REPUBLIC OF THE PHILIPPINES )

Santa Cruz, Laguna ) S.S.

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PEOPLE OF THE PHILIPPINES CRIMINAL CASE NO. 11E-03792

Plaintiff,

-Versus- FOR: MURDER

FRANCO B. SEGISMUNDO
Accused,

AFFIDAVIT-COMPLAINT

I, ROMINA A. ANDRADA, 36 years old, married, and a resident of Block

30, Lot 11, Ilang-ilang Street, Phase 3, Lynville Subdivision, Santa Cruz, Laguna
after having been duly sworn to in accordance with law, hereby deposes and says
THAT:

1. I am the mother of Cassie A. Andrada, 11 years old, enrolled as a Grade

Five Pupil at Santa Cruz Central Elementary School. A machine copy of
the birth certificate of Cassie A. Andrada is hereunto attached and made
as an integral part hereof as Annex “A”;

2. Last April 19, 2019, on or about 10:30 P.M., my daughter Cassie A.

Andrada with her cousin Rhian A. Bonifacio, asked for my permission
to attend the funeral of their grandmother, the late Ruby Azucena.

3. Because of the assurance of Rhian that she will be looking and taking
care of Cassie, I allowed them to go ahead of me as I was also planning
of going there and that the place of the wake was only a few houses
away. While I was on my way to the wake, I heard a commotion at a near
distance, which was followed by shouting and crying so I hurriedly went
to the place. Upon my arrival, I saw my daughter lying in the ground,
bathe in her own blood, with Rhian hoarsely shouting and crying for
help. Trembling and lost for words, I asked Rhian who was the culprit of
the crime which she answered without hesitation as one named Franco B.
Segismundo. I asked her where Franco is and she replied, “umalis na
 tita” (he has already fled auntie). Crying for help, I asked and begged the
people around us to help me bring my daughter to the nearest hospital
which was responded to with haste by Alan Del Mundo and other
relatives who were around. The sworn statement of Alan Del Mundo is
hereunto attached and made an integral part of this complaint as Annex
“B”;

4. Upon arrival at the Laguna Holy Family Hospital, Dr. Feona Villanueva,
immediately attended my daughter and after a thorough examination,
declared her dead on arrival. The medico-legal autopsy report, the NSO
death certificate and a certification from the City Civil Registrar of
Cassie A. Andrada is hereunto attached and made an integral part of the
complaint as Annex “C” , “ D”, and “E”, respectively;

5. While at the hospital, I inquired Rhian if the said Franco B. Segismundo

was the same Franco B. Segismundo who is our neighbor and who came
to our house earlier that day to borrow money from me which she
positively identified as the same person. The sworn statement of Rhian
A. Bonifacio is hereunto attached and made an integral part of this
complaint as Annex “F”;

6. I denied the request of said Franco B. Segismundo because of his

notorious character in our neighborhood as a drunkard, gambler and
without a permanent job and that after the said refusal to lend money, he
mumbled and uttered to me that I would surely regret my decision which
statement I took for granted.

7. I immediately reported the stabbing incident on or about 12:00 o’clock

midnight at the Santa Cruz Police Station which is the nearest police
station. The original copy of the excerpt of the police blotter duly issued
by Senior Police Inspector Virgilio Riguer III of Santa Cruz Police
Station is hereunto attached and made as an integral part hereof as Annex
“G” of the complaint;

8. I am therefore executing this affidavit freely and voluntarily in support of

my intent to file a case for MURDER with abuse of superior strength
 and/or the appropriate criminal case against Franco Segismundo, who is
35 years of age and a resident of Block 30, Lot 9, Ilang-ilang Street,
Phase 3, Lynville Subdivision, Santa Cruz, Laguna.

IN WITNESS HEREOF, I hereunto set my hand this 20th day of April,

2019 at Santa Cruz, Laguna.

ROMINA ANDRADA
Affiant

SUBSCRIBED AND SWORN to before me this 20th day of April 2019 at

Santa Cruz, Laguna, Philippines and I FURTHER CERTIFY that I have personally
examined the affiant and I am satisfied that he/she has read and personally
understood the contents of her foregoing “Complaint-Affidavit”.

SANTIAGO L. GUERRERO
Prosecutor II
Roll No. 51379-2006
IBP No. 808787-1/3/11
PTR No. 4128464- 1/3/11; Laguna
MCLE Compliance III No. 0013601