REPUBLIC OF THE PHILIPPINES)

CITY OF MAKATI ) S.S.

COMPLAINT-AFFIDAVIT

I, XXXXXXXXXXXXX, of legal age, single and residing at XXXXXXXXX,

Makati City, after having been sworn to in accordance with law, hereby deposes and state
that:

1. On July 26, 2016, YYYYYYYYYY and ZZZZZZZZZZZZZZZ

(hereinafter referred to as the respondents), both of legal age and also residing at
____________________, Makati City, executed Affidavits subscribed before Assistant
City Prosecutor Carlos M. Flores of the City Prosecution Office;

2. In the said Affidavits, respondent YYYYYYYYYYY categorically

declared that on April 5, 2016 about 5:30 p.m., she saw me spray a chemical mixture on
the dog and the car of TTTTTTTTT, whereas respondent ZZZZZZZZZ categorically
declared that as a result of the spraying of chemical on his car (Plate No. ________), it
suffered damage in the amount of Thirty Thousand (P30,000.00). Attached herewith and
marked as Annexes “A” and “B” are their respective Affidavits;

3. The said declarations of respondents are utter falsities as on the said date
and time I was on duty as Staff Nurse at the VRPMC located at 163 EDSA, Mandaluyong
City. Attached herewith and marked as Annex “C” is a photocopy of the Daily Time
Record from VRPMC;

4. Likewise, there is no truth to the claim of respondent that his vehicle

suffered damages as I was able to take pictures of the said vehicle after I learned of the
affidavits executed by the respondents and it was very apparent from the said pictures
that the said vehicle never sustained any damages. Attached herewith and marked as
Annex “D” is a photocopy of the pictures of the subject vehicle;

5. The falsities of their claim notwithstanding, respondents categorically

made such declarations in order to support the filing of complaint for malicious mischief
and violation of R.A. 8485 (Animal Welfare Act) against me so as to persecute me.
Fortunately, the investigating prosecutor in her Resolution dismissed the said complaint.
Attached herewith and marked as Annex “E” to “E-1” is a photocopy of the resolution;

6. It is evident from the foregoing that respondents made a willful and

deliberate assertion of falsehood in an affidavit made under oath, before a competent
officer, such affidavit being required by law in order to initiate a criminal complaint
before the Prosecution Office;

7. It is significant to note that respondents have initiated, and were similarly

been the subject, of numerous complaints, against and by me, as well as other persons.
Thus, motive on part of the respondents to commit the acts imputed evidently exists.
Attached herewith and marked as Annexes “F” and “G” are some of the complaints;
 8. IN WITNESS WHEREOF, I hereby sign this Complaint-Affidavit in
order to charge the respondents with the crime of Perjury, as well as for any other crime
they may have committed by reason of the foregoing.

XXXXXXXXXXXXXXX
(Affiant)

SUBSCRIBED and SWORN to before me in the City of Makati. I HEREBY

CERTIFY that I have personally examined the affiant and I am satisfied that he
voluntarily executed and fully understood the contents of his affidavit.

ASST. CITY PROSECUTOR

Makati City