Republic of the Philippines

Department of Justice
National Prosecution Office
Office of the City Prosecutor
Manila

People of the Philippines,

Plaintiff,

- versus - CRIMINAL CASE N0. 23458

FORCIBLE ABDUCTION
WITH RAPE
JULIO JOSE
234 Asuncio Street,
Tondo, Manila.
Accused.
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COMPLAINT

The undersigned accuses Julio Jose of the crime of Forcible Abduction with Rape,

committed as follows:

That on or about July 9, 2012, in the City of Manila, Philippines, the said accused, with

lewd designs, did then and there willfully, unlawfully and feloniously abduct, take and carry

away the undersigned complainant while coming out of a toilet in her home at 113 Magsaysay,

Tondo, in said City, by means of force, violence and intimidation to wit: by pulling her and

forcing her to walk, at the same time pointing at her a gun and threatening to kill her should she

cry out for help, succeeded in bringing her to ride in his car, where they rode going to the house

of the accused’s Uncle Sam where the said accused, by means of force, violence and

intimidation, succeeded in having sexual intercourse with her against her will.

Contrary to law.

KATERINA MONTENEGRO
Complainant

SUBSCRIBED AND SWORN TO before me this 13th day of August, 2012, in the City of
Manila, Philippines, by Katerina Montenegro, the complainant.

______________________________
Assistant Prosecutor
 I hereby certify that an ex-parte investigation in this case has been conducted by me in
accordance with law; that there is reasonable ground to believe that the offense charged has been
committed; and that the accused is probably guilty thereof.

Manila, August 13, 2012.

________________________
Assistant Prosecutor

WITNESSES:

1. Katerina Montenegro, 113 Magsaysay St., Tondo, Manila.

2. Det. Roger Salas, and Det. Arturo Santos, both of DB Detachment 3, MPF

3. Dr. Lorenzo Clarion, Medico Legal Div., MPF

4. Nathaniel Montenegro, 113 Magsaysay St., Tondo, Manila.

BAIL RECOMMENDED: THREE HUNDRED THOUSAND PESOS (P300,000.00) ONLY.