Republic of the Philippines Republic of the Philippines
Fourth Judicial Region Fourth Judicial Region Regional Trial Court Regional Trial Court
Branch XVI Branch XVI Cavite City Cavite City
MICHELL
MICHELLE A !E A !AALE CRLE CR"#"# Complainant, Complainant,
$ versus $ $ versus $
Co%plaint for& !iolation of RA '()( Co%plaint for& !iolation of RA '()( !iolence Against *o%en and their !iolence Against *o%en and their Children Children LA+# AI,A+ L -LI!E.
LA+# AI,A+ L -LI!E. Respondent Respondent /$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$/ /$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$/
COMPLAINT – AFFIDAVIT
COMPLAINT – AFFIDAVIT
I0 MICHELLE A !I0 MICHELLE A !AALE CR"#0 LE CR"#0 single0 of legal single0 of legal age0 Filipino0 1ith residenceage0 Filipino0 1ith residence at (23 .alcedo .t0 .an Antonio0 Cavite City0 after having been duly s1orn at (23 .alcedo .t0 .an Antonio0 Cavite City0 after having been duly s1orn in accordance 1ith la10 hereby depose and state& 4HA4
in accordance 1ith la10 hereby depose and state& 4HA4 5
5 I a% the sa%e peI a% the sa%e person 1ho irson 1ho is the co%s the co%plainplainant in thant in the instae instant case6nt case6 (
( 4he resp4he respondondent and I ent and I 1er1ere e colcolleglege s1eete s1eetheahearts for %ore than thrrts for %ore than threeee years
years 7
7 -n -n MaMarcrch h (3(30 0 ((858580 80 ouour r ththirird d aannnniiveversrsarary y anand d ririghght t aaftfter er ouour r graduation0 1e both decided to live together in the house 1hich his graduation0 1e both decided to live together in the house 1hich his parents
parents bought bought for for hi% hi% located located at at (23 (23 .alcedo .alcedo .t0 .t0 .an .an AntonioAntonio00 Cavite City
Cavite City 2
2 After beAfter being living live$in pae$in partnerrtners for %ore thas for %ore than five yean five years0 1e 1errs0 1e 1ere blessee blessedd 1ith t1o 1onderful 9ids0 Lance Alden !C -lives aged 20 and Mish 1ith t1o 1onderful 9ids0 Lance Alden !C -lives aged 20 and Mish Av
Aveline !eline !C -liC -lives agves aged (ed ( :
: 4h4he e fifirsrst t fifive ve yeyearars s of of ouour r coco%%%%onon$l$la1 a1 rerelalatitiononshship ip hahave ve bebeenen ha
har%r%ononioiousus He He 1a1as s a a grgreaeat t prprovovidider er fofor r hihis s fafa%i%ilyly He He shsho1o1eded nothing but being a loving and caring %an
)
) HoHo1e1eveverr0 0 ththinings gs chchanangeged d ststarartiting ng JuJuly ly ('('0 0 (8(85:5:0 0 1h1hen en he he 1a1ass te
ter%r%ininatated ed frofro% % ththe e fifir% r% 1h1here ere he he 1a1as s 1o1or9r9ining g .i.incnce e ththenen0 0 hehe beca%e ;obless and depressed
beca%e ;obless and depressed <
< *e*ee9s after he 1as tee9s after he 1as ter%inar%inated0 he persted0 he persistenistently loo9tly loo9ed for ;obs but toed for ;obs but to no avail All other fir%s and co%panies 1here he applied re;ected no avail All other fir%s and co%panies 1here he applied re;ected hi% =ecause of this0 he beca%e frustrated He easily gets %ad to %e hi% =ecause of this0 he beca%e frustrated He easily gets %ad to %e and our children
and our children 3
3 -n .epte%-n .epte%ber 530 (85:ber 530 (85:0 after he 1ent fro0 after he 1ent fro% a ;ob interv% a ;ob intervie1ie10 I tal9e0 I tal9ed tod to hi% and told hi% that the electricity bills and telephone bills are hi% and told hi% that the electricity bills and telephone bills are already due He responded violently and said0
already due He responded violently and said0 >Putang ina =ayarin na>Putang ina =ayarin na na%an?@ Hindi na natapos ang %ga babayaran na yan@B His response na%an?@ Hindi na natapos ang %ga babayaran na yan@B His response shoc9ed %e because I have never heard %y co%%on$la1 husband shoc9ed %e because I have never heard %y co%%on$la1 husband cursed li9e that no1ing hi% since college0 I 9no1 that he does not cursed li9e that no1ing hi% since college0 I 9no1 that he does not curse not use bad 1ords
curse not use bad 1ords especially in front of our childrenespecially in front of our children '
