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    2 Complaint Affidavit

    Uploaded by

    Alyssa Mari Reyes
    1) Esther Apolina is filing a cyberlibel complaint against Mary Jane Verano for posting libelous statements about her on Facebook and in the Singers for Christ Facebook group. 2) The post accused Esther of being a thief who stole money from the church, damaging her reputation. 3) Due to the defamatory post, Esther suffered mental anguish and damage to her career and reputation as treasurer of Singers for Christ. She is requesting damages and legal fees from Mary Jane Verano.

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    2 Complaint Affidavit

    Uploaded by

    Alyssa Mari Reyes
    2K views2 pages
    1) Esther Apolina is filing a cyberlibel complaint against Mary Jane Verano for posting libelous statements about her on Facebook and in the Singers for Christ Facebook group. 2) The post accused Esther of being a thief who stole money from the church, damaging her reputation. 3) Due to the defamatory post, Esther suffered mental anguish and damage to her career and reputation as treasurer of Singers for Christ. She is requesting damages and legal fees from Mary Jane Verano.

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    Original Title

    2 COMPLAINT AFFIDAVIT

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    1) Esther Apolina is filing a cyberlibel complaint against Mary Jane Verano for posting libelous statements about her on Facebook and in the Singers for Christ Facebook group. 2) The post accused Esther of being a thief who stole money from the church, damaging her reputation. 3) Due to the defamatory post, Esther suffered mental anguish and damage to her career and reputation as treasurer of Singers for Christ. She is requesting damages and legal fees from Mary Jane Verano.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    2K views2 pages

    2 Complaint Affidavit

    Uploaded by

    Alyssa Mari Reyes
    1) Esther Apolina is filing a cyberlibel complaint against Mary Jane Verano for posting libelous statements about her on Facebook and in the Singers for Christ Facebook group. 2) The post accused Esther of being a thief who stole money from the church, damaging her reputation. 3) Due to the defamatory post, Esther suffered mental anguish and damage to her career and reputation as treasurer of Singers for Christ. She is requesting damages and legal fees from Mary Jane Verano.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    Republic of the Philippines)

    Imus City, Cavite )s.s.


    x------------------------------x

    AFFIDAVIT-COMPLAINT

    I, ESTHER APOLINA, of legal age, single, Filipino and resident of


    Bucandala I, Imus City Cavite, under oath, hereby depose and say, that:

    1. I am a member and the treasurer of Singers for Christ since May 2017.
    I hereby formally charge MARY JANE VERANO for the crime of
    CyberLibel under section 4, (c) paragraph 4 of R.A. 10175 also known
    as the Cybercrime Prevention Act of 2012;

    2. The respondent, Mary Jane Verano, is of legal age, single, Filipino and
    resident of Bucandala II, Imus City Cavite;

    3. Sisters for Christ is a nationwide group here in the Philippines for


    those choir members in different Churches;

    4. On May 20, 2021, respondent posted to malign my person, character


    and honor caused the publication through the Social Media in 1)
    Facebook wall post in my personal account; 2) Post in the
    respondent’s Facebook account; and 3) Post in the Singers for Christ
    Facebook Group, the libelous post states,

    “Itong Church treasurer na to, naturingan na choir member at


    sumisimba linggo linggo naturingang magnanakaw. Mahiya ka naman
    pinagnanakawan mo ang simbahan. Magnanakaw ka Esther. God
    knows Hudas.”

    5. Said statement was posted by respondents contained malicious


    imputations with bad intentions and unjustifiable motives, purposely to
    malign, dishonor, discredit, insult and assassinate my character and
    good reputation to the public as well as to my constituents;

    6. The afore-quoted statement in the Social Media posted by the


    respondent created in the minds of the members of the Sisters for
    Christ that I am a thief and a swindler as a treasurer of the group;

    7. The statement written and posted by respondent has no factual basis,


    is highly speculative and was all false statements made to destroy my
    reputation as a treasurer and renowned to be trustworthy. Respondent
    was motivated by bad faith in the publishing of the said article online to
    defame, embarrass and discredit me to my colleagues, friends, family
    and to the readers and patrons of our Group;

    8. The libelous article having been published through Facebook, a social


    media platform accessible to and is made available to the general
    public was read by the said general public, including my colleagues,
    friends and family among others;
    9. Due to the said malicious public imputations by respondents, I suffered
    and continue to suffer serious anxiety, besmirched reputation, mental
    anguish, sleepless nights, not to mention the damage they have
    caused to my career, reputation and honor among the readers and
    patrons of the Singers for Christ and the general public;

    10. Due to such grossly injustifed malicious and libelous imputations, I


    therefor pray that respondents be made to pay the damages I was
    made to suffer as a result of the online published article in whatever
    amount the Honorable Court deems sufficient and proper together with
    the attorney’s fees and the cost of this suit.

    I hereby execute this affidavit to attest to the truth of the foregoing facts
    and hereby request the investigating prosecutor to file the crime of CyberLibel
    under R.A. 10175 against the herein Respondents.

    IN WITNESS WHEREOF, I have hereunto set my hand this 23th


    day of May 2021 in Imus City Cavite, Philippines

    ESTHER APOLINA
     Affiant 

    SUBSCRIBED AND SWORN TO before me this 23th day of May 2021 at


    Muntinlupa City, Philippines the following affiant MONICA A. MARIANO
    exhibiting to me her Government issued Non-Professional Driver’s License no.
    8293-9173-19 being sufficient and competent evidence of his/her identity in
    pursuant to the 2004 Rules of Notarial Practice.

    Doc. No. ____;


    Page No.____;
    Book No. ____;
    Series of 2021

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