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REPUBLIC OF THE PHILIPPINES Formatted: Font: 14 pt

REGIONAL TRIAL COURT Formatted: Left: 1.4", Top: 1.2"

NATIONAL CAPITAL JUDICIAL REGION


BRANCH 1, MANDALUYONG CITY

MARIMAR DELA CRUZ,


Complainant,
IS No.
____________________________ Formatted: Font: 14 pt

For: GRAVE ORAL DEFAMATION


Under Article 353 in relation to Article
358, Revised Penal Code

-versus-

ROSALINDA RAMOS,
Respondent. Formatted: Space After: 0 pt

x-----------------------x Formatted: Space After: 0 pt


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INFORMATION Formatted: Centered, Space After: 0 pt, Line spacing: 1.5


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The undersigned City Prosecution Attorneyor, upon sworn complaint Formatted: Font: 14 pt
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originally filed by the offended party, accuses ROSALINDA RAMOS of the
crime of GRAVE ORAL DEFAMATION, under Article 353 in relation to
Article 358 of the Revised Penal Code, committed as follows:

That on or about On December 23, 2015 at around one o’clock in Formatted: Space After: 0 pt, Line spacing: 1.5 lines
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the afternoon 1pm, in the City of Mandaluyong, Philippines, Formatted: Font: 14 pt
within the jurisdiction of this court, the said accused, while the
complainant was delivering her speech for all the City Hall
employees who were gathered inside the session hall of the
Mandaluyong City Hall, unlawfully, maliciously and feloniously
shouted in a serious and insulting manner the following:

”HAY GRABE!!! ANG KAPAL NG MUKHA, ANAK NG


BUWAYA! KALA MO KUNG SINONG MAGALING NA
MAYOR, AKALA MO SINONG MATINO AT TAPAT SA
MGA TAO, SUPER CORRUPT NAMAN! AS IN!! TIGNAN
MO ANG ITSURA, CORRUPT NA CORRUPT, BOOO! ALIS
NA! MAGNANAKAW KA!! MAGNANAKAW!”

(“That thick-faced person! Pretending to be a good Mayor,


pretending to be honest to her people, but in truth, she is super
corrupt, As in! Look at her, she looks so corrupt! Booo! Get out,
You thief!!”).

Such statement was uttered more few times and was heard by all Formatted: Font: 14 pt

the City Hall employees inside the session hall, including her ten
year old son, who was there inside the hall.

That the statement was uttered by the respondent publicly and


clearly prompted not by a sense of moral duty but by personal ill-
will, spite and/or malice with the object of destroying the
reputation, discrediting and ridiculing the complainant as an
individual before the bar of public opinion and contempt.
The ill-effects of the malicious utterances are shown by the
negative responses received from the employees of the City Hall,
expressing belief in respondents' baseless allegations as shameful,
heinous and unequivocally barbaric - all to damage and prejudice
of herein complainant.

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CONTRARY TO LAW. Formatted: Font: 14 pt

MANDALUYONG CITY, January 4, 2016. Formatted: Font: 14 pt

ALDEN RICHARD DE
LEON
City Prosecutor

WITNESSES:

1. _________________________________________
2. _________________________________________
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CERTIFICATION Formatted: Space After: 0 pt, Line spacing: 1.5 lines

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This is to certify that as shown by the records the undersigned, an authorized


officer, that there is a reasonable ground to believe that a crime has been
committed and that the accused is probably guilty thereof; that the accused
was informed of the complaint and of the evidence submitted against her and
was given an opportunity to submit controverting evidence.

ALDEN
RICHARD DE LEON
City Prosecutor

SUBSCRIBED AND SWORN to before me this ______________________


in the City of _____________________________, Philippines.

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