REPUBLIC OF THE PHILIPPINES)Province of Compostela Valley . . .)S.S.Municipality of Nabunturan. . . . . . )X - - - - - - - - - - - - - - - - - - - - - - - X

AFFIDAVIT - COMPLAINT

I, Juvilyn Beraña Telompros, of legal age, Filipino and a resident of E. Aguinaldo St., Purok 5, Nabunturan, Compostela Valley Province, Philippines, after having been sworn to in accordance with law, depose and say that:

1. Sometime January 22, 1997, I got married with Nelson H.

Telompros, hereto attached as Annex “A” a copy of the

Certificate of Marriage;

2. Our marital union bore three children namely Switzal Maye B.

Telompros, Kate Justeine B. Telompros and Keith Stephen B.

Telompros, hereto attached as Annex “B”, “C” and “D copies of

Certificates of Live Births of my three children;

3. Unfortunately our marital union turned sour. Sometime January

2008, I consulted a neighbour lawyer named Atty. Carlo D. Ancla

and I confided to him my marital woes and predicament. I asked

him whether it is possible for me to file a case against my

husband to severe my marital bond with him. Atty. Ancla told me

that it is very easy for me to obtain annulment papers provided I

will pay him Php 200,000.000. I asked for discount and it was

reduced to Php180, 000.00.

4. Thus, sometime last week of February 2008, I entered a Legal

Services Agreement with Atty. Carlo D. Ancla and I made partial

payment in the amount of Ninety Thousand (Php 90,000.00)

Philippine Pesos, hereto attached as Annex “E” a copy of the

Legal Services Agreement”. Soon thereafter, I paid the balance

amounting Ninety Thousand (Php 90,000.00) Philippine Pesos

thus completing my monetary obligation to him.

5. True enough, sometime third week of March 2008, Atty. Ancla

handed to me a Judgment on Civil Case No. 07-1653 entitled

Declaration of Absolute Nullity of Marriage, dated March 17, 2008

signed by Acting Presiding Judge Hon. Cader P. Indar, Al Haj,

hereto attached as annex “F” a copy of Judgment.

6. Atty. Ancla also handed to me a Certificate of Finality signed by

Acting Clerk of Court Umaima L. Silongan, hereto attached as

Annex “G” a copy of the Certificate of Finality.

7. Atty. Ancla also handed to me a Certification from the Office of

the City Civil Registrar of Cotabato, hereto attached as Annex

“H” a copy of the said Certification;

8. However, upon receipt of the copy of judgment, I noticed on the

bottom portion of the decision that there was a typographical

error since instead of my name and the name of my ex-husband,

different names were instead written. I told Atty. Ancla about this

and he promised to facilitate the necessary correction of the

typographical error

9. I also asked him whether it was “ok” for me to marry another

man and he told me that it was perfectly alright stressing that

my previous marriage has already been voided;

10. Thus, on October 23, 2008, thinking that my previous marriage

has already been severed legally and as per advice by Atty.

Ancla, I entered into a marriage union with my fiancé, William V.

Pizarro, hereto attached as Annex “I” a copy of the Certificate of

Marriage;

11. Sometime September 30, 2008, I worked out my visa papers for

my travel to the United States to join my new husband and I was

asked to secure an NSO certification of my status as a married

individual. To my surprise, a feedback for, dated October 8,

2008, reveals that “different names of contracting parties “was”

indicated in the dispositive portion of the court decision”, hereto

attached as Annex “J1”, “J2” a copy of the NSO Feedback form.

12. I confronted Atty. Ancla about it and he promised to personally

facilitate the necessary corrections. But after five (5) long years

since the discovery of the discrepancy, his promise to facilitate

the necessary corrections, remains broken, to my utter dismay,

anger and frustration.

13. Recently, I texted Atty. Ancla that I intend to file a case against

him to answer for all the lies, deceits and machinations that he

employed against me. Atty. Ancla texted back, hereto attached

as Annex “K” a copy of the transcript of some of his text

messages. Some of the text messages are reprinted hereunder

as follows:

(0917-308-3206 <Atty. Ancla>) 04-01-2013 (Jan. 4, 2013): “Dili man na mao move juv gnathreat na man ko nimo illegal tanan nato gihimo tanan ta madamay (highlighted for emphasis);

(0917-308-3206 <Atty. Ancla>) 07-01-2013 (Jan. 7, 2013): “Gd am! Juv, tgai ko hangtod karn bulana kay personalon nako adto cotabato problma imo papel magkuyog ni atty javines kay iya kontak otherwise we will return what is due to you..ayaw lang mi i-threat thru txt kay we r all guilty in illegal or unlawful course of action.

(0917-308-3206 <Atty. Ancla>) 15-03-2013: (March. 15, 2013 “Yes juv.moadto mi sa imo next wk Tuesday..gkuha na mga papeles hulat lng gamay juv

(0917-308-3206 <Atty. Ancla>) 15-03-2013 (March 15, 2013: “Signature na lang gprocure..bsta Tuesday makigkita mi nimo..gamay na lang paabot juv.

14. I believe that the promises of Atty. Ancla will never happen as the

judge who penned the decision has long been dismissed by the

Supreme Court. I came to know this when by chance I happen to

browse an internet news story from Sunstar Davao dated May 15,

2012 where it was reported that a Cotabato judge, by the name

of Cader P. Indar, Al Haj , the judge who penned my annulment

judgment, was disbarred for illegally dissolving marriages, hereto

attached as Annex “L” a printout of said internet news story;

15. All the lies, deception, deceits and machinations employed by

Atty. Ancla has caused me untold misery, sleepless nights,

broken heart, anger and utter dismay and frustration. I even

begged Atty. Ancla to return the sum of One Hundred Eighty

Thousand (Php 180,000.00) Pesos if only to appease my angry

heart, but up to this date, he failed to return even a single

centavo;

16. I am executing this affidavit complaint for the purpose of

attesting to the truth of the foregoing declarations and for the

purpose of filing a disbarment case against Atty. Carlo D. Ancla

for VIOLATION OF THE LAWYER’S OATH, FOR GROSS

MISCONDUCT AND DISHONESTY and for such other violations

of other laws against his person;

IN WITNESS WHEREOF, I have hereunto affixed my hand this ___________________, at Nabunturan, Compostela Valley Province, Philippines.

Juvilyn Beraña Telompros Affiant

SUBSCRIBED AND SWORN to before me this ______________, at Nabunturan, Compostela Valley Province Philippines affiant at Nabunturan, Compostela Valley Province, Philippines.