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REPUBLIC OF THE PHILIPPINES


DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
MANILA


Gloria Laptitin Labandera
Complainant
vs. I.S. No. ____________
For: Rape
Gerardo Fuentes
Respondent.

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COMPLAINT-AFFIDAVIT

I, GLORIA LAPITIN LABANDERA, Filipino, of legal age, and
with residence at No. 3B, 3rd street, San Beda Village, Manila, after
having been duly sworn in accordance with law, hereby depose and
state that:
(1) This complaint-affidavit is being filed to charge Gerardo
Fuentes a.k.a Ser Chip, Filipino, of legal age, and with residence
at No. 3B, 3rd street, San Beda Village, Manila, of the crime of
Rape under Article (Art.) 266 of the Revised Penal Code (RPC),
committed as follows:
(a) On 13 July 2013, at around 7:00 in the evening, I went
inside my room after I had my dinner. Even though it was my
day off today, I stayed at home because I dont want to spend
money and I was also saving money. I had no salary income for
the past three months.
(b) While fixing my things inside my room, my boss, Ser Chip
went inside. He said to me Mayroon tayong pag-uusapan. He

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then locked the door. Ser Chip looks drunk and smells oozing
with alcohol.
(c) Ser Chip approached me and started undressing me. I
tried resisting but he was too strong. He punched me in my gut
and I fell on the bed. He undressed himself as I was on the
bed.
(d) Ser Chip covered my mouth and started raping me. He
told me to keep quiet and not to shout.
(e) After satisfying his desires, Ser Chip threatened to kill me
if I told Maria Yasmin Fuentes, his wife.
(f) He then gave me 1,000 Philippine Pesos. I took the money
since I really needed the money after not having received my
monthly salary.
(g) I escaped the house at around 8:30 in the evening while
Sir Chief was in his room.
(2) Based on the foregoing, it is beyond cavil that respondent
Gerardo Fuentes committed the crime of rape punishable under
Art. 266 of the RPC. He had sexual intercourse with me against my
own will. This constitutes statutory rape as defined in our laws.





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AFFIANT FURTHER SAYETH NAUGHT.
IN WITNESS WHEREOF, I have hereunto set my hand this 14
th

day of July 2014, in Manila.

Gloria L. Labandera
Complainant/Affiant


SUBSCRIBED AND SWORN TO before me, this 14
th
day of
July 2014 in Manila.


Prosecutor

This is to certify that I have personally examined the herein
affiant and that I am satisfied that she voluntarily executed and
understood her statements herein.

Prosecutor

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