REPUBLIC OF THE PHILIPPINES

FIRST JUDICIAL REGION

REGIONAL TRIAL COURT
Branch 19, Bangui, Ilocos Norte

AMIELA SARMIENTO-SANTOS
Complainant, Criminal Case No. 2172-19
versus For
CONCUBINAGE
JOSEPH JHONLEE D. SANTOS &
QUEEN JAREMY CASTILLO
Respondent.
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COMPLAINT AFFIDAVIT

I, AMIELA SARMIENTO-SANTOS, of legal age, married and a resident of Poblacion 2,

Davila, Pasuquin, Ilocos Norte, under oath, declare that:

1. On March 20, 2016, JOSEPH JHONLEE D. SANTOS, the respondent, and I got
married.

2. On 31 March 2016, I saw the respondents JOSEPH JHONLEE D. SANTOS and

QUEEN JAREMY CASTILLO in Starbucks Bangui, eating together. Having doubts of
my husbands fidelity, I decided to investigate. I left the establishment, stayed in my car
and saw them leaving the establishment after Jhonlee gave Queen a kiss on the cheek.

3. On May 25, 2016, I saw credit card receipts in my Husbands wallet which shows
jewelry, a tennis bracelet, bought from Tiffany and Co by Jhonlee with his Mastercard. I
also saw the same jewelry referred in the receipt in a box beside my husbands suitcase
inside the closet. A copy of the credit card receipts is hereto attached as
Annex A

4. When I opened my husbands suitcase, I saw a used roundtrip plane ticket for MNL-
Hongkong-MNL. The tickets were issued under the names of respondents, for the
period of April 18-19, 2016. A copy of the roundtrip plane tickets is hereto attached as
Annex B.

5. Upon further investigation, I also found receipts showing that respondents had stayed
together in one suite at the Marco Polo Hotel. Their stay together at a hotel has also
persuaded me that they have already had carnal knowledge of one another. A copy of
the receipts showing proof of their stay at the Marco Polo Hotel is hereto attached as
Annex C.

6. That I have seen a Sex Video of My Husband Johnlee and Queen in the Cellphone of
my husband.

6. In addition, it is most unlikely that Ms. QUEEN JAREMY CASTILLO had not been
aware of my husbands current status as a married man seeing as this affair has been
going on for more than a year. They have been meeting together discreetly as well as
leaving on trips together abroad and meeting with another at hotels.
7. Based on the foregoing facts, I have logical reason to believe that the respondents
have committed the crime of Concubinage punishable under Art. 334. Concubinage.
Any husband who shall keep a mistress in the conjugal dwelling, or shall have sexual
intercourse, under scandalous circumstances, with a woman who is not his wife, or shall
cohabit with her in any other place, shall be punished by prision correccional in its
minimum and medium periods, under the Revised Penal Code.

8. I am executing this sworn statement for the purpose of charging my husband and his
concubine with violating Art. 334 of the Revised Penal Code which penalizes the crime
of concubinage. At Pasuquin Ilocos Norte, Philippines. June 25, 2017.

AMIELA SARMIENTO-SANTOS
Complainant

SUBSCRIBED and SWORN to before me, the undersigned prosecutor, this 25th day of
November, 2017 in Bangui, Ilocos Norte, Philippines.
I hereby certify that I have personally examined the above-named affiant and that I am
satisfied that the foregoing statements were given by her voluntarily and of her own free
will.

ATTY. BOB-ONG SARMIENTO

IBP O.R. No. 531220
PTR No. 792361

VERIFICATION and CERTIFICATION

 AGAINST FORUM SHOPPING

Republic of the Philippines )

) s.s
I AMIELA SARMIENTO-SANTOS of legal age, after having been sworn
according to law, depose and say:

1. That I am the complainant in the above-captioned case;

2. That I caused the preparation of the above complaint;
3. That the contents thereof are known to me personally and according to
relevant and authentic documents; and
4. That I have not commenced any other action or proceeding involving the
same issues in the Supreme Court, the Court of Appeals, or any other tribunal
or agency; that to the best of my knowledge, no such action or proceeding is
pending in the Supreme Court, the Court of Appeals, or any other tribunal or
agency; and that if I should hereafter learn that a similar action or proceeding
has been filed or is pending before the Supreme Court, the Court of Appeals,
or any other tribunal or agency, I undertake to report that fact to the Court
within five (5) days.

IN WITNESS WHEREOF, I have hereunto set my hands this 25th day of

June, 2017 at Pasuquin, Ilocos Norte .

AMIELA SARMIENTO-SANTOS
Affiant

SUBSCRIBED AND SWORN to before me this 25th day of June at Pasuquin, Ilocos
Norte, Philippines.

ATTY. BOB-ONG SANTOS

IBP O.R. No. 531220
PTR No. 792361

REPUBLIC OF THE PHILIPPINES

 FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 19, Bangui, Ilocos Norte

AMIELA SARMIENTO-SANTOS
Complainant, Criminal Case No. 2172-19
versus For
CONCUBINAGE
JOSEPH JHONLEE D. SANTOS &
QUEEN JAREMY CASTILLO
Respondent.
x----------------------------------------------x

INFORMATION

The undersigned, AMIELA SARMIENTO-SANTOS, accuses JOSEPH JHONLEE

D. SANTOS & QUEEN JAREMY CASTILLO of the crime of CONCUBINAGE,
committed as follows, to wit:

That on or about 31 March 2016, May 25, 2016, April 18-19, 2016, in the
City/Municipality ofPasuquin, Province of Ilocos Norte and within the
Jurisdiction of this Honorable Court, the accused JHONLEE D. SANTOS who is
the husband of the undersigned Complainant, cohabited and under
scandalous circumstances with his co-accused QUEEN JAREMY CASTILLO as
husband and wife in a private dwelling, Producing a sex taped video.
Contrary to law.
Pasuquin, Ilocos Norte, Philippines, June 25, 2017

AMIELA SARMIENTO-SANTOS
COMPLAINANT

SUBSCRIBED AND SWORN to before me this 25th day of June at Pasuquin, Ilocos
Norte, Philippines.

ATTY. BOB-ONG SARMIENTO

Prosecutor 1
IBP O.R. No. 531220
PTR No. 792361

Witnesses:

AN- B. ABAHO KOH T. ALAGA SOH O. BRAH

Prc ID No. 123456 Prc ID No. 223344 Prc ID No. 2345