Sample Joint Complaint Affidavit

REPUBLIC OF THE PHILIPPINES
OFFICE OF THE CITY PROSECUTOR

QUEZON CITY
ABDUL MAJEED ALINDO ET AL.,

Complainants, I.S. No. _______
- versus - For: Alarms and Scandals (Art.

155, RPC), Qualified
Trespass to Dwelling (Art.
280, RPC), Offending the
Religious Feelings (Art.
133, RPC) and Violation of
B. P. Blg. 6
JOHNMARK ESTRADA ET. AL.,

Respondents.
x-------------------------------------------x
JOINT COMPLAINT-AFFIDAVIT
COMPLAINANTs respectfully allege that:
Complainants are all of legal age, Filipinos and all residents of 44-
th
18 Ave., Murphy Quezon City with their names as follows:
1) ABDUL MAJEED ALINDO;

2) IMBRA RADIA;
3) NORMAN DIDA;
4) ELIAS M. MAUTE;
5) ARSAD DIMARO;
6) ALINOR MUNDI;
7) RASMIA ABDULLAH;
8) YUSOPH DATUMANONG;
9) CAMAD MACAROMPER;
10) CALIL MACASALONG;
11) ABDULMALIC MACASALONG; and
12) ISMAEL SULTAN
Respondents are likewise all of legal age, Filipinos and all residents
likewise of 44-18th Ave., Murphy Quezon City with their names as follows:
1) JOHNMARK ESTRADA;
2) EDEN DATUIN;
1
3) EVELYN MAGAT;
4) EDELYN ESTRADA; and
5) JESUS MILLARES
NATURE OF THE CRIMINAL COMPLAINT
This is a criminal complaint for Alarms and Scandals (Art. 155, RPC),
Qualified Trespass to Dwelling (Art. 280, RPC), Offending the Religious
Feelings (Art. 133, RPC) and Violation of Batas Pambansa Bilang 6 arising
from the acts of respondents as hereto set forth.
ULTIMATE FACTS
1. On or about Eleven Thirty O’clock (11:30 P. M.) in the evening on

April 28, 2021, a group of persons were having a drinking spree at 44-18 th
Avenue, Murphy, Barangay San Roque, Quezon City in front of the
residence of ABDUL MAJEED ALINDO;
2. In the event that they were intoxicated by the influence of liquor, they
unexpectedly and violently assaulted the house of ABDUL MAJEED
ALINDO for three (3) times for unknown reasons;
3. Despite the resistance and attempt to pacify them shown by ABDUL

MAJEED ALINDO, the respondents persisted to commit burglary and
pursued their assault until a commotion took place in the middle of the
peaceful night where everyone should be asleep;
4. One of them was even holding an ice pick; a tool used for chipping
ice, which can be used to inflict serious harm against persons, hence, a
dangerous weapon. Later, the possessor was identified as JOHNMARK
ESTRADA;
5. In the course of the tumults, they even shouted at the complainants in

this vernacular, “Mga Muslim, mandaraya at bobo”;
6. On that occasion, ELIAS M. MAUTE called the attention of the

Barangay and the local police;
7. At the Police Station, respondents were identified and were issued a

violation ticket for transgressing City Ordinance on Liquor Ban and Curfew
Hours in the amount of Five Thousand (Php 5, 000.00);
8. Thereafter, the handling police officer directed all involved parties to

better settle the incident at the Barangay;
2
9. Upon proceeding to the Barangay, complainants filed for alarms and
scandals, assault and causing public disorder in layman’s definition. Copy of
the Barangay Blotter is hereto attached as Annex “A”;
10. On April 30, 2021, both complainants and respondents met at the
Barangay to finally had the incident settle but complainants manifested to
formally lodge its complaint by direct filing to the prosecutors’ office since
the incident was not merely isolated because same occurrence has been
repeatedly committed in the past by the same assailants which was
consistently settled due to the mercy and forgiveness extended to by the
complainants that ends in the withdrawal of the complaint or desistance from
making further complaints;
11. Also, respondents consistently having a drinking session in front of a

