1.

REPUBLIC OF THE PHILIPPINES

City of Guihulngan

) S. S.

Province of Negros Oriental

COMPLAINT AFFIDAVIT

I, ROWENA LORICA, of legal age, Filipino, and a resident of 01

Sunshine Street, Mandaue, Cebu City, state under Oath that:
1. I am Overseas Filipino Worker working as a domestic helper in Wan
Chai Singapore.
2.

I am the mother of the victim, ALTHEA FHEM BARBON. She

was born on April 15, 2012 (4 years old), a resident of Guihulngan
City, Negros Oriental and a Kinder 1 pupil at Gucce Learning
Center in Guihulngan, Negros Occidental. Birth Certificate is
attached as Annex A. Her Birth Certificate and School ID are
attached hererto and marked as Annex A and B.

3. I accuse and charge SPO1 SEVERINO TABAYACYAC, of legal

age, single, Filipino, and was the head of the mission to chase and
apprehend my daughters father, PIM ALRICK BARBON on
August 30, 2016 in Guinhulngan City in Negros Occidental, who
was allegedly a wanted drug lord, and all police officers who took
part in the said mission. He and his colleagues hold office at PNP
Command Center, Lot 8, Olarte Highway, Guinhulngan City in
Negros Occidental, for HOMICIDE, as defined and punished under
Article 249 of the Revised Penal Code for the death of my daughter,
ALTHEA FHEM, committed under these circumstances:
a. That on the afternoon of 30 August 2016, my ALTHEA
FHEM was with her father, PIM ALRICK who fetched her
from her school. They were riding a motorcycle and passed by
the plaza before heading home;
b. That on that day, the police was conducting an entrapment
operation against PIM ALRICK but sensing the presence of
the police, PIM ALRICK tried to evade them;

c. That a hase took place between the police and PIM ALRICK
and that the police fired at him because, according to them,
he opened fire at them first;
d. That PIM ALRICK sustained a gunshot wound at the back
and died on the spot. His Death Certificate is attached hereto
and marked as Annex C;
e. That the fatal bullet passed through PIM ALRICKs chest
and hit ALTHEA FHEMs spine who was then sitting in
front of her father. Said gunshot wound caused her death 2
days after or on 1 September 2016 at the Negros Oriental
Provincial Hospital. Attached hereto and marked as Annex
D is Altheas Death Certificate.
4. ALTHEA FHEM, a kind-hearted kid child, an honor student, and
my only daughter. She could have had a bright future if only this
fatal incident had not taken her life. I am working overseas so I can
support my daughter and give her all the best a child could have.
This incident has caused me serious anxiety and great mental
anguish that I even sought professional help for depression.
5. Due to ALTHEA FHEMs untimely death, I had to take beg my
employer to let me fly back to the Philippines to see my daughter,
who allowed me to do so on condition that I will not get my salary
for the time I am in the Philippines. In addition, I had incurred
funeral expenses in the amount of P150,000.00, which also includes
expenses for food and other related expenses during the six-day
wake and the pasiyam. Attached hereto and marked as Annex E
are the receipts corresponding to such expenses.
6. Given the above circumstances, I intend to have the accused serve
their sentence as prescribed by law. I further claim all possible civil
liabilities arising from this criminal act including but not limited to
actual, moral, and exemplary damages.
TO THE TRUTH OF THE FOREGOING, I have signed this
Complaint-Affidavit on 7 October 2016 at the City of Guihulngan, Negros
Oriental.

____ROWENA LORICA____

Complainant-Affiant

SUBSCRIBED AND SWORN TO BEFORE ME this 7 October 2016

at the City of Guihulngan, Negros Oriental.

______Atty. Ronald Dela Rosa______

Investigating Prosecutor

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

______Atty. Ronald Dela Rosa______

Investigating Prosecutor