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Republic of the Philippines

National Capital Judicial Region


REGIONAL TRIAL COURT
Branch 165, Marikina City

PEOPLE OF THE PHILIPPINES,


Plaintiff,
CRIM. CASE NO. 4444-0000
- versus - For: KIDNAPPING

JUAN P. KIDNAPERO,
Accused.

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COMPLAINT-AFFIDAVIT

I, ALICIA A. ABANILLA, 55 years old, married, and a resident of Block 5, Lot


10, New York Street, Phase 15, Cherry Subdivision Antipolo City, accuses JUAN P.
KIDNAPERO of the crime of Kidnapping after having been duly sworn to in accordance
with law, hereby deposes and says THAT:

1. Last February 14, 2018, on or about 6:30 A.M. while I was on my usual route to
work as an executive secretary of ZUELLIG PHARMA, was abducted by JUAN
P. KIDNAPERO, who is my “inaanak” (godson) in a wedding while boarding
a bus near Filinvest Marcos Highway;

2. I was forcibly taken by him from the bus stop and was asked for Php300,000.00
in return for my release. Accused informed me that his wife is scheduled for a
Caesarian operation and they would be needing the said amount.

3. That I retorted I didn’t have any available cash that time and I will not be
available to give him the full amount that he was asking. Upon hearing this, he
pointed a gun at my side and told me that I need to go with him.

4. Due to fear for my life and safety, I was forced to follow him. At that instance, a
Montero 2017 SUV stopped and the foreigner-driver asked us: “May problema
ba?” Accused pointed the gun to the driver and told him to open the car door.

5. Inside the car, accused told the driver to continue driving. After his instructions,
he asked me to call my boss and to ask for Php 300, 000.00 and that only a lady
messenger can bring the money to Hi-top supermarket in Anonas and that no
police or security shall be informed.

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6. Trembling, I called my boss and told him to lend me Php 300,000.00 as I was
being held hostage and that my life is in danger.

7. Thereafter, we were headed to Hi-top supermarket where we met “Inday”, a lady


messenger sent by my boss to bring the money. He instructed the driver to get
the money from “Inday” and to immediately go back after being able to get the
bag of money.

8. After handing the bag of money to accused, the driver was told to drive us to
Marikina Valley Hospital. On our way, we took the chance to be able to escape
when accused tried to check the bag. I sprayed his eyes with perfume and the
driver opened the rear door on his side while we were passing an intersection
with a traffic enforcer. I pushed him from the car where he fell down.

9. We stopped and asked the traffic enforcer to help us and that the accused is a
kidnapper. The traffic enforcer called for reinforcement from a nearby patrol
and the accused was brought to the nearest police precinct.

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


to file a case for KIDNAPPING and/or the appropriate criminal case against
JUAN P. KIDNAPERO, who is 30 years of age and a resident of Block 1, Lot
2, MLC Street, Phase 3, Quiapo Subdivision, Bulacan.

IN WITNESS WHEREOF, I have hereunto set my hand this 15th day of February
2018 at Marikina City, Philippines.

ALICIA A. ABANILLA
Affiant

SUBSCRIBED AND SWORN to before me this 15th day of February 2018 at


Marikina City, Philippines and I FURTHER CERTIFY that I have personally examined
the affiant and I am satisfied that he/she has read and personally understood the contents
of her foregoing “Complaint-Affidavit”.

EVALYN B. BOBIS
Prosecutor II
Roll No. 51379-2008

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IBP No. 808787-1/3/09
PTR No. 4128464- 1/3/11; Marikina City
MCLE Compliance III No. 0013601
Issued on April 22, 2015

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