REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
ANTIPOLO CITY, RIZAL

CHIANG SANTOS
Complainant, I.S. No. 004789
vs. For: Kidnapping and
Serious Illegal
Detention

JAY NILAGA
Respondent.

X————————————————-X

COMPLAINT-AFFIDAVIT

I, CHIANG SANTOS, 20 years of age, single, a resident of 123 Sibat Street, Barangay
Pinagkuhanan, Pasig City, after having been sworn to in accordance with law, do
hereby depose and state:

1. That on October 30, 2018 at around 5:30 in the afternoon while I was with my
sister Marigold Santos (Marigold Santos’s Affidavit is herein attached as Annex
“A”) and waiting near the Jose Rizal University main gate for a jeepney en route
home to Pasig, a white Honda Civic with three male inside, including the driver,
suddenly stopped beside us and simultaneously one of them, which I know to be
JAY NILAGA, a Bachelor of Arts Major in Economics student of JRU, and my
aggressive suitor, grabbed me by the hand, and forced me inside their vehicle. I
tried to resist the grip of Jay Nilaga, but I was not able to free my self. When Nilaga
has successfully forced me in the vehicle, they hurriedly sped away;

2. That while inside the vehicle, I was shouting at Nilaga asking where will they take
me, he answered that he wanted to persuade me to marry him, so we will stay
together in a house somewhere in Rizal. I kept on shouting and resisting that Nilaga
covered my mouth with a piece of cloth and tightly tied it around my mouth so
that I will not be able to speak. He even tied both of my hands with a rope. It was
so tight that when I tried to free my self, I eventually wounded my self;
3. That after about two (2) or three (3) hours drive from the time Nilaga forced me in
the vehicle, we stopped by a three (2) storey house. Nilaga then grabbed me out of
the vehicle, forcibly led me inside the said house and locked me up in one of the
rooms in the ground floor;

4. That Nilaga told me that if I try to escape, he will kill me. He further said that the
only way to get out is to for me to accept his proposal to marry him;

5. That five days have passed and I’m still locked in the room. My mouth was kept
covered so that I will not be able to shout for help from the neighbouring houses.
Also, my hands and feet were kept tied, to prevent me from moving around;

6. That on the night of the sixth day of being kidnapped, that is November 5, 2018 a
man, who I identified as the driver of the Honda Civic when I was forcibly taken
by Nilaga, stealthily entered the room where I was left locked, and quickly freed
my hands and feet from the tight ropes, and told me that Nilaga left the house for
a while to buy some food. He wants me to quickly escape from the said house, and
ask for help from the neighbors;

7. That the said driver broke the glass window so that I will be able to get out of the
room without using the front door, in fear that Nilaga might come and prevent the
escape. I then jumped out the window, and cross over a 6 feet wall dividing the
house where I was detained, and the neighboring house with an owner named
Jericho Korales ( Jericho Korales’ Affidavit is herein attached as Annex “A”) and
said neighbor helped me to go home;

8. That my family and I sought legal consultation, and we were informed that the
respondent should be placed on trial for committing the crime of Kidnapping with
Serious Illegal detention as provided for under Article 267 of the Revised Penal
Code of the Philippines as amended by R.A 7659.

9. That accordingly, the crime of Kidnapping and Serious Illegal Detention has the
following elements:

a) The offender is a private individual;

b) He kidnaps or detains another or in any other manner deprives the latter of his
liberty;
c) In the commission of the offense, any of the following circumstances is present:
(a) the kidnapping or detention lasts for more than 3 days; or (b) it is committed
by simulating public authority; or (c) any serious physical injuries are inflicted
upon the person kidnapped or detained or threats to kill him are made; or (d) the
person kidnapped or detained is a minor, female, or a public officer.
10. That Pursuant to the aforementioned elements, Respondent is a private individual
by the fact the he is not a holder of any public office nor is he an agent of a person
in authority.

11. The the respondent held me hostage against my will and was deprived of my liberty
under the threat of being killed by the former.

