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REPUBLIC OF THE PHILIPPINES)

LA TRINIDAD, BENGUET ) S.S.

SPS. KRITE AND SANDRA BANGGAWAN,


Complainants,
I.S. No. ________
--versus-- For: Forcible Abduction
with Rape and Homicide

JEFTEE S. INGSON, DAVID A. ANTHONY,


AND BOYONG B. LOKO,
Respondents.
x------------------------------------------------x

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:

1. This Complaint-Affidavit is being filed to charge Jeftee S. Ingson, David A.


Anthony, and Boyong B. Loko, Filipino citizens, all of legal age, and residents
of No. 168, Pico, La Trinidad, Benguet, with Forcible Abduction with Rape
and Homicide, defined and penalized under Article 342 of the Revised Penal
Code in relation to Articles 266-A, 249 and 48 of the same code, committed as
follows:

2. On the night of August 6, 2018, our daughter Jackie S. Banggawan failed to


come home after attending her 5:00 to 7:00 o’clock evening class at Benguet
State University (BSU);

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.

6. Though we are very worried as to the whereabouts of our daughter, we went


home and hoped that she is just with one of her friends and will go home
anytime;

7. At around 10:00 o’clock in the morning of August 7, 2018, we received a call


from Baguio Police station, asking us to personally visit their office. Upon
arrival to the station they informed us that a dead young woman was found at
the foot of a cliff in Tam-awan Village, Baguio City, which has the same
descriptions as to how we described our daughter.

8. The investigation was conducted by PO3 BRENNAN S. BAGUIWAN and PO1


JANICE JOY G. PAIT who proceeded to Tam-awan and found a dead woman
lying on the ground upon receiving a call from The Chief Tanod of Tam-awan.
The body was brought to the Lapaz Funeral Parlor at Buyagan, La Trinidad,
Benguet. The Police Report is hereto attached and made an integral part hereof
as Annex “A”;

9. Upon hearing the information, we proceeded to the Lapaz Funeral Parlor at


Buyagan, La Trinidad to see the body. It was Jackie dressed in the same orange
shirt and jeans which she wore when she left home on August 6, 2018;

10. With the assistance of the police, and participation of identified witnesses, the
investigation of the crime was accelerated;

11. Witnesses GUINEVERE RAYMUNDO and CRISSY ANGYODA, both


classmates of JACKIE, testified that they last saw Jackie talking to the accused
Ingson, Anthony and Loko on August 6, 2018 at around 7 o’clock in the evening
near the last gate of Benguet State University along KM.6 La Trinidad, Benguet
while the said accused are inside a white Van. Attached hereto are their Sworn
Statements as Annexes “B” and “C”;

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”;

15. JOAHNA GOYAGOY, Medical Officer of the Philippine National Police


(PNP), Baguio City Crime Laboratory, performed an autopsy on the cadaver and
attested that indeed JACKIE was raped, and her cause of death was due to
serious injuries sustained. A copy of the Postmortem Findings is attached hereto
as Annex “G”, and a copy of the Death Certificate is also attached hereto as
Annex “H”;

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.

KRITE BANGGAWAN SANDRA B. SAPALIT


Complainant/Affiant Complainant/Affiant

CERTIFICATION

SUBSCRIBED and SWORN TO BEFORE ME, this 22nd day of August


2018 at La Trinidad, Benguet.

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

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