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Elgie Saramosing Jugar filed a complaint against Romell Medina Lucero for violating the Violence Against Women and Their Children Act. They have two children together but are not married. Lucero refuses to provide financial support for their children, despite having a well-paying job overseas, which constitutes economic violence under the law. Jugar struggles to support and care for the children on her own through a small online business. She seeks to file charges against Lucero to compel him to fulfill his parental duty of supporting their children.
Elgie Saramosing Jugar filed a complaint against Romell Medina Lucero for violating the Violence Against Women and Their Children Act. They have two children together but are not married. Lucero refuses to provide financial support for their children, despite having a well-paying job overseas, which constitutes economic violence under the law. Jugar struggles to support and care for the children on her own through a small online business. She seeks to file charges against Lucero to compel him to fulfill his parental duty of supporting their children.
Elgie Saramosing Jugar filed a complaint against Romell Medina Lucero for violating the Violence Against Women and Their Children Act. They have two children together but are not married. Lucero refuses to provide financial support for their children, despite having a well-paying job overseas, which constitutes economic violence under the law. Jugar struggles to support and care for the children on her own through a small online business. She seeks to file charges against Lucero to compel him to fulfill his parental duty of supporting their children.
DEPARTMENT OF JUSTICE OFFICE OF THE CITY PROSECUTOR Mandaluyong City
ELGIE SARAMOSING JUGAR,
Complainant, I.S. No. _____________ - Versus - For: Violation Against Women and Children Act (R.A. 9262)
ROMELL MEDINA LUCERO,
Respondent.
X * * * * * * * X
COMLAINT – AFFIDAVIT
I, ELGIE SARAMOSING JUGAR, of legal age, Filipino
Citizen, Single, and presently residing at No. 0047 F. Bonifaio Street, Kabayanan, San Juan, Metro Manila, after having been duly sworn to in accordance with law, do hereby depose and state:
1. Respondent, ROMELL MEDINA LUCERO, is of legal
age, Filipino Citizen, Single and presently residing at Blk. 1B, Lot 9, Marvie Hills, San Mateo, Rizal;
2. Respondent is an Overseas Filipino Worker as
Seaman (Seabased) as evidenced by an Overseas Filipino Worker (OFW) Information issued by the Philippine Overseas Employment Administration hereto attached as Annex “A” and made integral part of this Complaint- Affidavit;
3. That sometime on the year 2008, I and
respondent got acquainted to each other through cell phone communication. Said acquaintance was initiated by respondent as he obtained my cell phone number from my cousin. Constant communication between us ensued, which grew into courtship. On the same year, 2008, we personally met, were romantically involved over a period of time and on a continuing basis and became live in partners;
4. That out of our union without the benefit of
marriage or under a common law relationship, we were blessed with two (2) children. Our first child, KATE DANIEL JUGAR LUCERO, was born on 2
August 27, 2009 when I and respondent were still living
with his Mother at San Mateo, Rizal. Our second child, PRINCESS DENNISSE ANN JUGAR LUCERO, was born December 17, 2014. By year 2015, we resided at Marikina City.Copy of our said first child’s Certificate of Live Birth is hereto attached as Annex “B” while that of our second Child is hereto attached as Annex “C”, both of which are made indispensable parts of this Complaint-Affidavit;
5. Sometime on September 2015, respondent left
for overseas employment but was sent back home by his overseas employer as respondent alleged that he contracted malaria, however, respondent did not stayed with me and our children at Marikina City when he came back on the allegation that we might be infected by his malaria and at this point, he rarely stays with us and only provide us with measly One Thousand Pesos (P1, 000.00) a week;
6. Sometime on February 2016, respondent again
left for overseas employment / job. At that time, certain young woman sen me a photograph of her and respondent closely together in bed. I confronted respondent about the matter while he was abroad but he constantly made denials. I discovered later from trusted information that respondent already arrived in the Philippines from overseas employment and as of July 2016, he is living with the aforementioned woman together as husband and wife at San Mateo, Rizal;
7. That at present, I and our children are living at
my Sister’s address at San Juan City, Metro Manila, since we were constrained by respondent’s Mother to leave our house – residence in Marikina City as according to her, the same will be sold and thereafter, its owner informed me that respondent was not paying the purchase price of the house;
8. From July 15, 2016 and continuously up to
present time, respondent deliberately and completely refuse and fail to provide our two minor children with financial and economic support despite my repeated pleas for him to provide such support and, despite the fact of receipt by him of my Letter of Demand for Support hereto appended as Annex “D”, respondent remain heedless an adamant as he persistently refuses and fails to provide our minor children with financial or economic support; 3
9. That respondent’s deliberate, continuous and
complete refusal and failure to give support to our children occurred at the time I and the children were residing in Mandaluyong City, and such refusal and failure to provide support continues up to present time;
10. That, because of this, I was forced to put up my
own on-line shop in selling bags but is not that profitable to meet and sustain our children’s financial, economic and school needs causing me to be reliant for little financial help extended by my Brother and Sister;
11. That the afore-narrated actuations of the
respondent without any justifiable reasons in depriving our two (2) minor children of financial or economic support and/or monthy financial or economic support constitutes economic violence under Section 5, paragraph (2) of R.A. 9262 known as Violence Against Women and Children Act that is, - Depriving or threatening to deprive the woman or her children of financial support legally due her or her family, or deliberately providing the woman's children insufficient financial support;
12. That respondent’s actuations likewise constitutes
economic violence under Section 5, paragraph (3) of R.A. 9262, that is - Depriving or threatening to deprive the woman or her child of a legal right;
13. That as may be culled from the Overseas Filipino
Worker (OFW) Information issued by the Philippine Overseas Employment Administration (Annex “A” hereof), respondent is earning rich, abounding and handsome salary of One Thousand One Hundred Seventy Five United States Dollars (US$ 1, 175. 00) per month exclusive of his other overseas employment benefits, thus, there is no reason that he should deprived our two (2) children the monthly support or economic or financial report;
14. That respondent’s acts has caused so much
emotional and financial distress not only to me but to our two (2) children, specially our first Child who may already have trauma or stigma, since without my encouragement and insistence, he would not want to go to school as he is being branded of having no Father;
15. That I alone tend to and take care our minor
children thus, I could not take full time job or employment, except the on-line shop in selling bags I mentioned to help 4
a little somehow in our daily needs or sustenance though
it is not very profitable;
16. That I execute this Complaint-Affidavit to attest
to the truth of the foregoing facts and for the purpose of filing a Complaint for Violation of Republic Act 9262 known as the Violence Against Women and Their Children Act against respondent ROMELL MEDINA LUCERO with the Office of the City Prosecutor of Mandaluyong City.
IN WITNESS WHEREOF, I have hereunto affixed my
signature this ______ day of October 2016 at Mandaluyong City, Metro Manila, Philippines.
ELGIE SARAMOSING JUGAR
Affiant
SUBSCRIBED AND SWORN to before me this ______ day
of October 2016 and I hereby Certify that I have examined the Affiant and I am fully satisfied that she voluntarily executed her Complaint-Affidavit and that she understood the same.