Republic of the Philippines )

Province of Biliran )S.S.

Caibiran, Biliran )

COMPLAINT-AFFIDAVIT

I, ___________________, of legal age, married, Filipino and also a

resident of _______________________, Caibiran, Biliran, under oath,
hereby depose and say, that:

1. I am a journalist of ___________, ___________, and

Philippine Star, all are news agencies with on-line platform.

2. My news articles are being published on-line by the above-

stated news agencies principally through the social media site Facebook.

3. I hereby formally charge the following persons for the crime

of Libel under section 4(c)(4) of R.A. 10175 also known as the Cybercrime
Prevention Act of 2012:

3.1. ________________________________ (with the same

Facebook account name), single, Filipino with postal
address at 102 Real St., Poblacion Dist. IV, La Paz, Leyte,
a journalist of Manila Bulletin,

3.2. ____________________ (with the same Facebook

account name), single, Filipino with business address at
Comprehensive National High School, Burauen, Leyte;

3.3. __________________ (with Facebook account name

as________________), single, Filipino with business address at
Leyte-Samar Daily Express, Zamora St., Downtown,
Tacloban City;

3.4. ________________________ (with Facebook account

name as ____________________________), Filipino
with business address at DYOG Radyo Pilipinas, Calbayog
City;

3.5. All of legal age and herein referred to as

RESPONDENTS.

Complaint-Affidavit of__________________Page 1 of 5
 4. That the malicious imputations as discussed hereunder were
published or posted by the respondents in the popular social networking
site FACEBOOK.COM.

5. On October 11, 2018 at 9:25 PM, Ms. _______________, in

order to malign my person, character and honor, caused the publication
through her Facebook (FB) account
_______________________________ with internet address at
https://www.facebook.com/______________ of malicious FB post to
which ___________________________, ______________________,
____________________, and ___________________________ posted
malicious comments stated hereunder. Attached are the screen shots of the
FB post and comments (accessed last 22 October 2018, 3:22 P.M.)
containing the libelous and malicious imputations hereto attached as
Annexes "A and series".

6. Said FB post and comments published by respondents,

without observing the ethical standards of journalism, contained malicious
imputations with bad intentions and unjustifiable motives, purposely to
malign, dishonor, discredit, insult and assassinate my character and good
reputation to the public as well as to my constituents, an excerpt of which
are hereby quoted (in italics):

6.1. “This is my photo! I am warning the admin of this page to

take down my photo or else magkakagawas it copy paste
nga stories from PNA. Copycat!” (English Translation:
This is my photo! I am warning the admin of this page to
take down my photo or else the copy paste stories from
PNA will be made public. Copycat!) –
____________________ (Annex “A-1”)

6.2. “So iya ginamit an pic nga imo nga share ha amun for
mats. Waray ko ngani itun gamita kay ginamit mo na ha
MB, tapos hiya nga waray katugutan asya pa an naggamit
han material.” (English Translation: So she used the
picture that you shared with us for materials. I did not
even use it because you already used it for MB [Manila
Bulletin], and then she used it without permission)–
____________________ (Annex “A-9-A”)

6.3. “grabe and kawalan ng respeto” (English Translation:

Outrageous and shows no respect)–
____________________ (Annex “A-9-B”)

6.4. “Wa pa nakuntento sa pangopya ug articles sa PNA pati

pa akong pic gikuha.” (English Translation: Not contented

Complaint-Affidavit of__________________Page 2 of 5
 with copying of articles from PNA, my picture was also
taken)– _________________________(Annex “A-11-A”)

6.5. “An picture ngani ni Kimmy ginamit gihapun hitun nga

murat, ambut la kun nagsarit kan Kimmy kay diri man
name ni Kimmy an nakabutang ngadto.” (English
Translation: Even the picture of Kimmy was used by that
girl, I do not know if she asked permission from Kimmy
because the name of Kimmy was not indicated therein.)–
_________________ (Annex “A-12-A”)

6.6. “Ini nga nga girl ginkakawat tim photos.” (English

Translation: This girl is stealing your photos.)–
_______________________ (Annex “A-12-B”)

7. Ms. ______________ made it appear that I copied her

pictures (Annex “A-3-A”) that she used in her article published in the
Manila Bulletin Facebook Page and then accused me of using the same
picture in my Cebu Vote article posted at the latter’s FB Page (Annex A-2-
A).

8. The above-stated comments of the respondents pointed to

one person only, the undersigned complainant. In the FB comment
(Annex “A-12-B”) of _______________, the latter even included a photo
mine.

9. That I was informed by my friends about the post. I was

shocked to see and read the said FB post and comments on October 12,
2018 when I was at my residence at Caibiran, Biliran.

10. The said FB post were posted as “public” where FB user can
read and see the same. The afore-quoted portion of the FB post and
comments authored and published by respondents created in the minds of
the readers from all over the world that I am a thief and a plagiarizer.

11. The FB post and comments published by respondents has no

factual basis, is highly speculative and were all false statements made to
destroy my reputation as a law abiding citizen.

12. Respondents were motivated by bad faith in the publishing of

the said posts and comments online to defame, embarrass me to my
colleagues, friends, family and to the readers and patrons of their posts and
comments.

Complaint-Affidavit of__________________Page 3 of 5
 13. The libelous posts and comments having been published
through Facebook, a social media platform accessible to and is made
available to the general public was read by the said general public,
including my colleagues, friends and family among others.

14. Due to the said malicious public imputations by respondents,

I suffered and continue to suffer serious anxiety, besmirched reputation,
mental anguish, sleepless nights, not to mention the damage they have
caused to my career, reputation and honor among the readers and patrons
of ______________, ___________________, and Philippine Star and the
general public.

15. I have been in the media profession since YEAR 2000 and
this is the first time that I am being accused of wrongdoings of that nature.
My integrity and reputation has been tarnished and my job was put at risk
by those malicious FB post and comments. I could say that above stated
news agencies are already doubting my reputation as a journalist and as a
person.

16. Due to such grossly unjustified malicious and libelous

imputations, I have suffered and continued to suffer sleepless nights,
mental anguish, serious anxiety, besmirched reputation and public ridicule.
I therefor pray that respondents be made to pay jointly and severally,
MORAL DAMAGES in the amount of ONE MILLION PESOS (Php
1,000,000.00), and in the amount of FIVE HUNDRED THOUSAND
PESOS (Php 500,000.00) as EXEMPLARY DAMAGES to deter other
persons from committing the same, for I was made to suffer as a result of
the said Facebook post and comments together with the attorney’s fees and
the cost of this suit.

17. I hereby execute this affidavit to attest to the truth of the

foregoing facts and hereby request the investigating prosecutor to file the
crime of Libel under R.A. 10175 against the herein Respondents.

IN WITNESS WHEREOF, I have hereunto set my hand this day

of __________ 2018 in __________, Philippines

____________________
Complainant/Affiant

SUBSCRIBED AND SWORN TO before me this day of

_________2018 at _______________, Philippines the following affiant
Complaint-Affidavit of__________________Page 4 of 5
MIRIAM G. DESACADA exhibiting to me her Government issued ID
no. ______________ being sufficient and competent evidence of his/her
identity in pursuant to the 2004 Rules of Notarial Practice.

Doc. No. ____;

Page No.____;
Book No. ____;
Series of 2018

Complaint-Affidavit of__________________Page 5 of 5