1 Complaint-Affidavit PDF

Republic of the Philippines )
Makati City, Metro Manila ) S.S.
COMPLAINT-AFFIDAVIT
I, SPO2 PEDRO SANTOS, of legal age and a resident of 2600 Bagong Diwa
Street, Makati City, and a member of the Anti-Drug Task Group of the Makati
City Police Office and, after having been duly sworn to in accordance with
law, do hereby depose and state that:
1. After conducting a weeklong surveillance against the suspected drug

pusher within our Area of Responsibility, our Group came to know that a
certain Juan dela Cruz is engaged in the illegal sale of shabu;
2. Around 12:30 in the afternoon of July 31, 2018, PSUPT. BENJAMIN

ALEJANDRO (“PSUPT. Alejandro”), Chief of Police of Makati City
Police Station, conducted pre-operation conference in preparation for a
buy-bust operation against the suspect. PO3 MIGUEL CORVITE is
designated as poseur-buyer. I and PO3 BEN ZAMORA are appointed as
back-up.
3. PSUPT. ALEJANDRO handed to me two (2) pieces of One Hundred

Peso Bill with serial numbers Z679111 and SJ441842 as the buy-bust
money.
4. Thereafter, our team proceeded to Felipe Street, Poblacion, Makati City,

the place where suspect is known to operate.
5. We, the back-up team, followed secretly the poseur-buyer and positioned
ourselves strategically in order to observe the actual transaction between
the suspect and the poseur-buyer;
6. At about 1:30 in the afternoon of the same date, we saw our poseur-buyer
having conversation with the suspect. The suspect handed something to
our poseur-buyer that led him to raise up his right hand. This gesture is the
pre-arranged signal to rush up to the scene and arrest the suspect;
7. We immediately approached the suspect to arrest him. I was able to recover

the marked money bearing serial numbers Z679111 and SJ441842 used in
the entrapment and two (2) pieces of small heat-sealed transparent plastic
sachets containing white crystalline substance suspected to be shabu.
Another plastic sachet was recovered from the direct possession, custody
and control of JUAN DELA CRUZ;
8. Upon arrest, I apprised the suspect of his constitutional rights;
ANNEX A Page 1 of 3
9. The two (2) pieces of small heat-sealed transparent plastic sachet
containing white crystalline substance suspected to be shabu were marked
as “PS-1”, “PS-2”, and “PS-3” respectively;
10.The marked money consisting of two (2) One Hundred Peso bills were also
marked as “PS-4” and “PS-5”;
11.Immediately after seizure and confiscation, the operating troop, having

initial custody and control of the drugs and marked money, made a
physical inventory and took photographs of the same, in the presence of
the accused JUAN DELA CRUZ, a representative from the newspaper
Tempo, Rowena F. Damasen, a representative of the Department of Justice,
Atty. Roxanne V. Paliparan, and Barangay Captain Alex S. Xavier. The
same persons signed the copies of the inventory and were given copies
thereof;
12.At about 3:30 in the afternoon of the same date, the shabu and marked
money, together with the arrested suspect and the operating troop, were
taken to the Makati City Police Station 1, aboard the police car with plate
number ACY-592;
13. At about 4:00 PM of the same date, the team and the suspect arrived at the
police station. The suspect, as well as the shabu and marked money, was
turned over by the undersigned to the Investigator, PO2 JUSTIN R.
AZURIN (“PO2 Azurin”), to undergo police booking procedure. This
procedure included the taking of mug shots and fingerprints and the
recording of the marked money and the three (3) pieces of small heat-
sealed transparent plastic sachet containing white crystalline substance
suspected to be shabu in the police booking sheet;
14.At about 4:30 in the afternoon of the same date, the suspect was detained
at the Makati City Police Station 1 to undergo inquest. The shabu was
turned over by PO2 AZURIN to SPO4 PAUL REYES who brought the
same to the Southern Police District Crime Laboratory Office, Old
Pamamdisan, San Antonio Village, Makati City;
15.The two (2) pieces of small heat-sealed transparent plastic sachet

containing white crystalline substance suspected to be shabu were received
by PO3 CESAR CASTRO, RMT, the Forensic Analyst at the Crime
Laboratory Office at 5:30 in the evening of the same date;
16.The findings reveal that the result of the qualitative examination conducted
on the above-stated specimens (“A” thru “C”) gave positive result to the
test for the presence of Methamphetamine Hydrochloride (shabu), a
dangerous drug;
Page 2 of 3
17.I am executing this sworn statement for the purpose of charging the
respondent with having violated Section 5 and 11, Article II of R.A No.
9165.
IN WITNESS WHEREOF, I hereunto affixed my signature this 5th day of

August 2018, in the City of Makati, Philippines.
PEDRO SANTOS
Complainant
SUBSCRIBED AND SWORN to before me this 5th day of August 2018 at

Makati City, Metro Manila, Philippines, the affiant exhibiting his CTC. No.
77776543 issued at the City of Makati on January 8, 2018 and his Driver’s
License No. N00-77776543 issued by the Land Transportation Office on July
16, 2015.
MERCEDES G. BENZ
City Prosecutor
CERTIFICATION
The undersigned prosecutor certifies that she personally examined the affiant
and that he is satisfied that she voluntarily executed and understood her
complaint-affidavit
MERCEDES G. BENZ
City Prosecutor
Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2018.
Page 3 of 3

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Republic of the Philippines )

Makati City, Metro Manila ) S.S.

1. After conducting a weeklong surveillance against the suspected drug

2. Around 12:30 in the afternoon of July 31, 2018, PSUPT. BENJAMIN

3. PSUPT. ALEJANDRO handed to me two (2) pieces of One Hundred

4. Thereafter, our team proceeded to Felipe Street, Poblacion, Makati City,

7. We immediately approached the suspect to arrest him. I was able to recover

8. Upon arrest, I apprised the suspect of his constitutional rights;

11.Immediately after seizure and confiscation, the operating troop, having

15.The two (2) pieces of small heat-sealed transparent plastic sachet

IN WITNESS WHEREOF, I hereunto affixed my signature this 5th day of

SUBSCRIBED AND SWORN to before me this 5th day of August 2018 at

Doc. No. _____;

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