' -n .epte-n .epte%ber (80 (%ber (80 (85:0 aro85:0 around 58&und 58&88 p%0 he ar88 p%0 he arrived hrived ho%e druno%e drun9 I9 I offered hi% dinner Ho1ever0 1hen he found out that our food 1as offered hi% dinner Ho1ever0 1hen he found out that our food 1as only fish and vegetables0 he 1as enraged He said0 >Dulay?@ Dulay only fish and vegetables0 he 1as enraged He said0 >Dulay?@ Dulay lang ang ipapa9ain %o sa 9in? Ana9 ng puta@ Paano na%an a9o lang ang ipapa9ain %o sa 9in? Ana9 ng puta@ Paano na%an a9o %ag9a9aroon ng gana %aghanap ng trabaho niyan 9ung hindi %o 9o %ag9a9aroon ng gana %aghanap ng trabaho niyan 9ung hindi %o 9o pa9a9ainin
pa9a9ainin nang nang %aayos? %aayos? *a*ala la 9ang 9ang silbi@B silbi@B After After he he uttered uttered thosethose 1ords0 he thre1 the plates and the food in %y face He even poured 1ords0 he thre1 the plates and the food in %y face He even poured the glass of 1ater on %y face
the glass of 1ater on %y face
58 -n .epte%ber ((0 (85:0 I 1ent to %y %others house and as9ed for 58 -n .epte%ber ((0 (85:0 I 1ent to %y %others house and as9ed for %oney for the pay%ent of electricity bills After such0 I paid our bills %oney for the pay%ent of electricity bills After such0 I paid our bills and 1ent ho%e *hen %y husband arrived ho%e0 I infor%ed hi% that and 1ent ho%e *hen %y husband arrived ho%e0 I infor%ed hi% that I 1as able to pay the bills by borro1ing %oney fro% %y %other 4his I 1as able to pay the bills by borro1ing %oney fro% %y %other 4his angered hi% again In front of our 9ids0 he grabbed %y ar% and angered hi% again In front of our 9ids0 he grabbed %y ar% and pressed
pressed %y %y face face and and told told %e0 %e0 >Pinapa%u9ha >Pinapa%u9ha %o %o ba ba sa sa a9ing a9ing 1ala1ala a9ong 91entang a%a?@ Putang ina 9ang babae 9a@B He proceeded to a9ong 91entang a%a?@ Putang ina 9ang babae 9a@B He proceeded to hit %e in the face
hit %e in the face causing %e to lose %y causing %e to lose %y consciousnessconsciousness
55 *ith our savings gradually deteriorating and %y husband still ;obless0 55 *ith our savings gradually deteriorating and %y husband still ;obless0 I decided to apply for 1or9 I infor%ed %y husband of %y plan but he I decided to apply for 1or9 I infor%ed %y husband of %y plan but he 1as silent about it
1as silent about it
5(-n -ctober (:0 (85:0 I infor%ed hi% that I got accepted as a call 5(-n -ctober (:0 (85:0 I infor%ed hi% that I got accepted as a call center agent in 4eleperfor%ance Mall of Asia and 1as about to start center agent in 4eleperfor%ance Mall of Asia and 1as about to start %y training the ne/t 1ee9 Ever since0 he
%y training the ne/t 1ee9 Ever since0 he stopped loo9ing for ;obs andstopped loo9ing for ;obs and stayed ho%e
stayed ho%e
57 +ove%ber (0 (85:0 I started %y ;ob as a call center agent My shift 57 +ove%ber (0 (85:0 I started %y ;ob as a call center agent My shift 1as fro% (&88p% to 58&88p% *hen I arrived ho%e fro% 1or90 I 1as fro% (&88p% to 58&88p% *hen I arrived ho%e fro% 1or90 I found hi% drin9ing 1ith his college friends in our garden He then found hi% drin9ing 1ith his college friends in our garden He then approached %e and punched %e in the sto%ach0 in front of his friends approached %e and punched %e in the sto%ach0 in front of his friends
and our children He proceeded in accusing %e that
and our children He proceeded in accusing %e that I have a para%ourI have a para%our I re%e%ber hi% saying0 >I9a1 hayup 9a +apa9alandi %o talagang I re%e%ber hi% saying0 >I9a1 hayup 9a +apa9alandi %o talagang babae 9a
babae 9a Dabing$gabi na Dabing$gabi na ngayon 9a ngayon 9a lang u%u1i lang u%u1i .inong lala9e .inong lala9e %o0%o0 tang ina 9a?@B His college friends and our children tried to stop hi% tang ina 9a?@B His college friends and our children tried to stop hi% but
but he he even even pushed pushed our our son son a1ay a1ay causing causing Lance Lance to to fall fall and and sustainsustain %inor in;uries I 1as then rushed to the nearest clinic to treat %y %inor in;uries I 1as then rushed to the nearest clinic to treat %y 1ounds and contusions
1ounds and contusions
52 -n +ove%ber 5:0 (85:0 %y birthday0 I 1ent to %y %other and 52 -n +ove%ber 5:0 (85:0 %y birthday0 I 1ent to %y %other and
co
