Republic of the Philippines

Department of Justice
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
City of Davao

KATH RYN
Complainant,
IS No. _____________
- versus - For: Murder

BERNARD DO
Accused.
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COMPLAINT-AFFIDAVIT

I, KATH RYN, of legal age, single, Filipino and a resident of Buhangin,

Davao City, after having been duly sworn to in accordance with law, do hereby
depose and state that:

1. The defendant, BERNARD DO, is our family bodyguard residing at

Panacan, Davao City;

2. At around 6:00 in the evening of March 12, 2020, after dinner, defendant
arrived at our house;

3. Defendant saw my husband, LAO RYN, in the kitchen cooking for our
dinner, the kitchen being at least 5 feet from the dining table where my
kids and I are seated;

4. Without provocation, the defendant pulled his gun from his waist and
proceeded to shoot my husband in the head;

5. Upon seeing what our bodyguard did, I rushed to my husband’s aid and
called for rescue from 911 through a phone call;

6. The bodyguard left immediately without even saying anything;

 7. Upon reaching the hospital, my husband was declared by the attending
physician as dead on arrival because of severe blood loss from the
gunshot wound;

8. After attending to my husband, I reported the said incident to the nearest

police station. A true and faithful machine copy of the police report is
hereby attached here as “Annex A”;
9. I am therefore executing this Complaint-Affidavit against our bodyguard,
BERNARD DO, who may be served with subpoena and other processes
of this Honorable Office at his residence at Panacan, Davao City.
10.
PRAYER

WHEREFORE, it is respectfully prayed that defendant, BERNARD DO, be

charged with Murder, to pay moral damages and costs of suit. Such other reliefs as
the court may deem proper are also prayed for.

IN WITNESS WHEREOF, I have hereunto set my hand this 13 th day of

March 2020 at Davao City, Philippines.

(SGD) KATH RYN

Complainant-Affiant

SUBSCRIBED AND SWORN to before me, in the City of Davao, this 13 th

day of March, 2020. I hereby certify that I have personally examined the above-
named affiant and that I am satisfied that the foregoing statements were given by
him voluntarily and of his own free will.

(SGD) MARA NGAL

Administering Assistant City Prosecutor