REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE PROSECUTOR
BAGUIO CITY

AFFIDAVIT –COMPLAINT

I, Marl Boro, of legal age, married, Filipino citizen and a resident at #69 Upper
Malvar, Trancoville, Baguio City, Philippines, after having been sworn to in accordance
with law, do hereby depose and say:

1. That I am instituting this CRIMINAL COMPLAINT against Phillip Morris, of

legal age, married,Filipino citizen, resident at #70 Upper Malvar, Trancoville,
Baguio City, Philippines for ORAL DEFAMATION as defined and penalized
under Article 353 in relation to Article 358 of the Revised Penal Code of the
Philippines;

2. That the acts complained of were committed as follows:

a. Yesterday at around 5pm, I was heading home at # 69 Upper Malvar,

Trancoville, Baguio City when I met my neighbor, Phillip Morris who, without
saying nothing, to my surprise, he intentionally shouted (”PUTA KA!, INAGAW
MO ASAWA KO, PALAGI KAYONG NAGLALANDIAN SA ILALIM NG
BAHAY NAMIN”), You are a whore!You stole my wife!,You are always flirting
with each other under our house. It was uttered a lot of times and was heard by
my neighbours and my son who is Five years old.

b. That the statement was uttered by Phillip Morrison September 06, 2011
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 my reputation and
discrediting and ridiculing me as an individual before the bar of public opinion
and contempt;

c. The ill-effects of the malicious utterances are shown by the negative responses
that I have-received from my neighbors, especially my son, expressing belief in
respondents' baseless allegations as shameful, heinous and unequivocally barbaric
- all to my damage and prejudice;

3. That by reason of the foregoing, I suffered sleepless nights, wounded feelings, moral
and social embarrassment which Phillip Morris should compensate by way of
damages which is the natural, proximate and necessary result of the malicious
publication in the amount of not less than One Hundred Thousand Pesos (Ph.
100,000.00) which shall be donated for various programs for the welfare of the
children of Barangay Brookside;

4. That I am executing this affidavit to attest to the truth of the foregoing averments and
for the purpose of criminally prosecuting said Phillip Morris for ORAL
DEFAMATION/SLANDER as there are grave utterances as determined by the City
Prosecution Office in the preliminary investigation.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 6th day of

September, 2018 at Baguio City, Philippines.
 Marl Boro
Affiant
CTC No.:01-55454543- 1
Issued on: February 17, 2011
Issued at: Baguio, City

JURAT and CERTIFICATION

SUBSCRIBED and SWORN to before me this 6th day September, 2018 at Baguio City,
Philippines. I hereby certify that I have personally examined the affiant and that I am
satisfied that he read and understood the contents of his affidavit-complaint and that he
voluntarily executed the same.

AMELING, PHILIP RAY B.

City Prosecutor