REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
CITY OF MANILA

Lilibeth “Lyka” Virginia

Complainant
vs. I.S. No. ____________
For: Rape
Dominador “Drex” Narzabal,
Menandro “Andre” Contante
Respondents.

x-----------------------------------------------------------------------------------------x

COMPLAINT-AFFIDAVIT

I, LILIBETH “LYKA” VIRGINIA, Filipino, of legal age, with

residence at No. 50 Anonas Street, Sta. Mesa, Manila, after having been duly

sworn in accordance with law, hereby depose and state that:

(1) This complaint-affidavit is being filed to charge Dominador Narzabal

a.k.a “Drex”, Filipino, of legal age, and with residence at No. 219 Brgy

985, Ermita, Manila, and Menandro Contante a.k.a “Andre”, Filipino, of

legal age, and with residence at No. 75 Brgy 758, Paco, Manila of the

crime of Rape under Article (Art.) 266 of the Revised Penal Code (RPC),

committed as follows:

(a) On December 2, 2018, at around 10:00 in the evening, while I was

working as a Guest Relations Officer at Ermita Club 69, Andre

approached me and asked me to join him and his friend, Drex at their

table as the latter was celebrating his birthday at the time.

(b) That upon arriving at their table, Drex handed me a glass of beer,

saying: “Tagay para sa tagumpay!” I initially declined the offer as I

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 don’t drink while at work, but both Andre and Drex insisted so I

agreed to take a sip.

(c) When Andre noticed that I was barely drinking, he nudged Drex at

the elbow, said “Papahirapan tayo ni Ganda,” and laughed. Drex

then urged me to drink by putting one thousand peso bill on the table,

saying: “Isang libo para sa isang baso. Sagot na namin buong gabi

mo.”

(d) Within 5 to 10 minutes after drinking the whole glass, I suddenly felt

motionless and slowly losing my consciousness so decided to get up

so I could go back to the dressing room. But Drex and Andre also

stood up and positioned themselves by my side as they proceeded to

assist me.

(e) The next thing I remember, I was inside the hotel room naked and

Drex was trying to get on top of me. I cried for help but Drex started

to kiss me on my lips and neck. He pulled out his genital organ and

inserted it into my vagina and started to rape me. I tried to push Drex

off of me but to no avail as I felt too weak

(f) After satisfying his carnal desires, Drex told Andre, “Tol, ikaw

naman.” Andre then started raping me.

(g) While I was lying on my back crying, Drex again approached me and

threatened me: “Wag kang maingay kahit kanino. Kami na bahala

sayo.” He then pulled some bills from his pocket and forced me to

hold said bills. Then they left me at the hotel.

(2) I am deeply traumatized by the said event so I called my friend, Kristine,

and told her everything.

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(3) Appalled by what happened, Kristine and I went to the police station to

report the crime committed by Drex and Andre against my person. The

police took my sworn statement, a copy of which is hereto attached and

made an integral part hereof as Annex “A”. Thereafter, I was examined

by their medico-legal officer. A copy of the Medico-Legal Report is

likewise hereto attached and made an integral part hereof as Annex “B”.

(4) The elements of rape are carnal knowledge, force or intimidation, and the

commission of the act without the consent or against the will of the

woman, or when the latter is under twelve (12) years of age or when she

is deprived of reason or otherwise unconscious.

(5) Based on the foregoing, it is beyond cavil that respondents Dominador

“Drex” Narzabal and Menandro “Andre” Contante committed the crime

of rape punishable under Art. 266 of the RPC. They had sexual

intercourse with me by forcing themselves unto me. This constitutes rape

as defined in our laws.

(6) Further, whenever the crime of rape is committed with the use of a deadly

weapon or by two or more persons, the penalty shall be reclusion

perpetua to death.

AFFIANT FURTHER SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto set my hand this 18th day

of February 2014, in Cavite City.

Lilibeth “Lyka” Virginia

Complainant/Affiant

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 SUBSCRIBED AND SWORN TO before me, this 12 th day of

December 2018 in City of Manila .

Prosecutor

This is to certify that I have personally examined the herein affiant

and that I am satisfied that she voluntarily executed and understood her

statements herein.

Prosecutor

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 ANNEX “A”
REPUBLIC OF THE PHILIPPINES )
CITY OF Manila ) S.S.

SINUMPAANG SALAYSAY

I am Lilibeth Virginia, Filipino, of legal age, and with residence at No. 50 Anonas Street, Sta.
Mesa, Manila, after having been duly sworn in accordance with law, hereby depose and state that:

1. On December 2, 2018, at around 10:00 in the evening, while I was working as a Guest
Relations Officer at Ermita Club 69, Andre approached me and asked me to join him and his
friend, Drex at their table as the latter was celebrating his birthday at the time.

2. That upon arriving at their table, Drex handed me a glass of beer, saying: “Tagay para sa
tagumpay!” I initially declined the offer as I don’t drink while at work, but both Andre and
Drex insisted so I agreed to take a sip.

3. When Andre noticed that I was barely drinking, he nudged Drex at the elbow, said
“Papahirapan tayo ni Ganda,” and laughed. Drex then urged me to drink by putting one
thousand peso bill on the table, saying: “Isang libo para sa isang baso. Sagot na namin buong
gabi mo.”

4. Within 5 to 10 minutes after drinking the whole glass, I suddenly felt motionless and slowly
losing my consciousness so decided to get up so I could go back to the dressing room. But
Drex and Andre also stood up and positioned themselves by my side as they proceeded to
assist me.

5. The next thing I remember, I was inside the hotel room naked and Drex was trying to get on
top of me. I cried for help but Drex started to kiss me on my lips and neck. He pulled out his
genital organ and inserted it into my vagina and started to rape me. I tried to push Drex off of
me but to no avail as I felt too weak.

6. After satisfying his carnal desires, Drex told Andre, “Tol, ikaw naman.” Andre then started
raping me.

7. While I was lying on my back crying, Drex again approached me and threatened me: “Wag
kang maingay kahit kanino. Kami na bahala sayo.” He then pulled some bills from his pocket
and forced me to hold said bills. Then they left me at the hotel.

IN WITNESS WHEREOF, I have hereunto set my hand this 4 th day of January 1999, in Makati
City.

LILIBETH VIRGINIA
Affiant

SUBSCRIBED AND SWORN to before me this 4 th day of January 1999 at Philippine National
Police Station 123, Cavite City. I further certify that I have personally examined the Affiant and I am
satisfied that he/she voluntarily executed and understood his/her statement.

LIZA SOBERANO
Administering Officer

Doc. No. _____;

Page No. ____;
Book No. ____;
Series of 1999.

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 ANNEX “B”
OSPITAL NG MAYNILA
Medical Record Division
President Quirino Avenue,
Malate, Manila,

MEDICO LEGAL CERTIFICATE

December 3, 2018

TO WHOM IT MAY CONCERN:

This is to certify that Ms. Lilibeth Virginia, of legal age, with residence at No. 50
Anonas Street, Sta. Mesa, Manila, was examined and treated in this hospital on January
4, 1999 with the following findings:

- shallow healed lacerations at 3 and 8 o’clock positions

- in a non-virgin state physically

Issued this 3rd day of December 2018, for whatever purpose it may serve.

This certificate is issued by authority of the Director:

Dr. Vicky Belo, M.D.