can help her
win a guy tonight. She even gave me this!” as she was pointing to a
chocolate-coated apple on a stick. Which she then ate happily.

j) The party ended soon. I helped Cecil Dopey and Lucita Sleepy in
cleaning up the dishes. During that time, Cecil was unusually quiet
but I thought she was just tired from the work.

k) The following morning around 8 o’clock, I knocked at Snow White’s


room. She did not respond so I thought she was still asleep. When I
entered her room, she looked paler and weaker than usual. She tried
to stand up from her bed, but then collapsed on the floor. I shouted
for help and Chris Bashful immediately came. By that time, Snow
White was not responding and her body was scarily jerking.

l) I, Chris Bashful, and the driver Luis Grumpy rushed Snow White to
Far Far Away Medical Center, Makati City but Dr. Doc declared that
Snow White was dead on arrival and the cause of death was
organophosphate poisoning.

Attached herein is the Medical Certificate labeled as Annex “A” and


made part of this Complaint-Affidavit

m) I asked the Dr. Doc where could she have got the said poison.
The doctor responded that the chemical is often found in insecticides.

n) When we went back home, I saw Cecil Dopey crying in our quarters.
She asked if Snow White was indeed poisoned. She said she saw the
Respondent put something in the chocolate mix during the night of

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the party. She said that the Respondent wanted to prepare the dessert
to impress the guests. However, she saw that the Respondent added
something unusual to the chocolate mix. She did not know that the
chocolate was only for Snow White so she said it did not raise any
suspicion. Lucita also affirmed that she saw the Respondent took out
a bottle and pour it to the mixture

Attached herein are the affidavits of Cecil Dopey and Lucita Sleepy
labeled as Annexes “B” and “C”, respectively, and made part of this
Complaint-Affidavit

o) I talked to Roberto Sneezy to tell him that Snow White died of


insecticide poisoning during the party last night. He was worried that
he would be suspected since he is our gardener. He told me that he
saw the Respondent in the garden shed last night. And that when he
offered his help, the Respondent told him that she was just looking
for the light switch to the garden. He also told me that this morning,
he found out that a bottle of Baygone Insecticide is missing.

Attached herein is the affidavit of Roberto Sneezy labeled as Annex “D”


and made part of this Complaint-Affidavit

5. From the foregoing, I FIRMLY BELIEVE that the crime of MURDER by


means of poison was committed against Snow White which resulted to her
death and there is probable cause that QUEENIE D.V. WHITE committed
such unlawful act.

6. I am executing this complaint-affidavit to file a formal complaint of murder


against QUEENIE D.V. WHITE.

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IN WITNESS WHEREOF, I have hereunto affixed my signature this
13th of June 2018, at Makati City.

Linda Masayahin Happy


Complainant/Affiant

SUBSCRIBED AND SWORN to before me this 13th of June of 2018


at Makati City. I hereby certify that I have personally examined the above-
named affiant and that I am satisfied that the forgoing statements were given
by her voluntarily and of her free will.

Hunter A. Mangangaso
City Prosecutor
Roll No. 12345
MCLE Compliance No.
V-1234156
January 10, 2017

Doc. No. 1
Page No. 1
Book No. 1
Series of 2018

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