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Republic of the Philippines)

Maasin City, So. Leyte )s.s.


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

AFFIDAVIT-COMPLAINT

I, BENDEVER C. GERONA, of legal age, single, Filipino and


resident of Buac Gamay, Sogod, So. Leyte , under oath, hereby depose and
say, that:

1. I am a student of the College of Law of The College of Maasin,


Maasin City, So. Leyte since June 26,2017. I hereby formally
charge the following persons for the crime of Libel under
section 4, (c) paragraph 4 of R.A. 10175 also known as the
Cybercrime Prevention Act of 2012;

1.a. ANTONIO REYES, Editor-In-Chief, LLOYD


BANTUG, Columnist of The Southern Leyte Times all of
legal age and with business address at Mambajao, Maasin
City, So. Leyte, herein referred to as RESPONDENTS.

2. The Southern Leyte Times is a newspaper of general circulation


in the Province of Southern Leyte with business address at at
Mambajao, Maasin City, So. Leyte.

3. On July 5, 2o17, respondents by conspiring and confederating


to malign my person, character and honor caused the
publication through the Southern Leyte Times Website
(www.SouthernLeyteTimes.com), under the Opinion page, an
article entitled Bendever Gerona: Kawatan ug Lubi written by
Columnist Lloyd Bantug, published for all to see through their
office in Mambajao, Maasin City on even date.

Attached is the full text of libelous article hereto referred as


Annex "A".

4. Said article published by respondents, without observing the


ethical standards of journalism, 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, an excerpt of which are hereby quoted:

Mr. Gerona, though a mere college student in the morning,


is known in local circles to be a kawatan ug lubi at night.

5. The afore-quoted portion of the online article authored by


respondent Lloyd Bantug published by the herein respondents
created in the minds of the readers that I am a thief.

6. The article written and published by respondents has no factual


basis, is highly speculative and was all false statements made to
destroy my reputation as a law abiding citizen. Respondents
were motivated by bad faith in the publishing of the said article
online to defame, embarrass me to my colleagues, friends,
family and to the readers and patrons of their publication;

7. The libelous article having been published through the


Southern Leyte Times Website, a website 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;

8. 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 Southern Leyte Times and
the general public;

9. Due to such grossly unjustified malicious and libelous


imputations, I therefor pray that respondents be made to pay
jointly and severally, 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
attorneys 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
Libel under R.A. 10175 against the herein Respondents.

IN WITNESS WHEREOF, I have hereunto set my hand this


7th day of August 2017 in Maasin City, Southern Leyte, Philippines

Affiant

SUBSCRIBED AND SWORN TO before me this 7th day of August


2017 at Maasin City, Southern Leyte, Philippines the following affiant
BENDEVER C. GERONA exhibiting to me her Government issued Non-
Professional Drivers License no. 7773-9153-19 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 2017