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REPUBLIC OF THE PHILIPPINES

Sixth Judicial Region
REGIONAL TRIAL COURT
Branch _______
CJ Ramon Q. Avancena Hall of Justice
Iloilo City
Josefa Vincerina
Complainant ,
-versusJericho Villaruel
Respondent.

Docket No: _________

For: Violation of R.A 9262
Violence Against Women and
their Children

x-----------------------------------x
COMPLAINT
COMES
NOW,
the
complainant,
through
the
undersigned counsel and unto this Honorable Court, most
respectfully avers:
1. That the complainant, Josefa Vincerina, is of legal age,
Filipino citizen, single, with residence and postal address at
Gen. Luna St., La Paz, Iloilo City, where she may be served
with summons and other court processes;
2. That the defendant, Jericho Villaruel, is of legal age,
Filipino citizen, married, with residence and postal address at
Brgy. Bakhaw, Mandurriao, Iloilo CIty, where he may be
served with summons and other court processes;
3.That the complainant and respondent were classmates
at University of Iloilo. Jericho courted Josefa and they
became on-and-off sweethearts towards the end of
2014. When the complainant learned afterwards that
respondent had taken a live-in partner (now his wife), whom
he had gotten pregnant, Josefa broke up with him;
4. That before Jericho got married, he got in touch with
Josefa and tried to convince her to elope with him, saying
that he did not love the woman he was about to marry.
Josefa rejected the proposal and told Jericho to take on his
responsibility to the other woman and their child;

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6. That Josefa changed her cellphone number but Jericho

somehow managed to get hold of it and sent her text
messages. Jericho used two cellphone numbers for sending
his messages, namely, 0920-4769301 and 0921-8084768.
The sim cards of which is marked as Annex A;
7. That Josefa replied to his text messages but it was to ask
him to leave her alone;
8. That in the early morning of June 5, 2015, the complainant
received through multimedia message service (MMS) a
picture of a naked woman with spread legs and with Josefas
face superimposed on the figure. The printed copy of which
is attached hereto as Annex B;
9. That after she got the obscene picture, Josefa got other
text messages from the respondent which stated that it
would be easy for him to create similarly scandalous pictures
of her and he threatened to spread the picture he sent
through the internet. One of the messages he sent to Josefa,
written in text messaging shorthand, read: Madali lang ikalat
yun, my chatrum ang Iloilo rayt pwede ring send sa lahat ng
chatter. The Sony Ericsson P900, the phone used by the
respondent to communicate with her, is marked as Annex C;
10. That Josefa sought the assistance of the police. Josefa
asked Jericho to meet her at E. Lopez St. Iloilo, City wherein
the latter came in with a motorcycle. After parking it, he
walked towards Josefa but the waiting police officers
intercepted and arrested him. They searched him and seized
his Sony Ericsson P900 cellphone and several SIM
cards. While Jericho was being questioned at the police
station, he shouted at Josefa: Malandi ka kasi!;
11. That the above situation has caused substantial
emotional
anguish,
psychological
distress
and
humiliation to the said Josefa Villaruel;
12. That due to the aforementioned event, the complainant
asked the assistance of a lawyer to know the means and
available remedies to stop and desist the respondent from
threatening her;
12. That based on the foregoing, it was explained to her that
there was a violation of Republic Act 9262, also known as An
Act Defining violence against Women and Their Children,

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which allows the complainant to avail of the remedies

therein;
PRAYER
WHEREFORE, premises considered, it is most
respectfully prayed unto this Honorable Court that, after
hearing, judgment be rendered in favor of the complainant
and to pay the amount of P100,000.00 as moral damages
and the cost of the suit.
City of Iloilo, 10 February 2015.

MA. GERALYN D. GABRIEL

Counsel for Complainant
Beautiful Law office, Del Rosario Building
16 Libertad St., Jaro, Iloilo City
Attorneys Roll No. 2345/January 07,
2010/ Iloilo City
IBP No. 087678/January 20, 2010/Iloilo
City

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )
City of Manila
) S.S.
I, Josefa Vincerina, of legal age, Filipino citizen, single
and resident of Gen. Luna St., La Paz, Iloilo City, after having
been duly sworn to in accordance with law do hereby depose
and say:
1.
2.

That I am the plaintiff in the above-entitled case;

That I have caused the preparation of the foregoing
complaint and have read the allegations contained therein;
3.
The allegations in the said complaint are true and
correct of my own knowledge and authentic records;

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4.

I hereby certify that I have not commenced any other

action or proceeding involving the same issues in any
court, tribunal or quasi-judicial agency and, to the best of
my knowledge, no such other action or claim is pending
therein;
5.
That if I should learn thereafter that a similar action or
proceeding has been filed or is pending, I hereby undertake
to report that fact within five (5) days therefrom to the court
or agency where the original pleading and sworn certification
contemplated herein have been filed;
6.
I executed this verification/certification to attest to the
truth of the foregoing facts and to comply with the provisions
of Adm. Circular No. 04-94 of the Honorable Supreme Court.
IN WITNESS WHEREOF, I have hereunto affixed my
signature this 10th of September 2016, in the City of Iloilo.
Josefa VIncerina
SUBSCRIBED AND SWORN to before me this 10th day
of February, 2016 the affiant is personally known to me and
exhibiting to me her passport No. 7684 issued at Iloilo City
on February 9, 2015 and her CTC No. 398890 on March 19,
2015.

MA. GERALYN D. GABRIEL

Beautiful Law office, Del Rosario Building
16 Libertad St., Jaro, Iloilo City
Attorneys Roll No. 2345/January 07,
2010/ Iloilo City
IBP No. 087678/January 20, 2010/Iloilo
City

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MONALIZA M. GESTOSO
Beautiful Law office, Del Rosario Building
16 Libertad St., Jaro, Iloilo City
Attorneys Roll No. 5434/January 07,
2010/ Iloilo City
IBP No. 087695/June 02, 2010/Iloilo City

CERIL LYN L. BURRO

Beautiful Law office, Del Rosario Building
16 Libertad St., Jaro, Iloilo City
Attorneys Roll No. 9807/February 14,
2010/ Iloilo City
IBP No. 654786/February 14, 2010/Iloilo
City

Doc. No. 18;

Page No. 5;

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Book No. XIII;

Series of 2016.