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I, JILLENE C. SAVELLANO, Filipino, of legal age, married
and a resident of No. 1234 Pasedea FB Harisson Pasay City,
Philippines, after having been sworn to in accordance with law,
hereby deposes and say that:

1. At around 3 p.m., I received a call from my brother-inlaw, Moreno M. Ilao Jr. (Moreno for brevity) informed
me that my daughter, Joyce, was kidnapped by two
unidentified men ), as my helper , Kristine Joyce
Dalangin (Dalangin for brevity) assumed that these
two men were the persons instructed by Moreno to
deliver the gift to my daughter Joyce; I rushed home

2. At around 4 p.m. of December 14, 2014, I received the

first call from the kidnappers. He introduced himself as
June. He demanded a ransom of PhP 10 million for Joyce
and ordered me not to report the matter to the police
else Joyce will be harmed. A friend of my parents,
however, reported the kidnapping to the PACC Special
Operations Task Force Habagat headed by General
Marianito Arias Jr. (Gen. Arias for brevity);

3. While I was trying to pool resources from friends and

relatives, I continued receiving calls from the same
negotiator urging me to cooperate;

4. Through another call around 4:30 pm, the negotiatorkidnapper instructed me to produce three (3) individuals
for him (negotiator-kidnapper) to interview and choose
from to deliver the money, the qualifications given was
mapapagkatiwalan ng pera, hindi ninyo kamag-anak,
mukhang instik at marunong managalog.


Since we have few family friends that have Chinese

blood, we were only able to ask the help of my
daughters godfather, Eric Reynoso (Reynoso for
brevity). I called Reynoso around 5:00 pm who was
willing to help deliver the money if selected;

6. At around 10:00 p.m., I again received a call from the

kidnappers, but this time by a different person. He
inquired if I was able to come up with three (3)
individuals; I informed the
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negotiator that we could only come up with

one: Reynoso; the kidnapper asked me to tell Reynoso
to come at our house the next day.

7. The next day, December 15, 2014, at 8:00 a.m.,

Reynoso arrived. The kidnappers called in the
afternoon. They interviewed Reynoso on the phone. The
ransom was reduced to PhP 8 million, which was further
reduced to PhP 5 million at 4:00 p.m. But I still could not
raise the amount. After dinner, the negotiator
instructed Reynoso to go home. Reynoso borrowed my
car. Thereafter, I received another call threatening,
puputulin ko ang daliri ng anak mo, papatayin ko

8. After a while, the kidnappers called again demanding for

Reynoso to come back, and Reynoso came back to our
residence at around 8:00 p.m. I was then instructed to
have the ransom money delivered, which at that time
was significantly reduced to PhP 2.5 million and which
we were able to raise that day. It was to be placed in a
box and gift wrapped. Reynoso was instructed by the
negotiator to deliver the ransom money at the Quezon
Memorial Circle near GSIS. Reynoso then took my red
Honda Civic Plate No. TGH 439;

9. On the way, Reynoso called me telling me that he was

intercepted by two cars which he had to follow. The
PACC operatives, tailing Reynoso, were on radio contact
with me, however, belied Reynosos allegation of
interception. The PACC then suspected Reynoso to be in
cahoots with the kidnappers.

10. Eventually, Reynoso, bringing Joyce, arrived at my

place past midnight. Reynoso told me hinarang ako
inipit ako sa dalawang kotse at nakita ko si June sa isa
sa mga sasakyan. Five minutes after Reynosos arrival,
Gen. Arias and his men arrived and arrested Reynoso;

11. A few hours thereafter, at around 4:00 a.m. of

December 16, 2014, I received a call from Gen. Arias
informed me that the ransom money was recovered
except for PhP 1,000,000 which were given by Reynoso
to herein respondents Garduque and Zaraspe;

12. At around noon of December 16, 2014, I again

received a call from the PACC informing me that
Reynoso wanted to talk to me. Reynoso apologized to
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me saying, Sorry, ginawa ko sa inyo ito, napipilitan

lang ako and Tutulong naman ako sa PACC ibinigay ko
na yung dalawang pangalan;

13. Reynoso admitted that he was the mastermind of the

crime and named June J. Garduque (Garduque for
brevity) and Gerard O. Zaraspe (Zaraspe for brevity)
as the men who kidnapped Joyce in their house. At 4:00
p.m. of December 16, 2014, I received a call from the
PACC confirming the arrest of both Garduque and
Zaraspe. And, later, at 9:00 p.m., the PACC further
informed me that they have recovered my red Toyota

14. That in view of the foregoing, I am executing this

complaint-affidavit freely and voluntarily in order to file
a case for the crime of KIDNAPPING FOR RANSOM
under the RPC particularly, Article 267 thereof, against
herein Respondents;

15. That in support hereof, I attached the affidavits of my

servant, of Moreno and of General Arias marked hereto
as Annex 1 and series and made integral parts hereof;

IN WITNESS WHEREOF, I have hereunto affixed my signature

on 18th day of December 2014 at Pasay City, Philippines.

SUBSCRIBED AND SWORN to before me this 18 th day of
December 2014 at Pasay City, Philippines. I FURTHER CERTIFY
that I have personally examined the affiant and I am satisfied
that she has read and personally understood the contents of the

Assistant City Prosecutor

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