Republic of the Philippines

NATIONAL POLICE COMMISSION

Regional Office VI
Big City
-o0o-

PRETTY LADY.,
Complainant, Admin Case No.:
________________

For: Grave Misconduct

under Sec. 2 (C) (3) (r),
-versus- Grave Dishonesty under
Sec. 2 (C) (4) (b), Conduct
Unbecoming of a Police
Officer under Sec. 2 (C) (5)
and Oppression under Sec.
PSINSP GWAPO, 2 (C) (7), all of NAPOLCOM
PO2 TARONG and Memorandum Circular No.
PO1 NAUGHTY, 2016-002
Respondents.
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -x

COMPLAINT

COMES NOW, Complainant PRETTY LADY., through

the undersigned counsel, and unto this Honorable Office,
most respectfully states that:

THE PARTIES

1. Complainant PRETTY LADY, is of legal age, married,

Filipino, a resident of Brgy. FM, Big City Philippines and
is currently detained at the Custodial Facility of Big City
Police Station, Big City, Philippines, where he may be
served with notices and other processes of this
Honorable Office at his residential address.

2. Respondent PSINSP GWAPO is the Team Leader of

Regional Drugs Enforcement Unit 6 (RDEU 6) of
Philippine National Police Regional Office VI, having his
office address at Camp Crime, Big City, Philippines,
where he may be served with summons and other
processes of this Honorable Office.

3. Respondent PO2 TARONG is a member of Regional

Drugs Enforcement Unit 6 (RDEU 6) of Philippine

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 National Police Regional Office VI, also having his office
address at Camp Crime, Big City, Philippines, where he
may be served with summons and other processes of
this Honorable Court.

4. Respondent PO1 NAUGHTY is also a member of

Regional Drugs Enforcement Unit 6 (RDEU 6) of
Philippine National Police Regional Office VI, having his
office address at Camp Crime, Big City, Philippines,
where he may be also served with summons and other
processes of this Honorable Court.

THE FACTS

The following are the facts and circumstances that can

be gleaned in the Affidavit of Pretty Lady., the Police
Certification dated February 14, 2018 where complainant
was the informant, the affidavits of complainant's witnesses,
namely: Spouses Hot Love and Cold Love and the Police
Certification also dated February 14, 2018 where said
Spouses Love were the informants and the complaint
together with its respective annexes filed by the respondents
before the Office of the City Prosecutor of Big City where
respective copies of the same are hereto attached and
marked as Annexes "A", "B", "C", "D", "E", "F" and "G",
respectively.

5. At around six (6) o’clock in the morning of January 1,

2018, complainant rode a passenger tricycle then
driven by Sweet Lover from his house at Barangay FM,
Big City going to a small cockfarm owned by his in-laws,
namely, Spouses Spouses Hot Love and Cold Love, at
Brgy. AM, Big City.

6. While complainant who was on board the tricycle was

passing by the Big City Public Cemetery at Brgy. CM, Big
City, a gray van coming from the opposite direction
crossed their way causing the tricycle to stop.

7. Thereafter, a group of some unidentified persons in

civilian clothes alighted from the van and approached
herein complainant.

8. While complainant was being approached by said

unidentified persons, another white Limousine arrived
at the opposite direction and situated itself at the back
of the tricycle.

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9. The group of unidentified persons then introduced
themselves as police officers, told the complainant that
they have a warrant for her arrest and handcuffed said
complainant but without showing a warrant of arrest to
said complainant.

10. Thereafter, complainant was brought by said

police officers to Brgy. OA, Big City in front of Big City
Cemetery which is about three (3) kilometers away from
where complainant was illegally arrested and
handcuffed.

11. It was only then that complainant was able to

identify Respondent Gwapo from the group as he had
already seen said respondent on television, not to
mention the fact that Respondent Gwapo was once a
Chief of Police of Big City.

12. Meanwhile, while they were at Brgy. OA,

complainant was asked by Respondent Gwapo if
complainant had a firearm with him which complainant
vehemently denied.

