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Republic of the Philippines

City of Davao s.s.

AFFIDAVIT-COMPLAINT

I, SPO2 Dos, 35 years old, married, and a resident of Block 30, Lot 11, Nawa Street,
Phase 4, V&G Subdivision, Davao City, after having been duly sworn to in accordance with law,
hereby deposes and says THAT:
1. I am a PNP soldier assigned in Talomo Police Station.

2. On December 2, 2016, at around 5.:30 in the morning I was accompanied by SPO1


Uno. We were riding a motor vehicle to get to Talomo Police Station. SPO1 Uno was
the one driving said vehicle. When we got to barangay Bayabas, Toril we were
ambushed by a group of armed men. They were almost more or less 30 meters
away from the said vehicle when they ambushed us. They concealed themselves by
hiding in a large tree and bushes. Both, SPO1 Uno and I, SPO2 Dos, dropped to the
ground due to the hail of bullets fired towards us. Due to the inflicted gunshot
wounds to the body and chest of SPO1 Uno, this lead to his instant death. I only
sustained wounds on my chest and body due to the gunshots;

3. The perpetrators were wearing combat uniforms having NPA


emblem/insignia/symbol. They were heavily armed as they carried with them
high caliber automatic weapons.

4. I have recognized one of the faces of the perpetrators. His face was the
exactly the same as @KA BOBBY also known as JUAN DELA CRUZ. I came
to know of his face due to the fact he is a wanted criminal and on the watch
list of the AFP and PNP. His face is well known amongst the PNP and AFP as
he is known as a notorious rebel leader of the NPA.

5. I am therefore executing this affidavit freely and voluntarily in support of my


intent to file a case of FRUSTRATED MURDER and/or the appropriate
criminal case against JUAN DELA CRUZ @ KA Bobby, whose whereabouts
are unknown.

IN WITNESS WHEREOF, I have hereunto set my hand this 3rd day of


December 2016 at Davao City, Philippines.

SPO2 DOS
Affiant

SUBSCRIBED AND SWORN to before me this 3rd day of December 2016 at


Davao City, Philippines and I FURTHER CERTIFY that I have personally examined the
affiant and I am satisfied that he has read and personally understood the contents of her
foregoing “Complaint-Affidavit”.
DANIEL PADILLA
Assisting Provincial Prosecutor
Roll No. 898989-2016
IBP No. 898989-1/1/2016
PTR No. 898989-6/6/2016
MCLE Compliance No. 990909
Issued on December 3, 2016