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REPUBLIC OF THE PHILIPPINES

Department of Justice
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
QUEZON CITY

JOSEFA V. CONTRERAS
Complainant,

-versus- I. S. No. 11E-03792

For: Murder

CHRISTEN CRUZ
RALPH TAN
APRIL ROSE MAPA
Respondents,

COMPLAINT-AFFIDAVIT

I, JOSEFA V. CONTRERAS, of legal age, Filipino, and may be

served with summons and other notices at Brgy. Balagtas, Laguna, after
having been sworn in accordance with law, hereby dispose that:

1. I am the sister of Isabel Jasmin Reyes y Vallescas. My sister

2. I am executing this Complaint-Affidavit to charge Christen Cruz,

Ralph Tan, and April Rose Mapa, for the QUALIFIED
MURDER, defined and punished under the Revised Penal Code. The
offense was committed under the circumstances below.

3. This Complaint-Affidavit is supplementary to the complaint that has

already been filed by the police authorities before this Honorable
Office.

4. On February 10, 2006, Sergeant Binay invited my mother, Teresita

Reyes, to come to the police station to identify the body found in
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Lemery, Laguna on December 6, 2005. Teresita identified that the

dead body found was Isabela.

5. Dr. Rosalinda De Castro conducted an autopsy on my sister. Based on

the autopsy, Isabel’s cause of death was due to hack wounds and left
traumatic injuries in the head. She also suffered from contusions
around the lips circumoral, right and left wrists, right leg lower third
anterior, and incisions on the right preuricular area before the ear and
also on the left, incised wound on the left side of the neck extending
to midchest, laceration around the forehead and left chin, four hack
wounds on the back of the ear and fractures on the skull. Bluntly
stated, Isabel suffered from multiple fatal wounds in the hands of her
murderers.

6. John Derick Dreje, one of the witnesses, asked Cruz what happened.
After a little prodding, Cruz and Mapa admitted that they killed
Isabel.

7. At some time before, I asked why they were looking for Manolo, Cruz
and Mapa answered that they killed Isabel. I realized that the stains on
Cruz and Mapa’s hands and clothes were blood stains. Cruz, in front
of Mapa and Tan, then recounted the horrifying story of the details of
the murder of Isabel. As told, at the night Isabel asked for permission
to go out, she was met by her friend Mapa at a bar. When Isabel went
to the restroom, Mapa and Cruz quickly followed Isabel. Mapa
suddenly poked a knife at Isabel and ordered the latter to board the car
parked outside driven by Tan. While seated at the back seat of the car,
Mapa and Cruz tied Isabel’s hands and feet with a nylon cord, gagged
her mouth and drove off. When they reached a dark curb, Cruz
ordered Tan to pull over. Cruz then commanded Isabel to alight from
the car. At the side road, Mapa dragged Isabel’s hair, causing Isabel’s
head to hit the pavement. Mapa and Cruz then started to beat Isabel.
While hitting Isabel, a passenger jeepney suddenly drove by, forcing
Cruz and Mapa to duck and take cover. As soon as the jeepney was
nowhere in sight, they dumped Isabel in the compartment and drove
off to a dark grassy area in Barangay Ayao-Iyao, Lemery, Laguna.
Unsatisfied, Mapa and Cruz struck Isabel’s head with a hammer,
screw driver, and car jack several times. The two insatiably took turns
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in beating Isabel. One used a car jack while the other, a hammer or a
screw driver. Still discontented, like a rabid predator, they beat the
already weak Isabel on the head, over and over again. Thereafter, they
took her cellphone, wallet and left her lifeless body. The whole time
Cruz was narrating the horrifying incident, Mapa and Tan did not say
a single word.

8. Isabel and I were supposed to celebrate the 25th anniversary of our

parents with them. Her death is unthinkable. Her sudden violent death
has deeply traumatized me, and caused me great emotional grief, and
distress. I have to suffer great mental and emotional anguish upon my
sister’s horrifying death. We do not deserve this.

9. Given the extraordinary circumstances of my sister’s violent death,

caused by murder of the three respondents, I intend to claim in the
same criminal case any and all possible civil liabilities as provided by
Art. 100 of the Revised Penal Code: Every person criminally liable for
a felony is also civilly liable, arising from the criminal act, including
but not limited to, actual, moral, and exemplary damages. I also intend
to claim attorney’s fees.

10. Accordingly, I am executing this Complaint-Affidavit for the purpose

of attesting to the truth of the foregoing statements and to charge
respondents with Qualified Murder.

IN WITNESS HEREOF, I hereunto set my hand this 10th day of

October 2006 in Laguna.

JOSEFA V. CONTERAS
Affiant