mosque dedicated to religious worship and other vices such as playing cards
notwithstanding the objections by complainants. There was likewise a time
that respondents butchered a pig right in front of a Mosque located at the
same address where complainants usually do their worship that offended
their feelings notoriously;
12. All the incidence were all personally witnessed by the undersigned
complainants since all of them were close neighborhood and living in the
same compound;
13. Alarms and scandals can be committed when any person who, while
intoxicated or otherwise, shall cause any disturbance or scandal in public
places as what exactly done by respondents;
14. Qualified trespass to dwelling can be committed when any private

person shall enter the dwelling of another against the latter's will which can
be aggravated when committed by means of violence or intimidation as what
had happened in this case;
15. Offending the religious feelings can be committed by anyone who, in

a place devoted to religious worship or during the celebration of any
religious ceremony shall perform acts notoriously offensive to the feelings
of the faithful like butchering of a pig right in front of a mosque;
16. Batas Pambansa Bilang 6 declared unlawful to carry outside of one's

residence any bladed, pointed or blunt weapon such as "knife", "spear",
"pana", "dagger", "bolo", "barong", "kris", or "chako", except where such
articles are being used as necessary tools or implements to earn a livelihood
or in pursuit of a lawful activity. By the spirit of the law, carrying out of an
ice pick falls within the purview of such declared unlawful article;
17. Complainants reserve its right to file a “Reply” should respondents

filed their counter-affidavits.
3
ANNEXES
For the record, and to form part hereof, by incorporation and

reference, attached hereto is copy of the following documents, to wit:
Annex “A” - Barangay Blotter
PRAYER
WHEREFORE, premises considered, it is respectfully prayed that

after notice and hearing the respondents be indicted for Alarms and
Scandals (Art. 155, RPC), Qualified Trespass to Dwelling (Art. 280, RPC),
Offending the Religious Feelings (Art. 133, RPC) and Violation of Batas
Pambansa Bilang 6.
Quezon City, May ____, 2021.
ABDUL MAJEED ALINDO ELIAS M. MAUTE

Complainant/Affiant Complainant/Affiant
ARSAD DIMARO ALINOR MUNDI

RASMIA ABDULLAH YUSOPH DATUMANONG

CAMAD MACAROMPER CALIL MACASALONG

ABDULMALIC MACASALONG ISMAEL SULTAN

4
IMBA RADIA NORMAN DIDA
SUBSCRIBED and sworn to before in Quezon City this ___ day of

May 2021, affiants/complainants showing their official identification
document.
Administering Prosecutor

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REPUBLIC OF THE PHILIPPINES

OFFICE OF THE CITY PROSECUTOR

ABDUL MAJEED ALINDO ET AL.,

- versus - For: Alarms and Scandals (Art.

JOHNMARK ESTRADA ET. AL.,

COMPLAINANTs respectfully allege that:

1) ABDUL MAJEED ALINDO;

NATURE OF THE CRIMINAL COMPLAINT

1. On or about Eleven Thirty O’clock (11:30 P. M.) in the evening on

3. Despite the resistance and attempt to pacify them shown by ABDUL

5. In the course of the tumults, they even shouted at the complainants in

6. On that occasion, ELIAS M. MAUTE called the attention of the

7. At the Police Station, respondents were identified and were issued a

8. Thereafter, the handling police officer directed all involved parties to

11. Also, respondents consistently having a drinking session in front of a

14. Qualified trespass to dwelling can be committed when any private

15. Offending the religious feelings can be committed by anyone who, in

16. Batas Pambansa Bilang 6 declared unlawful to carry outside of one's

17. Complainants reserve its right to file a “Reply” should respondents

For the record, and to form part hereof, by incorporation and

Annex “A” - Barangay Blotter

WHEREFORE, premises considered, it is respectfully prayed that

Quezon City, May ____, 2021.

ABDUL MAJEED ALINDO ELIAS M. MAUTE

ARSAD DIMARO ALINOR MUNDI

RASMIA ABDULLAH YUSOPH DATUMANONG

CAMAD MACAROMPER CALIL MACASALONG

ABDULMALIC MACASALONG ISMAEL SULTAN

SUBSCRIBED and sworn to before in Quezon City this ___ day of

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