13. For reasons only known to him, Respondent Gwapo

then forcefully shoved complainant in the chest.

14. Thereafter, complainant was brought by the police

officers outside the cockfarm in Brgy. AM, Big City,
where he remained inside one of the vans guarded by
some police officers from the outside.

15. Around ten (10) minutes lapsed thereafter,

complainant was brought inside the cockfarm and saw
that the suspected dangerous drugs and other items
were already placed at the table.

16. It was only this time that the police operatives

declared that an alleged buy-bust operation was
conducted and that complainant was, in fact, the
subject.

17. Thereafter, complainant was brought to Big City

Police Station where she has been detained until the
present.

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18. On January 11, 2018, a criminal case was filed
against the complainant before the Office of the City
Prosecutor of Big City for the alleged violation of
Sections 5 and 11 of Republic Act No. 9165 of the
Comprehensive Dangerous Drugs Act of 2002.

19. It was only then that complainant was able to

actually identify Respondents Tarong and Naughty as
some of the unidentified police officers who effected
the arrest of the complainant.

CAUSE(S) OF ACTION

20. Complainant was not committing any illegal act

during the time of her arrest as can be seen in the
proofs submitted before this Honorable Office.

21. As a matter of fact, complainant was illegally

arrested the moment he was handcuffed in front of Big
City Public Cemetery in Brgy. OA, Big City and
apparently discontented for this initial act, respondents
went on and planted evidence against said
complainant, resulting in the deprivation of his liberty
despite the fact that he had not committed any crime
when he was apprehended.

22. This is a clear case of Planting of Evidence as

defined and penalized by under Section 29 of Republic
Act No. 9165.

23. As it is a clear and intentional violation of law

carrying with it the imposable penalty of more than six
(6) months and one (1) day of imprisonment,
Respondents should be properly held liable for Grave
Misconduct as described under NAPOLCOM
Memorandum Circular No. 2016-02.

24. For willfully and intentionally making untruthful

statements in their affidavits by making it appear that
there was an alleged buy-bust operation that took place
causing the arrest of herein complainant when in truth
and in fact, no such operation took place, Respondents
Tarong and Naughty should be equally held liable for
Grave Dishonesty under the above-mentioned Circular.

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 25. For their wanton acts shown in effecting the
unlawful arrest of herein complainant and by laying
unnecessary force upon his person, Respondents
displayed excessive use of authority and disgrace to
themselves as police officers and as such, they should
be held liable for Conduct Unbecoming of a Police
Officer and Oppression as likewise separately defined
and penalized under said Circular.

PRAYER

WHEREFORE, premises considered, it is most

respectfully prayed upon this Honorable Office after finding
merit to this present complaint that decision be rendered in
favor of the complainant Pretty Lady and finding
Respondents Gwapo, Tarong and Naughty GUILTY as charged
of the following administrative offenses defined and
penalized under NAPOLCOM Memorandum Circular No. 2016-
002, to wit:

1. Grave Misconduct under Sec. 2 (C) (3) (r);

2. Grave Dishonesty under Sec. 2 (C) (4) (b);
3. Conduct Unbecoming of a Police Officer under Sec. 2 (C)
(5); and,
4. Oppression under Sec. 2 (C) (7).

Other reliefs just and equitable under the premises are

likewise prayed for.

RESPECTFULLY SUBMITTED.

Done in the City of Big, Philippines, this 15 th day of

February 2018.

ASTIG LAW OFFICES

Counsel for Complainant Pretty Lady.
Suite 16, Second Floor, Body Building
Jump St., Big City
Tel. Nos. 8-7000
astigrunsinmyblood@gmail.com

by:

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 ATTY. DAW PIHO
IBP NO. 1057665, 01/03/18, Big City
PTR NO. 4988730, 01/09/18, Big City
Roll of Attorneys No. 66666
MCLE Compliance No. V-0000000, 4/15/18

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