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I, MALAN DIDAW, of legal age, single, Filipino citizen, with
assistance of counsel, and a resident of 123 Tomorrowland, Plur St.,
Malate, Manila, Philippines, do hereby state under oath that:
1. I am a DJ (disc jockey) and Music Producer based in Manila,
Philippines having just accepted a contract for three (3) years under
Its Lit Man Productions on April 23, 2016.
2. I accuse and hereby charge MS. TAK LESA, residing at 5
Badroll, Ultra St., Makati, of violating Article 358 of the Revised Penal
Code (Slander and Oral Defamation), committed against me when
she publicly, maliciously and deliberately uttered defamatory remarks
against me.
3. The acts complained were committed as follows:
a. On the evening of May 3, 2016, I had a DJ gig at The
Palasyo Bar in Taguig City. While I was busy spinning
records, Tak Lesa went to the stage and grabbed the
microphone from MC Palo and started uttering Sarap
maging DJ, right? Is it as good as fucking around with all
of your bosses? Hands to you, girl! Youre really willing to
do anything just to be in the business. You arent even
that good! Now thats what you call a fame whore!
Everyone, lets give it up for our bad bitch DJ in town!!!.
b. Other than the fiasco she made, I was informed by my
colleagues in the music industry that there were rumors
circulating about me being the mistress of the President of
the Its Lit Man Productions, Mr. Music Islife. The said
rumors were purportedly started by Tak Lesa when Its Lit
Man Productions did not renewed her contract in order to
make room for me in the production company.
4. Ms. Tak Lesas remarks, falsely saying that I have illicit
sexual relationships with several married men uttered in public are
clearly insulting and defamatory as they malign me and attribute to
me a criminal act, nature and predisposition. There is, moreover, no
doubt that Ms. Tak Lesas malicious spreading of rumors against me
was deliberate as her explanation and clarification a few utterances

thereafter would show. Ms Tak Lesas remarks are also very serious
as they cast aspersions on my reputation, line of business, character
and very person before my peers, fans, and fellow artists.
5. Mr. Tak Lesas remarks have injured my name, reputation
and character before my colleagues and fans. By reason of the
foregoing, I suffered sleepless nights, wounded feelings, moral
and social embarrassment which Ms. Tak Lesa should
compensate by way of damages which is the natural, proximate
and necessary result of the malicious utterances in the amount
of not less than Five Hundred Thousand Pesos (PhP 500,000.00).
6. While my name, reputation and character are incapable of
pecuniary estimation as these are the result of a lifetimes effort to
build a name, reputation and character that my future descendants
can be proud to bear, Ms. Tak Lesa cannot be allowed to simply go
scot-free without bearing the consequences of her acts. For this
reason, I am also holding Ms. Tak Lesa liable civilly for defaming
me in the amount of One Million Pesos (P1,000,000.00) in
nominal damages and Five Hundred Thousand Pesos
(P500,000.00) in exemplary damages.
IN WITNESS WHEREOF, I have hereunto affix my signature
this 14th day of May 2016 in Manila, Philippines.
SUBSCRIBED AND SWORN to before me this 14 th day of May
2016 in the City of Manila. I hereby certify that I have personally
examined the above-named affiant and that I am satisfied that the
foregoing statements were given to her voluntarily and of his own free
Investigating Prosecutor
Azanith Ann B. Payad
11583371 G04

Republic of the Philippines

Branch 34
Manila City
Criminal Case No: 12345
For: Slander and Oral
-versusTAK LESA,
The undersigned Assistant City Prosecutor accuses TAK LESA, a
resident of 5 Badroll, Ultra St., Makati City, Philippines of the crime of
Slander and Oral Defamation, defined and penalized under Article
358, of the Revised Penal Code, as amended, committed as follows:
On May 3, 2016 on or about 11:30 in the evening at The
Palasyo Bar in Taguig City, in the presence of more or less a
hundred of person, accused TAK LESA, with the use of a
microphone and within hearing distance of everyone present,
unlawfully, maliciously and feloniously uttered in a serious and
insulting manner at the undersigned complainant the following
words: Sarap maging DJ, right? Is it as good as fucking
around with all of your bosses? Hands to you, girl! Youre
really willing to do anything just to be in the business. You
arent even that good! Now thats what you call a fame whore!
Everyone, lets give it up for our bad bitch DJ in town!!!, which
utterances are serious and insulting in nature, tending to cause
dishonor, discredit and contempt of complainant and causing
her extreme mental anguish, wound (sic) feelings, besmirched
reputation and serious anxiety for which she is entitled to
recover moral and exemplary damages in an amount to be
determined by the honorable court.
Manila, Philippines, May 14, 2016
Associate City Prosecutor

I hereby certify that a preliminary investigation has been conducted in

this case, that on the basis of the sworn statement and other
evidence submitted before, there is reasonable ground to believe that
the offense charged
Subscribed and sworn to before me this day of 14 May 2016, in the
City of Manila, Philippines.
Azanith Ann B. Payad
11583371 G04