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2018-80004

Republic of the Philippines


REGIONAL TRIAL COURT
4th Judicial Region
Branch 24
Laguna

People of the Philippines,


Plaintiff,
Criminal Case No: 2018
- versus - For: Kidnapping with
Murder and Robbery
with Violence Against
Persons

Christen Alvarez Cruz and April Rose Celemin Mapa,


Accused,

COMPLAINT

I, Ralph Tan of legal age, Filipino, married and a resident of 95


Mango Drive, Lemery, Laguna, after having been duly sworn in
accordance with law do hereby depose and state:

1. That I am instituting this criminal complaint against accused


Christen Alvarez Cruz of legal age, Filipino, single, and a
resident of 94 Mango Drive, Lemery, Laguna for special
complex crime of kidnapping and murder under R.A. 7659;

2. That I am instituting this criminal complaint against accused


April Rose Celemin Mapa of legal age, Filipino, single, and a
resident of 93 Mango Drive, Lemery, Laguna for special
complex crime of kidnapping with murder under R.A. 7659;

3. That I am instituting this criminal complaint against accused


Cruz and Mapa for robbery with violence against persons
under Article 295 of the Revised Penal Code;

4. That the acts complained of were committed as follows:

a. On 5 December 2005, accused and I were at Playmates Bar


where accused Mapa was waiting for the deceased Isabel
Jasmin Reyes;

b. That when deceased Isabel went to the bathroom, accused


Cruz and Mapa quickly followed;
2018-80004

c. Accused Mapa suddenly poked a knife at deceased Isabel


and ordered the latter to board the car parked outside;

d. I, the driver of the car, witnessed accused Mapa and Cruz


tying Isabel’s hands and feet with a nylon cord and gagging
her mouth;

e. Upon reaching a dark curb, accused Cruz ordered me to


pull the car over;

f. Accused Cruz ordered Isabel to alight the car. Accused


Mapa, then, dragged deceased Isabel by the hair, causing
the latter’s head to hit the pavement. Deceased Isabel was
beaten by the accused;

g. Upon seeing a jeepney approaching, accused Cruz and


Mapa took cover until it was nowhere in sight, dumped
Isabel in the compartment and left;

h. Accused and I drove off a dark grassy area in Barangay


Ayao-Iyao. Accused Cruz and Mapa, again, took deceased
Isabel out of the car, and struck her head with a hammer,
screw driver, and car jack seal several times;

i. Before leaving deceased Isabel’s lifeless body, accused Cruz


and Mapa took the former’s cellphone and wallet.

5. That on the same day, Josefa Contreras and John Dreje knew
that the accused killed deceased Isabel through the confession
of Cruz;

6. That deceased Isabel Jasmine Reyes, deprived of liberty, was


a female;

7. That as a consequence of deprivation of liberty, accused Cruz


and Mapa inflicted hack wounds and traumatic injuries,
causing deceased Isabel to suffer contusions, incisions,
lacerations and fractures;

8. That deceased Isabel died as a consequence of detention and


dehumanizing acts consummated by accused Cruz and Mapa
leaving multiple fatal wounds through the use of hammer, car
jack and screw driver;

9. That before leaving the place of incident, accused Cruz and


Mapa unlawfully took from deceased Isabel’s possession, a
cellphone and a wallet;
2018-80004

10. That accused Cruz and Mapa committed the crime of


kidnapping with murder around 11:30 p.m. in a dark curb and
dark grassy area in Barangay. Ayao-Iyao, which aggravates
the crime;

11. That the means employed in the commission of murder was


attended with treachery under Article 14 of the Revised Penal
Code. Accused Cruz and Mapa tied Isabel’s hands and feet
thus, insuring its execution without risk to themselves.

PRAYER

In view of the gravity and seriousness of the facts presented,


herein petitioner hereby respectfully prays that the accused be
criminally charged with crimes of KIDNAPPING WITH
HOMICIDE and ROBBERY WITH VIOLENCE AGAINST
PERSONS.

IN WITNESS WHEREOF, the petitioner hereunto set his hand


on this 10th day of October in the City of Laguna, Philippines.

RALPH TAN
Plaintiff
2018-80004

VERIFICATION AND CERTIFICATION AGAINST NON-


FORUM SHOPPING, SPLITTING A SINGLE CAUSE OF
ACTION AND MULTIPLICITY OF SUITS

I, Ralph Tan of legal age, Filipino, married and a resident of


95 Mango Drive, Lemery, Laguna on oath, state:

1. That I am the plaintiff in the above-entitled case have


caused this Statement of Claim to be prepared; that I read and
understood its contents which are true and correct of my own personal
knowledge and/or based on true records;

2. That I have not commenced any action or proceeding


involving the same issue or subject matter, and specifically the same
check/s in the Supreme Court, the Court of Appeals or any other
tribunal or agency, particularly before the Office of the City Prosecutor
of Laguna;

3. 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 learn thereafter that
a similar action or proceeding has been filed or is pending before these
courts or tribunal or agency, I undertake to report that fact to the Court
within five (5) days therefrom.

3. That the filing of this case is not in violation of the rule


against splitting a single cause of action or multiplicity of suits.

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


of October 10, 2018.

RALPH TAN
Plaintiff

SUBSCRIBED AND SWORN to before me this 10TH day of


OCTOBER 2018.

_________________
NOTARY PUBLIC