REPUBLIC OF THE PHILIPPINES

BAGUIO CITY
PEOPLE OF THE PHILIPPINES,
Plaintiff,

CRIMINAL COMPLAINT
for

-versusACTS OF LASCIVIOUSNESS
LARRY INDAMMOG,
Accused.
x-----------------------x
COMPLAINT-AFFIDAVIT
I, REVEILLE DOMINGO, 23 years of age, male, single, Filipino, a
resident of Sumulong Street, Baguio City, after having been sworn to in
accordance with law, do hereby accuse LARRY INDAMMOG of the crime
of ACTS OF LASCIVIOUSNESS committed as follows:
1. At around 10:00 PM of September 01, 2015, I and my friends
went to Bohemian Cafe along Assumption Road for a nightcap.
2. After about an hour, the accused and his friends, who had been
drinking since 8:00 PM at the said cafe, approached our table,
introduced themselves, and joined us.
3. The night went on until everyone was drunk. When my friends
expressed their willingness to leave as they were feeling drunk
and tired, I readily agreed to go with them.
4. However, the accused offered to bring me home. As I did not want
to come off as rude, I accepted his offer and stayed with him.
Both of our friends left thereafter.
5. It was about 2:00 AM of September 02, 2015 when we left the
said cafe, feeling really disoriented from the intoxication.
6. We walked through Assumption Road and Upper General Luna,
heading for my apartment in Sumulong Street, when he stopped in
front of a dark area of the Rex Hall Residences.
7. He started to kiss me and touch my private parts. When he
reached for my sexual organ and found out that I am just a
crossdresser, he became violent.

8. He pushed me, which knocked me hard to the ground. That was

when I came to my senses.
9. Fearing for my life, I shouted for help. The security guard of the
Rex Hall Residences heard my pleas. He hurriedly came to pacify
the accused, but the latter couldnt be calmed down, so the guard
called for law enforcers.
10. Upon their arrival, I narrated what happened, but they simply sent
the us on different directions, inferring that it was just a
misunderstanding of two inebriated individuals.
11. The foregoing facts and circumstances are true. I freely depose
them without any force or intimidation done against me.
12. To attest to the truthfulness and veracity of the antecedents, I,
Reveille Domingo, complainant, affix my signature below.

Reveille Domingo
Complainant
_____________________________________________________________
SUBSCRIBED and SWORN to before me, a notary public in the City
of Baguio, this 3rd day of September 2015, the affiant personally appeared,
exhibiting his employment ID issued by Convergys Corporation as
competent evidence of identity.

Atty. Ricardo Navarro

Notary Public
Notarial Commission No. 20508, valid until December 30, 2016
Roll No. 265481
PTR No. 184562
IBP No. 479321
MCLE Compliance No. 510902, August 08, 2015
Doc. No. 20
Page No. 25
Book No. 2
Series of 2015

Liberty Building, Navarro Law Office

Camp Joh Hay, Baguio City
Tel. No. (074) 222-9090
Email Address: ricardonavarrolaw@gmail.com
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