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Criminal Case Case by GUAIMALIA

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Republic of the Philippines


Department of Justice
CITY PROSECUTION OFFICE
________________

GUIAMALIA KENENGKO
Complainant ,
-versusBEDO SINUMPAY
Respondent.

Docket No: _________


For: Violation of R.A 9262
Violence Against Women
and their Children

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

COMPLAINT AFFIDAVIT
I, GUIAMALIA KENENGKO, of legal age, Filipino,
married to the respondent, and a resident of #3 Notre Dame
Avenue, Cotabato City, after having been duly sworn in
accordance with law, hereby depose and state:
1. I am and the same person who is the complainant in
the instant case;
2. I know the person of BEDO, being my husband and
who is currently in active service in the XXXXXXXXX
Bacolod City, where he may be served with Office
summons, notices and processes;
3. That we were married on February 10, 2006 at
Regional Trial Court Branch 13 before the sala of
Hon.

Judge

XXXXXXX.

The

copy

of

marriage

certificate is hereto attached as Annex A;


4. That out of lawful marriage, we begot two(2)
children. The first child is XXXXXXXXXXXXXX who
was born on June 2, 2006 and our second child
XXXXXXXXXXXXXXX was born on February 25, 2009.
Our daughter Gianna is Nine (9) years old while our
son Corvin is six (6) years old. Copies of their

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Certificates of Live Birth are hereto attached and


marked as Annexes B and C respectively;
5. That in the beginning of our marriage, we lived
harmoniously as husband and wife and parents to
our children until later part that the my husband had
shown

and

displayed

irrational

behaviour

not

expected from a mature and a responsible husband


and father to our children;
6. That while he was in Armed Forces of the Philippines
assigned at Camp Bonifacio, Taguig City, he used to
regularly go home and visit us;
7. That when he transferred his service to the PNP
starting on March 2011, he did not go home already
and spare sometime to visit us, worst is he did not
even send support to us;
8. That I have sent letter addressed to the former PNP
Chief PDG Alan Purisima requesting for sub-allotment
of allowances intended for our two (2) children, copy
of which is hereto attached as Annex D;
9. We both ended up in entering into a Memorandum of
Agreement which executed on September 16, 2013
at Manila, Philippines with a stipulation that my
husband shall give a total amount of Five Thousand
(P5,000.00)

Pesos

per

month

divided

as

Two

Thousand Five Hundred (P 2,500,00) for every child


and additional Two Thousand (P 2,000.00) Pesos for
childrens education, copy of the said Memorandum
of Agreement is hereto attached and marked as
Annex E;
10.

Despite this agreement, my husband continuously

failed to comply to his undertakings because he


failed to give the amount agreed upon as a support;

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11. I was constrained to seek legal assistance from


the Public Attorneys Office XXXXXXXXXXXXXX
which immediately assisted me by preparing and
sending a Demand Letter requesting that the amount
Seven Thousand (P 7,000.00) Pesos shall be directly
deducted from the net pay of my husband and the
amount be sent to me in a form of a check. The
same request is not yet acted upon until this very
moment, copy of the said letter is hereto attached
and marked as Annex F;
12. That his act of continuous failure to give support
since the year 2011 tantamount to economic abuse
which is defined under R.A 9262 or Violence Against
Women and their Children as:
"Economic abuse" refers to acts that make or attempt to
make a woman financially dependent which includes, but is not limited
to the following:
1.

Withdrawal of financial support or preventing the victim


from engaging in any legitimate profession, occupation,
business or activity, except in cases wherein the other
spouse/partner objects on valid, serious and moral
grounds as defined in Article 73 of the Family Code;
xxxxxxxxx.

13.

I have been hearing rumors that my husband

has been romantically engaged and cohabiting with


another woman in Bacolod. Because of this, I did an
effort to confirm the said rumors. Until I found out,
to my surprised, that he is already married with
another woman in the name of Mary Faith B. Dizon
on August 24, 2011, copy of their Certificate of
Marriage is hereto attached as Annex G;

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14. That although the respondent is legally married to


the

complainant

and

the

marriage

is

legally

subsisting, he contracted subsequent marriage which


is a violation of Article 349 of the Revised Penal
Code,pertinent

provision

of

the

law

is

quoted

hereunder, to wit:
Article 349. The penalty of prision mayor shall be imposed
upon any person who shall contract a second or subsequent marriage before
the former marriage has been legally dissolved, or before the absent spouse
has been declared presumptively dead by means of a judgment rendered in
the proper proceedings.
15. That this act of marrying another woman and
cohabiting with several women caused substantial
and emotional distress to me and our children which
is violation of paragraph (h) Section 5 of R.A 9262;
16. Moreover, we suffer and continuously suffering of
mental and emotional anguish, public ridicule and
humiliation when he had contracted subsequent
marriage and denial of financial support to our
children which is a violation of paragraph (i) Section
5 of R.A 9262;
17. That this act of my husband is a gross misconduct
which tarnishes the reputation of Philippine National
Police;
18. That because of this criminal act and gross
misconduct, my husband deserves to suffer from
consequences of his act and be discharged from
service so as not to allow a person like him to tarnish
the image of the entire PNP and shall serve as an

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example that similar acts cannot be done by other


members of the PNP;
19. That this criminal complaint is without prejudice of
filing a separate criminal complaint for bigamy; and
20. That I cause the preparation of this affidavit to
support my complaint.
IN WITNESS WHEREOF, I have hereunto set my hand
this

____________________

at

____________,

Philippines.

GUIAMALIA KENENGKO
Complainant-Affiant

SUBSCRIBED AND SWORN to before me this _______


day of September 2015.
_____________________
City Prosecutor