12. That the the kidnapping and detention lasts for more than three (3) days and the
respondent threatened to kill me;

13. That I am executing this sworn statement for the purpose of charging the
respondent for committing a crime of Kidnapping and Serious Illegal Detention.

IN WITNESS HEREOF, I have hereunto affixed my signature this November

20, 2018, Pasig City, Philippines.

CHIANG SANTOS
Complainant/Affiant

SUBSCRIBED AND SWORN to before me, the undersigned prosecutor, this

th
25 day of November 2018, in the City of Antipolo, Rizal, Philippines.

The undersigned Prosecutor certifies that she personally examined the affiant
and that she is satisfied that she voluntarily executed and understood her complaint-
affidavit.

RHOWEE D. BUERGO
Assistant City Prosecutor
 ANNEX “A”

Republic of the Philippines)

Mandaluyong City )S.S.

AFFIDAVIT

I, MARIGOLD SANTOS, Filipino, of legal age, single and a resident of 123 Sibat
Street, Barangay Pinagkuhanan, Pasig City Philippines, after being sworn in
accordance with law, depose and state:

1. That I am the sister of CHIANG SANTOS;

2. That on October 30, 2018 at around 5:30 in the afternoon while I was with my
sister CHIANG SANTOS and waiting near the Jose Rizal University main gate for
a jeepney en route home to Pasig, a white Honda Civic with three male inside,
including the driver, suddenly stopped beside us and simultaneously one of them,
which I know to be JAY NILAGA, a Bachelor of Arts Major in Economics student
of JRU, and Chiang’s aggressive suitor, grabbed Chiang by the hand, and forced
her inside their vehicle. And when Nilaga has successfully forced her in the
vehicle, they hurriedly sped away;

3. That I immediately informed the school security guards of what happened, and
thereafter, the school administrators called our parents, and we reported the
incident to the nearby local police (Attached herewith as Annex “A” is a copy of
the missing person report) ;

4. That five days has already passed and Chiang was still not home, and no where to
be found;

5. That at night of November 5, 2018, six days from the time she was forcibly taken
by respondent Nilaga, Chiang was able to come home, and she was accompanied
by a certain Jericho Korales, the person who drived her home, and away from the
house where she was detained for six days;

6. That I am executing this Affidavit to attest to the truth of the foregoing and to
support and corroborate the statements contained in the Complaint-Affidavit
 executed by Chiang Santos for the purpose of filing a case for “KIDNAPPING
AND SERIOUS ILLEGAL DETENTION" against JAY NILAGA.

MARIGOLD SANTOS
Affiant

CERTIFICATION

th
SUBSCRIBED AND SWORN to before me in the City of Mandaluyong this 25 day
of November, 2018. I hereby certify that I have personally examined the above named
affiant and that I am satisfied that the foregoing statements were given by her
voluntarily and of his own free will.

ASSISTANT CITY PROSECUTOR

MANDALUYONG CITY
 Marigold Chiang’s Affidavit: ANNEX “A”

MISSING PERSON’S REPORT

Mandaluyong Police Department

Mandaluyong City

MISSING PERSON

Name: Alias/Street Relatives:

Chiang Santos Name/Nickname Jerry and Nina Santos
: (parents), Marigold
Chiang Santos (sister),

Nationality: Height: Weight: Hair: Eyes: Sex:

Filipino 5’4" 125 lbs Brown Brown Female

Hat: Jacket/Coat: Shirt: Pants: Skirt/Dress Shoes:

Yellow : black
blouse, Navy shoes
school blue
uniform school
skirt

Age: DOB: Social Security Scars/Marks/Tattoos:

20 August 10, #: none
1998 XXX-XX-XXXX

Overall Health: Last Seen Health Condition:

Good In good health

Last Seen By: Last Seen Location: Last Seen Last Seen
Marigold Santos, sister Jose Rizal University man Date: Time:
gate, along Shaw Boulevard Tuesday, Approx.
10/30/20 5:30
18 p.m.

