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COMPLAINT – AFFIDAVIT
We, Sps. Krite and Sandra Banggawan, 37 and 36 years old respectively,
married, Filipino, currently residing at M.B. 095 Pico, La Trinidad, Benguet, after
being sworn in accordance with law, hereby depose and state that:
3. We, Sps. Banggawan, tried to contact her mobile number at about 9:00 o’clock,
but she could not be reached;
4. It was raining hard that night and we thought our daughter was simply having
difficulty getting ride, thus Krite Banggawan decided to fetch her at about 10:00
o‘clock, but returned home without Jackie;
5. We were not able to sleep that night, and so as early as 5:00 o'clock in the
morning we started the search for our daughter, but there was no trace of her.
Thus, we sought the assistance of the police both Baguio City and La Trinidad
Police Stations. However, as protocols in case of a missing person we were
advised to at least wait for twenty-four (24) hours before they will start with the
search and declare a person missing. But they guarantee as that they will contact
us in case they’ll hear anything about our daughter, so they asked some physical
Complaint-Affidavit / Page 1
features of our daughter and the description of the clothes she was wearing when
she left the house on that day.
10. With the assistance of the police, and participation of identified witnesses, the
investigation of the crime was accelerated;
12. KAYSER CLAIR DODON who owns a store located at the crossing of Tam-
awan testified that while she was outside her store preparing to close at around
8:00 PM, she saw a woman with the description of Jackie alighting and running
away from a white van when a man went after her and grabbed her back to the
white van. Upon witnessing the incident she quickly closed her store and went
inside. Her Sworn Statement is hereto attached as Annex “D”;
13. Another witness VAL LAGMAN, a taxi driver, saw Jackie running. Her blouse
was torn and her hair was disheveled. Trailing her was a white van where a very
loud rock music could be heard. His Sworn Statement is hereto attached as
Annex “E”;
Complaint-Affidavit / Page 2
14. Also, OSWALD T. LIZARDO, a Chief Tanod at Tam-awan, while having foot
patrol at about 5:00 o'clock in the morning, saw a white van near a cliff at Tam-
awan Village. Thinking that the passenger of the white van was throwing
garbage at the cliff, he look at the van’s plate number AYU 888 and wrote it on
his palm. However, after the white van left and went near the cliff, he was
surprised to see a body of a dead woman which he immediately reported to the
police station. His Sworn Statement is hereto attached as Annex “F”;
16. MR. CLIFF FORD, the owner of the apartment where accused were renting,
testified that he last saw accused on August 6, 2018, but have not seen them
since then. Attached hereto is his Sworn Statement as Annex “I”;
17. Based on the foregoing, Jackie S. Banggawan was forcibly placed inside the
white van bearing plate number AYU 888 by the three suspects, Jeftee Ingson,
Anthony David and Boyong Loko, with the intention to rape her. And, while in
the occasion of rape, the three suspects killed the victim;
18. We are executing this affidavit to attest to the truth of the foregoing facts and
for the purpose of filing a criminal complaint for Forcible Abduction with Rape
and Homicide against the suspects, Jeftee Ingson, Anthony David and Boyong
Loko.
IN WITNESS WHEREOF, we have hereunto set our hands this 22nd day of August
2018, at Municipality of La Trinidad, Benguet, Philippines.
CERTIFICATION
I hereby certify that I have personally examined the affiants and that I am
satisfied that they voluntarily executed and understood this complaint-affidavit.
CLIFFORD D. LARDIZABAL
Investigating Prosecutor
Complaint-Affidavit / Page 3