confnfesessesed d to to hher er 11hahat t ththe e rerespspoondndeent nt hhas as bbeeeen n dodoiing ng tto o %%ee "n9no1ingly0 %y %other tal9ed to respondent about it *hen I 1ent "n9no1ingly0 %y %other tal9ed to respondent about it *hen I 1ent ho%e that night0 the respondent pulled %y hair and pressed %y face ho%e that night0 the respondent pulled %y hair and pressed %y face against the 1all He said0 >Hayup 9a@ Magsusu%bong 9a pa sa nanay against the 1all He said0 >Hayup 9a@ Magsusu%bong 9a pa sa nanay %o?B
%o?B
5: -n +ove%ber (80 (85:0 right after %y shift0 I arrived ho%e early and 5: -n +ove%ber (80 (85:0 right after %y shift0 I arrived ho%e early and noticed so%e bruises to %y sons legs I as9ed hi% ho1 he sustained noticed so%e bruises to %y sons legs I as9ed hi% ho1 he sustained the% My son started crying I as9ed hi% 1ho did that to hi% and he the% My son started crying I as9ed hi% 1ho did that to hi% and he said0 >.i Papa poB 1hile crying
said0 >.i Papa poB 1hile crying 5) .ince I
5) .ince I coulcould not d not bear his hitting any%bear his hitting any%ore0 I ore0 I deciddecided to ed to %ove to %y%ove to %y %others place together 1ith %y
%others place together 1ith %y childrenchildren
5< 4he acts afore%entioned are violative of Republic Act +o '()( or 5< 4he acts afore%entioned are violative of Republic Act +o '()( or Anti$!iolence Against *o%en and 4heir Children Act of (882 1hich Anti$!iolence Against *o%en and 4heir Children Act of (882 1hich provides that
provides that !i
!iolence against 1o%en and their olence against 1o%en and their children refers to children refers to any act or any act or a series of acts co%%itted by any person against a 1o%an 1ho a series of acts co%%itted by any person against a 1o%an 1ho is his 1ife0 for%er 1ife0 or against a 1o%an 1ith 1ho% the is his 1ife0 for%er 1ife0 or against a 1o%an 1ith 1ho% the person has or had
person has or had a se/ual or dating relationship0 or a se/ual or dating relationship0 or 1ith 1ho%1ith 1ho% he has a co%%on child0 or against her child 1hether legiti%ate he has a co%%on child0 or against her child 1hether legiti%ate or illegiti%ate0 1ithin or 1ithout the fa%ily abode0 1hich result or illegiti%ate0 1ithin or 1ithout the fa%ily abode0 1hich result in or
in or is li9ely to is li9ely to result in physical0 se/ualresult in physical0 se/ual0 0 psycpsychologhological har%ical har% or suffering0 or econo%ic abuse including threats of such acts0 or suffering0 or econo%ic abuse including threats of such acts0 battery0
battery0 assault0 coercion0 harass%ent or arbitrary assault0 coercion0 harass%ent or arbitrary deprivation of deprivation of liberty
liberty It includes0 but is It includes0 but is not li%ited to0 the not li%ited to0 the follo1ing acts&follo1ing acts& A
A PhPhysysicical al !!iiololenencece rerefefers rs to to acacts ts ththat at ininclcludude e bobodidily ly or or physical har%6
physical har%6
PRAYER
PRAYER
*HEREF-RE0 pre%ises considered0 it is %ost respectfully prayed of *HEREF-RE0 pre%ises considered0 it is %ost respectfully prayed of this Honorable Court that after due notice and hearing0 ;udg%ent be rendered this Honorable Court that after due notice and hearing0 ;udg%ent be rendered in favor of Co%plainant&
in favor of Co%plainant& 5
5 For the issFor the issuance ouance of te%pof te%porary protrary protectioection order fro% rn order fro% responespondentdent66 (
( For thFor the pae pay%ent y%ent of supof support port to hito his chis childrenldren 7
7 -ther rel-ther reliefs ;ust aniefs ;ust and eGuitd eGuitable undable under the pre%iser the pre%ises are li9e1es are li9e1ise prayeise prayedd for
for
Cavite City0 Philippines0 April 570 (85) Cavite City0 Philippines0 April 570 (85)
ATTY. GRACE MARIELLE CRUZ ATTY. GRACE MARIELLE CRUZ Counsel for Plaintiff Counsel for Plaintiff Cru Associates La1 Fir% Cru Associates La1 Fir% 55< Da%boa .t0 .an Loreno0
55< Da%boa .t0 .an Loreno0 Cavite CityCavite City
VERIFICATION AND CERTIFICATION OF NONFORUM VERIFICATION AND CERTIFICATION OF NONFORUM
!"OPPING !"OPPING Republic of the Philippines
Republic of the Philippines
CCiitty y oof f CCaavviitte e K K ....
