Republic of the Philippines )

Iligan City ) s.s.

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

AFFIDAVIT-COMPLAINT

I, Tyrion Lannister, of legal age, single, Filipino and resident of

Celdran, Iligan City, under oath, hereby depose and say, that:

1. I am a student of the College of Law of Mindanao State University –

Iligan Extension since June 26, 2016. I hereby formally charge the
following persons for the crime of Libel under section 4, (c)
paragraph 4 of R.A. 10175 also known as the Cybercrime
Prevention Act of 2012; Cercie Lannister, Editor-In-Chief, Jaime
Lannister, Columnist of The Iligan Times all of legal age and with
business address at Tibanga, Iligan City, herein referred to as
RESPONDENTS.

2. The Iligan Times is a newspaper of general circulation in the

Province of Lanao del Norte with business address at Tibanga,
Iligan City.

3. On July 5, 2018, respondents by conspiring and confederating to

malign my person, character and honor caused the publication
through the Iligan Times Website (www.IliganTimes.com), under the
Opinion page, an article entitled “Tyrion Lannister: Kawatan.”
written by Columnist Jaime Lannister, published for all to see
through their office in Tibanga, Iligan City on even date.

Attached is the full text of libelous article hereto referred as Annex

"A".

4. Said article published by respondents, without observing the ethical

standards of journalism, contained malicious imputations with bad
intentions and unjustifiable motives, purposely to malign, dishonor,
discredit, insult and assassinate my character and good reputation
to the public as well as to my constituents, an excerpt of which are
hereby quoted:

“Mr. Tyrion Lannister, though a mere college student in the

morning, is known in local circles to be a kawatan at night.”

5. The afore-quoted portion of the online article authored by

respondent Jaime Lannister published by the herein respondents
created in the minds of the readers that I am a thief.

6. The article written and published by respondents has no factual

basis, is highly speculative and was all false statements made to
 destroy my reputation as a law-abiding citizen. Respondents were
motivated by bad faith in the publishing of the said article online to
defame, embarrass me to my colleagues, friends, family and to the
readers and patrons of their publication;

7. The libelous article having been published through the Iligan Times
Website, a website accessible to and is made available to the
general public was read by the said general public, including my
colleagues, friends and family among others;

8. Due to the said malicious public imputations by respondents, I

suffered and continue to suffer serious anxiety, besmirched
reputation, mental anguish, sleepless nights, not to mention the
damage they have caused to my career, reputation and honor
among the readers and patrons of the Southern Leyte Times and
the general public;

9. Due to such grossly unjustified malicious and libelous imputations, I

therefor pray that respondents be made to pay jointly and severally,
the damages I was made to suffer as a result of the online
published article in whatever amount the Honorable Court deems
sufficient and proper together with the attorney’s fees and the cost
of this suit.

I hereby execute this affidavit to attest to the truth of the foregoing facts
and hereby request the investigating prosecutor to file the crime of Libel under
R.A. 10175 against the herein Respondents.

IN WITNESS WHEREOF, I have hereunto set my hand this 7th day of

August 2018 in Iligan City, Philippines

Tyrion Lannister
Affiant

SUBSCRIBED AND SWORN TO before me this 7th day of August

2018 at Iligan City, Philippines the following affiant TYRION LANNISTER
exhibiting to me his Government issued Non-Professional Driver’s License no.
7773-9153-19 being sufficient and competent evidence of his/her identity in
pursuant to the 2004 Rules of Notarial Practice.

Doc. No. ____;

Page No.____;
Book No. ____;
Series of 2018