Republic of the Philippines )

City of Muntinlupa ) S.S.

COMPLAINT AFFIDAVIT

I, PIA W. STOCKINGER, of legal age, Filipino, married and

with postal address at No. 2015 Universe Street, Muntinlupa City,
after having been sworn to in accordance with law hereby depose
and state that:

1. I am filing a case for violation of Republic Act No. 9262

against respondent Marlon Stockinger. He may be served with
summons, subpoena and other processes of the Honorable Office
of the Prosecutor at No. 2015 Universe Street, Muntinlupa City.

2. The facts constituting the said offense are as follows:

3. Respondent and I are legally married. As proof of our

marriage, attached as Annex A is a photocopy of our marriage
certificate.

4. During the course of our marriage, we were blessed with

five (5) children namely:

a. Iris Stockinger, fifteen (15) years of age, attached

as Annex B is a photocopy of her certificate of live birth;

b. Raquel Stockinger, thirteen (13) years of age,

attached as Annex C is a photocopy of her certificate of
live birth;

c. Andrea Stockinger, twelve (12) years of age,

attached as Annex D is a photocopy of her certificate of
live birth;

d. Maxine Stockinger, nine (9) years of age, attached

as Annex E is a photocopy of her certificate of live birth;
and

e. Chalita Stockinger, seven (7) years of age, attached

as Annex F is a photocopy of her certificate of live birth.

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 5. On May 2014, respondent went to Riyadh, Saudi Arabia.
At first, our line of communication is fine. After six (6) months,
however, I noticed that he became irritable and would refuse to
answer my call.

6. On May 16, 2015, respondent informed me that he will be

coming back to the Philippines on June 2015. He, however, did not
mention the exact date of his arrival. Since I wanted to know his
exact date of arrival, I went to IMG and learned that respondent
indeed arrived at the Philippines on May 22, 2015. Despite his
arrival, respondent did not contact us or showed his face to us.

7. I learned that respondent was staying at his mothers

house and is cohabiting with his concubine, Paulina Vega. I also
learned that he and Paulina Vega were married in Hong Kong.

8. Because of these I suffered extreme depression, and

sleepless nights. I was unable to perform my daily routine because
of mental and emotional anguish caused by respondents extra-
marital relationship and his neglect of our family.

9. This is punished under Section 5 (i) in relation to Section

3 (C) of Republic Act No. 9262 or the Anti-Violence Against
Women and Their Children Act of 2004. The said provisions
pertinently provides that:

SEC. 3. Definition of Terms. As

used in this Act, (a) Violence against
women and their children refers to any act
or a series of acts committed by any
person against a woman who is his wife,
former wife, or against a woman with
whom the person has or had a sexual or
dating relationship, or with whom he has a
common child, or against her child whether
legitimate or illegitimate, within or without
the family abode, which result in or is likely
to result in physical, sexual, psychological
harm or suffering, or economic abuse
including threats of such acts, battery,
assault, coercion, harassment or arbitrary
deprivation of liberty. It includes, but is not
limited to, the following acts:

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 xxx xxx
xxx

C. Psychological violence refers to

acts or omissions causing or likely to cause
mental or emotional suffering of the victim
such as but not limited to intimidation,
harassment, stalking, damage to property,
public ridicule or humiliation, repeated
verbal abuse and marital infidelity. It
includes causing or allowing the victim to
witness the physical, sexual or
psychological abuse of a member of the
family to which the victim belongs, or to
witness pornography in any form or to
witness abusive injury to pets or to
unlawful or unwanted deprivation of the
right to custody and/or visitation of
common children.

SEC. 5. Acts of Violence Against

Women and Their Children. The crime of
violence against women and their children
is committed through any of the following
acts:

xxx xxx
xxx

(i) Causing mental or emotional

anguish, public ridicule or humiliation to the
woman or her child, including, but not
limited to, repeated verbal and emotional
abuse, and denial of financial support or
custody of minor children or denial of
access to the womans child/children.

10. For a criminal case of violation of Section 5(i) of Republic

Act No. 9262 to prosper, the following elements according to the
Supreme Court in the case of Ricky Dinamling v. People of the
Philippines, G.R. No. 199522 (June 22, 2015) must concur:

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 From the aforequoted Section 5(i),
in relation to other sections of RA No.
9262, the elements of the crime are
derived as follows:

(1) The offended party is a woman

and/or her child or children;

(2) The woman is either the wife or

former wife of the offender, or is a woman
with whom the offender has or had a
sexual or dating relationship, or is a woman
with whom such offender has a common
child. As for the woman's child or children,
they may be legitimate or illegitimate, or
living within or without the family abode;

(3) The offender causes on the

woman and/or child mental or emotional
anguish; and

(4) The anguish is caused through

acts of public ridicule or humiliation,
repeated verbal and emotional abuse,
denial of financial support or custody of
minor children or access to the children or
similar such acts or omissions.

11. In the case at bar, all the elements are present because;

11.1 I am the legal wife of respondent;

11.2 I suffered mental and emotional anguish; and

11.3 The mental and emotional anguish was caused by

respondents extra-marital affair and his deliberate failure to
contact us and apparent neglect of our family.

12. Aside from Psychological violence, we, my children and I

likewise suffered from Economic Abuse for failure of respondent to
give financial support while he was at Riyadh, Saudi Arabia. There
were occasions that we were forced to beg food from neighbors as
we have no money.

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 13. RA 9262 defines economic abuse as:

D. Economic abuse refers to acts

that make or attempt to make a woman
financially dependent which includes, but is
not limited to the following:

1. withdrawal of financial support or

preventing the victim from engaging in any
legitimate profession, occupation, business
or activity, except in cases wherein the
other spouse/partner objects on valid,
serious and moral grounds as defined in
Article 73 of the Family Code;

2. deprivation or threat of deprivation

of financial resources and the right to the
use and enjoyment of the conjugal,
community or property owned in common;

14. Respondent is also guilty of Physical Abuse since during

our cohabitation, respondent assaulted and inflicted violence
against my person numerous times especially when he is drunk.

15. I have executed this affidavit to attest to the truth of the

foregoing and to charge respondent MARLON STOCKINGER with
the crime of VIOLATION OF REPUBLIC ACT NO. 9262.

IN WITNESS WHEREOF, I have hereunto set my hand this

April 8, 2017 in Muntinlupa City.

PIA W. STOCKINGER

SUBSCRIBED AND SWORN TO before me this April 8, 2017

in Muntinlupa City. I hereby ceritfy that I have personally
examined the affiant and that I am satisfied that she has read the
foregoing affidavit, that she fully understood the same and that
the contents thereof are true and correct based on her personal
knowledge.

PUBLIC PROSECUTOR

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 ANNEX A

MARRIAGE CERTIFICATE

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 ANNEX B

CERTIFICATE OF LIVE BIRTH

IRIS STOCKINGER

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 ANNEX C

CERTIFICATE OF LIVE BIRTH

RAQUEL STOCKINGER

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 ANNEX D

CERTIFICATE OF LIVE BIRTH

ANDREA STOCKINGER

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 ANNEX E

CERTIFICATE OF LIVE BIRTH

MAXINE STOCKINGER

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 ANNEX F

CERTIFICATE OF LIVE BIRTH

CHALITA STOCKINGER

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