I0 MICHELLE A !ALE CR"#0 of legal age0 after having been duly I0 MICHELLE A !ALE CR"#0 of legal age0 after having been duly s1orn in accordance 1ith
s1orn in accordance 1ith la10 dla10 depose and state epose and state that&that& 5 I a% a
5 I a% a co%plainant in the above$stated case6co%plainant in the above$stated case6 ( I caused the preparation of
( I caused the preparation of the foregoing co%plaint6the foregoing co%plaint6
7 I have read the contents thereof and the facts stated therein are true and 7 I have read the contents thereof and the facts stated therein are true and co
corrrrecect t of of %y %y pepersrsononal al 9n9no1o1leledgdge e ananddor or on on ththe e babasisis s of of cocopipies es of of docu%ents and records in %y possession6
docu%ents and records in %y possession6
2 I have not co%%enced any other action or proceeding involving the sa%e 2 I have not co%%enced any other action or proceeding involving the sa%e issue
issues s in the in the .upre%.upre%e e CourCourt0 the t0 the Court of AppCourt of Appeals0 or eals0 or any other tribunaany other tribunal or l or agency6
agency6
: 4o the best of %y 9no1ledge and belief0 no such action or proceeding is : 4o the best of %y 9no1ledge and belief0 no such action or proceeding is pending in the .upre%e Court0 the Court of A
pending in the .upre%e Court0 the Court of Appeals0 or any other tribunal or ppeals0 or any other tribunal or agency6
agency6
) If I should thereafter learn that a si%ilar action or proceeding has been ) If I should thereafter learn that a si%ilar action or proceeding has been filed or is pending before the .upre%e Court0 the Court of Appeals0 or any filed or is pending before the .upre%e Court0 the Court of Appeals0 or any
other tribunal or agency0 I underta9e to report that fact 1ithin five :K days other tribunal or agency0 I underta9e to report that fact 1ithin five :K days therefro% to this Honorable Court
therefro% to this Honorable Court
Cavite City0 Philippines0 April 570 (85) Cavite City0 Philippines0 April 570 (85)
Michelle
Michelle A !A !ale Cruale Cru
."=.CRI=E, A+, .*-R+ 4- before %e this April 570 (85) in Cavite0 ."=.CRI=E, A+, .*-R+ 4- before %e this April 570 (85) in Cavite0 Philippines the follo1ing affiant e/hibiting to %e her Passport +o 5:35:< Philippines the follo1ing affiant e/hibiting to %e her Passport +o 5:35:< iss
issued ued at at ,F,FA ManiA Manila la beibeing ng sufsuffificiecient nt and and co%co%petpetent ent evievidendence ce of of her her identity in pursuant to the (882 Rules of +otarial Practice
identity in pursuant to the (882 Rules of +otarial Practice
,
,oocc ++oo66 aayyeellyyn n LLaatt P
Paagge e ++oo66 ++--44AARRN N PP""==LLIIC C ffoor r CCaavviittee =oo9
=oo9 +o+o6 6 Co%%ission Co%%ission .erial .erial +o +o .
.eerriiees s oof f ((8855)) ""nnttiil l ,,eeccee%%bbeer r 77550 0 ((8855)) Roll of
Roll of AttorneyAttorney I=P +o
I=P +o P4R +o P4R +o