Address: Residence Phone:

123 Sibat Street, Barangay Pinagkuhanan, 600-77-56
Pasig City Business Phone: N/A

Occupation: Employer/School: N/A Employer Address:

Student Jose Rizal University N/A
MISSING PERSON REPORTED BY

Name: Relation: Address: Residence Phone:

Marigold Sister 123 Sibat Street, 600-77-56
Santos Barangay Business Phone: N/A
Pinagkuhanan, Pasig
City

REPORTING PERSON’S NARRATIVE (Brief narrative of the facts surrounding the missing person
report.)
The missing person was reported by the victim’s sister, Marigold
Santos. That on October 30, 2018 at around 3 o’clock in the
afternoon while she was with her sister CHIANG SANTOS and
waiting near the Jose Rizal University main gate for a jeepney
en route home to Pasig, a white Honda Civic with three male
inside, including the driver, suddenly stopped beside them and
simultaneously one of them, which I she knew to be JAY NILAGA, a
Bachelor of Arts Major in Economics student of JRU, and Chiang’s
aggressive suitor, grabbed Chiang by the hand, and forced her
inside their vehicle. And when Nilaga has successfully forced
her in the vehicle, they hurriedly sped away.
Janie was described as a a female with black hair that falls
down to her shoulders. She has fair skin with brown eyes. She is
approximately five-foot and four inches in height and has brown
eyes. Chiang Santos was last seen wearing a JRU female uniform,
that is a with yellow blouse, and a navy blue knee length skirt,
and black shoes.
Chiang does not appear to have any scars, tattoos, or noticeable
birth marks.

DATE October 30,

REPORTING OFFICER Cardo Dumalisay 2018
REPORTED

SUPERVISING Richard Polisidad 8213 6/22/10

OFFICER Signature Unit Number Date
 ANNEX “B”

Republic of the Philippines)

Mandaluyong City )S.S.

AFFIDAVIT

I, Jericho Korales, Filipino, of legal age, single and a resident of 56 Kaligtasan Street,
Barangay Salvacion, Antipolo City, Rizal Philippines, after being sworn in accordance
with law, depose and state:

1. That on October 30, 2018, at around 8 o’clock in the evening, I saw a white Honda
Civic stopped in front of a neigboring house. About four (4) persons went in the
house. One of them is a woman who seems like fighting one of the three guys
accompanying her;

2. That at first, I did not suspect anything wrong because it is common for me to see
that there are groups of people, male or female, entering said house, once or twice
a week, but I don’t really know who the owner is;

3. That in the silence of the night of November 5, 2018, at around 9pm, I heard a
sound similar to a broken class. The sound came from the direction of the house
close to mine. And said house is the one where I saw a white Honda Civic stopped,
and where four (4) persons went inside, six days ago;
4. That I went out the house to observe what was happening, and to my surprise, a
lady jumped over the wall, and fell on my yard;

5. That the lady looked so frightened, run towards me and asked me to help her go
home;

6. That the said lady, who introduced herself as Chiang Santos, told me that she lives
in Pasig, and that she was taken by a certain Jay Nilaga six days ago, and detained
her. She further said that someone helped her escape from the house, and broke the
window of the room where she was locked, so that she can get out without using
the from door;

7. That I quickly started my car, and drive her home;

8. That upon reaching the house address given by Chiang, she hurriedly alighted the
car, run toward the house, knocked at the door and shouted for the people inside to
open it.There, her parents and sister Marigold, finally were reunited with Chiang;

9. That I am executing this Affidavit to attest to the truth of the foregoing and to
support and corroborate the statements contained in the Complaint-Affidavit
executed by Chiang Santos for the purpose of filing a case for “KIDNAPPING
AND SERIOUS ILLEGAL DETENTION" against JAY NILAGA.

JERICHO KORALES
Affiant

CERTIFICATION

th
SUBSCRIBED AND SWORN to before me in the City of Mandaluyong this 25 day
of November, 2018. I hereby certify that I have personally examined the above named
affiant and that I am satisfied that the foregoing statements were given by her
voluntarily and of his own free will.

ASSISTANT CITY PROSECUTOR

MANDALUYONG CITY