Sample Complaint Affidavit Murder

Download as docx, pdf, or txt
Download as docx, pdf, or txt
You are on page 1of 3

Republic of the Philippines

Quezon City s.s.

AFFIDAVIT-COMPLAINT

I, BECKY N. POE, 25 years old, married, and a resident of Block 5, Lot 7, Rosas
Street, Brgy. Bagong Pag-asa, Quezon City, after having been duly sworn to in
accordance with law, hereby deposes and says THAT:

1. I am the mother of Maria N. Poe, 10 years old, enrolled as a Grade Four Pupil
at Bright School, Quezon City. A machine copy of the birth certificate of
Maria N. Poe is hereunto attached and made as an integral part hereof as
Annex “A”;

2. Last July 20, 2019, on or about 8:00 P.M., my daughter Maria N. Poe with her
cousin Camille P. Gopez, asked for my permission to attend the funeral of
their grandmother, the late Azucena S. Poe.

3. Because of the assurance of Camille that she will be looking and taking care of
Maria, I allowed them to go ahead of me since I will also go there and that the
place of the wake was near. While I was on my way, a commotion broke at a
near distance, which was followed by shouting and crying so I quickly went to
the place. Upon my arrival, I saw my daughter lying in the ground, bathe in
her own blood, with Camille hoarsely shouting and crying for help. Trembling
and lost for words, I asked Angelyn who was the culprit of the crime which
she answered without hesitation as one named Jeffrey Q. dela Torre. I asked
her where he is and she replied, “he has already fled, Auntie”. I asked and
begged the people around us to help me bring my daughter to the nearest
hospital which was responded to with haste by Rene Solis and other relatives
who were around. The sworn statement of Rene Solis is hereunto attached and
made an integral part of this complaint as Annex “B”;

1|Page
4. Upon arrival at the Quezon City Hospital, Dr. Maria Gracia Tan, immediately
attended my daughter and after a thorough examination, declared her dead on
arrival. The medico-legal autopsy report, the NSO death certificate and a
certification from the City Civil Registrar of Maria N. Poe is hereunto
attached and made an integral part of the complaint as Annex “C” , “ D”, and
“E”, respectively;

5. While at the hospital, I inquired Camille if the said Jeffrey Dela Torre was the
same Dino Q. dela C Jeffrey Dela Torre, who is our neighbor and who came
to our house earlier that day to borrow money from me. She positively
identified that both is the same person. The sworn statement of Camille P.
Gopez is hereunto attached and made an integral part of this complaint as
Annex “F”;

6. I denied the request of said Jeffrey Dela Torre because of his notorious
character in our neighborhood as a drug addict, drunkard, gambler and
without a permanent job; That after the said refusal to lend money, he
mumbled and uttered to me that I would surely regret my decision which
statement I took for granted.

7. I immediately reported the stabbing incident on or about 12:00 o’clock


midnight at the Quezon City II Police Station which is the nearest police
station. The original copy of the excerpt of the police blotter duly issued by
Senior Police Inspector Renato Go III of Quezon City II Police Station is
hereunto attached and made as an integral part hereof as Annex “G” of the
complaint;

8. I am therefore executing this affidavit freely and voluntarily in support of my


intent to file a case for MURDER and/or the appropriate criminal case against
Jeffrey Dela Torre, who is 30 years of age and a resident of Block 10, Lot 10,
Rosas Street, Brgy. Bagong Pag-asa, Quezon City,

2|Page
IN WITNESS WHEREOF, I have hereunto set my hand this 20 th day of July,
2019 at Quezon City, Philippines.

BECKY N. POE
Affiant

SUBSCRIBED AND SWORN to before me this 20th day of July, 2019 at


Quezon City, Philippines and I FURTHER CERTIFY that I have personally examined
the affiant and I am satisfied that he/she has read and personally understood the contents
of her foregoing “Complaint-Affidavit”.

MARK B. LONZAGA
Prosecutor II
Roll No. 51355-2006
IBP No. 808997-1/3/11
PTR No. 423464- 1/3/11; Leyte
MCLE Compliance III No. 0013601
Issued on April 22, 2018

3|Page

You might also like