Crim Complaint Sample

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Republic of the Philippines

REGIONAL TRIAL COURT


Branch 5
Baguio City

PEOPLE OF THE PHILIPPINES,


Plaintiff,

- versus - CRIMINAL CASE N0. 12321


FORCIBLE ABDUCTION
WITH RAPE
WANTIK A. AWO
Session Road,
Baguio City.
Accused.
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COMPLAINT

The undersigned accuses Wantik A. Awo of the crime of Forcible

Abduction with Rape, committed as follows:

That on or about December 30, 2016, in Baguio City, Philippines,

the said accused, with lewd designs, did then and there willfully,

unlawfully and feloniously abduct, take and carry away the

undersigned complainant while coming out of a toilet in her home at

Magsaysay Ave., Baguio City, by means of force, violence and

intimidation to wit: by pulling her and forcing her to walk, at the same

time pointing at her a gun and threatening to kill her should she cry

out for help, succeeded in bringing her to ride in his car, where they

rode going to the house of the accuseds Uncle Sam where the said

accused, by means of force, violence and intimidation, succeeded in

having sexual intercourse with her against her will.

Contrary to law.
LAMBANA MARIKIT
Complainant

SUBSCRIBED AND SWORN TO before me this 23 rd day of January,


2017, in Baguio City, Philippines, by Lambana Marikit, the complainant.

MARIA N. MAKILING
Assistant
Prosecutor

I hereby certify that an ex-parte investigation in this case has


been conducted by me in accordance with law; that there is reasonable
ground to believe that the offense charged has been committed; and
that the accused is probably guilty thereof.

Baguio City, January 23, 2017.

MARIA N.
MAKILING
Assistant Prosecutor

WITNESSES:

1. Lambana Marikit, Magsaysay Ave., Baguio City.

2. Nathan Marikit, Magsaysay Ave., Baguio City.

BAIL RECOMMENDED: THREE HUNDRED THOUSAND PESOS


(P300,000.00) ONLY.

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