REPUBLIC OF THE PHILIPPINESOFFICE OF THE CITY
PROSECUTORMANILA
JOHN RANOLPH C. LOPEZComplainant Versus -I.S. No. _________IVAN
BORJA y BANDIDOFor: Robbery with forceand 3 unnamed suspects( John
Doe 1, upon thingsJohn Doe 2 and John Doe
3)Respondentsx-------------------------------x
COMPLAINT AFFIDAVIT
I, John Randolph C. Lopez, of legal age, Single, Filipino
Citizen and a resident of 1025 Ibarra St., Sampaloc, Manila, under
oath and declare that:
1. Last October 16, 2013, our house located at 1025 Ibarra
Street, Sampaloc, Manila was robbed(by unidentified persons) which
was only discovered at around 11 am in the morning and no suspects
were identified on that day;
2. Last October 29, 2013 newly discovered evidence was procured
through Close Circuit Television Footage(CCTV) that was provided
for by our neighbour Daniel S. Calalang(Disc of the said CCTV is
hereby attached as Annex A);
3. In the CCTV Footage, it was identified that Ivan B. Borja(our
neighbour at Ibarra Street) served as the lookout and criminal
mastermind having provided carpentry service in the past. Thus,
giving the 3 unnamed suspects vital information regarding victims
whereabouts and daily activities;
4. Also in the CCTV Footage, the last person to leave our house
was Shielame Moreno(our kasambahay), after which Ivan Borja gave
the go signal to the other respondent(John Doe 1) to open the by
force in which all the door locks were broken when Shielame Moreno
was about to proceed inside 1049 Ibarra Street(Disc containing the
Photos of the Crime Scene is hereby attached as Annex B);
5. After the door was already open, John Doe 1 left the premises
after which another unnamed suspect via a box type car(John Doe 2)
forced himself in(Police Blotter Report is hereby attached as Annex
C);
6. When John Doe 2 was inside the house, another unidentified
suspect(John Doe 3) was manning the outside premises who also rode
in another box type car;
7. I am executing this sworn statement for the purpose of
charging the respondents with Robbery with force upon things as
provided for under the Revised Penal Code.
City of Manila, Philippines. _________________, 2013
John Randolph C. LopezComplainant
SUBSCRIBED AND SWORN to before me, the undersigned Prosecutor,
this ___________________ in the City of Manila, Philippines.
The undersigned Prosecutor certifies that he personally examined
and understood his complaint-affidavit
