REPUBLIC OF THE PHILIPPINES )

PROVINCE OF DAVAO DEL SUR ) S.S.

MUNICIPALITY OF DIGOS. . . . . . . . . . . . .)
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COMPLAINT AFFIDAVIT
I,

CAPT. RAMON MIGUEL RODRIGUEZ, Filipino, of legal

age, single, and Chief of Police of Digos City, Davao del Sur, after
having been duly sworn to in accordance with law, do hereby
depose and say:
1. That I am the same and identical person who caused the
execution of this complaint-affidavit;
2. That on January 5, 2015, at around 9:00 a.m., we received a
police assistance call from one Lyndon Monday, a traffic
aide dispatched near Lapu-Lapu Extension, Digos City, who
witnessed an unidentified man, later identified as Uriel
Peter Y Pabalan, fire two shots at the back of an unidentified
woman, later revealed to be the victim as Virginia Abil.
(Attached herewith is the Post-Mortem Examination of
Virginia Abil marked as Annex A);
3. That according to Lyndon Monday, after he saw Pabalan
shoot Abil, the former fired at Pabalan; but said traffic aide
missed him. He also mentioned that after the shootout,
Pabalan fled on foot;
4. Acting as Chief of Police of Digos City, I alerted my men
near the vicinity of the incident to respond. Among the
police

officers

who

responded

were

Victoriano and SPO2 Jeffrey Navarra;

SPO1

Jefferson

5. On the same day, at about 9:30 a.m., the above responding

elements of the Digos Police Station apprehended Pabalan
in a grassy area near SM Eatery located along Lapu-Lapu
Extension. The police confiscated his .22 caliber Smith and
Wesson Magnum with four (4) live ammunitions and two (2)
spent shells, and recovered
Page 2 Complaint-Affidavit
CAPT. RAMON MIGUEL RODRIGUEZ
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a bag containing Php 450,000.00 consisting of P1,000.00
and P500.00 bills. (Attached herewith are the pictures of a
confiscated .22 caliber Smith and Wesson Magnum marked
as Annex B, a picture of two (2) spent shells marked as
Annex C and a picture of the recovered plastic bag
containing Php 450, 000.00 marked as Annex D);
6. At about 10:15 am of the same day, a taxi cab driver who
identified himself as Joseph Madriaga went to the Digos
Police Station and recounted the events to P/Insp. Princess
Watin that he was the taxi driver who drove both Pabalan
and Abil. According to Madriaga, he saw Pabalan extract
money from Abil and how the accused restricted her
movements. He also revealed that he was present in the
crime scene where Abil was killed by Pabalan. (Attached
herewith is the Police Blotter attached as Annex E);
7. Based on the above circumstances, it is obvious that
Pabalan, being a private individual, did then and there
wilfully, unlawfully and feloniously, for the purpose of
extorting ransom from one Virginia Abil and of killing the
said Virginia Abill if the desired amount of money could not
be given; kidnap, carry away, detain and deprive the said
Virginia Abil of her liberty without authority of law, against
her will and consent;

8. Citing the recall of the above witnesses, it is apparent that

said Pabalan with the use of superior strength, did then and
there wilfully, unlawfully and feloniously, with intent to kill
and with treachery, attack, assault and use personal
violence upon one Virginia Abil by then and there aimed his
gun at the back of his ill-fated victim, shot at her twice,
hitting her just above her nape, thereby inflicting upon the
latter mortal wounds which were the direct and immediate
cause of her death thereafter;
Page 3 Complaint-Affidavit
CAPT. RAMON MIGUEL RODRIGUEZ
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9. That I am executing this complaint-affidavit to attest to the
truth of the foregoing and to file the appropriate criminal
case or cases against URIEL PETER Y PABALAN, with
residence at 14344 Estrada Blvd., Digos City as the
aforementioned circumstances warrant;
10.

That I am executing this complaint-affidavit freely and

voluntarily;
IN WITNESS WHEREOF, I have hereunto set forth my hand
this 8th day of January 2015 at Digos City, Davao del Sur,
Philippines.

CAPT. RAMON MIGUEL RODRIGUEZ

Affiant
SUBSCRIBED AND SWORN TO BEFORE ME this 8 th day of
January 2015 at Digos City, Davao del Sur Philippines.

PEARL ANGELI Q. CANADA

Associate Prosecutor Attorney II