Republic of the Philippines

DEPARTMENT OF JUSTICE
REGIONAL TRIAL COURT
Quezon City

POECHIZ CANTEEN INC.,

Complainant,

- versus -

Case No. 05-12817-10

RO-RO ACADEMY,
Respondent.
x-----------------------------------------------x

COMPLAINT-AFFIDAVIT
I, Miriam Marcos, of legal age, Filipino, married, and a resident
of 116 Sampaloc, Manila, Philippines, after having been duly sworn in
accordance with law, do hereby depose and state:

1.

That I am the president of PoeChiz Canteen Inc., (PoeChiz), a

company which offer school meal and refreshments to the employees,
teachers and students of Ro-Ro Academy.

2.

That PoeChiz entered into an agreement with Ro-Ro Academy (Ro-Ro),

and as part of our agreement, PoeChiz would remit percentage of its
cash sales to Ro-Ro, on top of a fixed amount, for the use of their
Conservatorys south wing in setting up the canteen.

3.

That on October 15, 2015, Ro-Ro terminated its agreement with

PoeChiz after PoeChiz had started defaulting on its obligations.

4.

That on October 20, 2015, upon questioning why Ro-Ro terminated

its agreement with PoeChiz, Ro-Ro, however, posted in a conspicuous
manner, plain sight to public, an advisory at the campus gate and in
front of the Conservatory.

5.

That such advisory is defamatory and malicious for implying that

PoeChiz is a bad debtor after Ro-Ro disclosed to the public its
disagreements with PoeChiz. And for stating that PoeChiz had caused
disturbance or harm to Ro-Ros employees, teachers and students,
making it appear to the public that PoeChiz, through its directors and
officers, were hooligans.

6.

That such act of posting was done in malice considering the fact that
Ro-Ro posted information that injured the reputation of the party
(PoeChiz) defamed.

7.

That the advisory tend to cause dishonor, discredit or contempt on

the part of company and its directors and officers, as would inflict
PoeChizs reputation considering that it had been in the food industry
for so long and it caters other schools as well.

8.

That such advisory had brought PoeChiz and its directors and officers
so much disgrace and humiliation. And as its president, I couldnt eat
nor sleep for days.

9.

That in view of the stated facts, there is a clear showing of defamation

in the advisory seen by the public, which was done maliciously, and
that PoeChizs identity was clearly identified. Therefore, it is crystal
clear that the unlawful act exercised by Ro-Ro constituted a crime of
libel.

10.

That I am executing this complaint-affidavit to attest to the

truthfulness of the forgoing facts and that in the instant COMPLAINT be
acted upon as soon as possible.

11.

That the acts of Ro-Ro Academy, through its directors and officers be
investigated and upon finding probable cause that the corresponding
information for cases for appropriate civil and/or criminal cases
including defamatory and malicious publication offenses be filed in the
appropriate court PROMPTLY in the interest of fair and honest
discussion and to insure expeditious settlements of issues arising from
the agreement.
CERTIFICATION
SUBSCRIBED AND SWORN to before me this 14 th day of November
2015 at Quezon City.
I hereby certify that I have personally examined the Affiant and
that I am satisfied that he voluntarily executed and understood the
foregoing Complaint-Affidavit.
Quezon City, November 14, 2015.

POECHIZ CANTEEN INC.,

Complainant
By:
Atty. Jejomar Honasan
Managing Partner, BiHon Law Offices
Counsel for Complainant
Roll No. 41194

ISSUED I.D. ____

VALID UNTIL ____
DATE OF ISSUE ____
PLACE OF ISSUE ____
Series of 2014.