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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
Mandaluyong City

ELGIE SARAMOSING JUGAR,

Complainant,
I.S. No. _____________
- Versus -
For: Violation Against Women
and Children Act
(R.A. 9262)

ROMELL MEDINA LUCERO,

Respondent.

X * * * * * * * X

COMLAINT – AFFIDAVIT

I, ELGIE SARAMOSING JUGAR, of legal age, Filipino

Citizen, Single, and presently residing at No. 0047 F.
Bonifaio Street, Kabayanan, San Juan, Metro Manila, after
having been duly sworn to in accordance with law, do
hereby depose and state:

1. Respondent, ROMELL MEDINA LUCERO, is of legal

age, Filipino Citizen, Single and presently residing at Blk.
1B, Lot 9, Marvie Hills, San Mateo, Rizal;

2. Respondent is an Overseas Filipino Worker as

Seaman (Seabased) as evidenced by an Overseas Filipino
Worker (OFW) Information issued by the Philippine
Overseas Employment Administration hereto attached as
Annex “A” and made integral part of this Complaint-
Affidavit;

3. That sometime on the year 2008, I and

respondent got acquainted to each other through cell
phone communication. Said acquaintance was initiated by
respondent as he obtained my cell phone number from my
cousin. Constant communication between us ensued,
which grew into courtship. On the same year, 2008, we
personally met, were romantically involved over a period
of time and on a continuing basis and became live in
partners;

4. That out of our union without the benefit of

marriage or under a common law relationship, we were
blessed with two (2) children. Our first child, KATE
DANIEL JUGAR LUCERO, was born on
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August 27, 2009 when I and respondent were still living

with his Mother at San Mateo, Rizal. Our second child,
PRINCESS DENNISSE ANN JUGAR LUCERO, was born
December 17, 2014. By year 2015, we resided at Marikina
City.Copy of our said first child’s Certificate of Live Birth is
hereto attached as Annex “B” while that of our second
Child is hereto attached as Annex “C”, both of which are
made indispensable parts of this Complaint-Affidavit;

5. Sometime on September 2015, respondent left

for overseas employment but was sent back home by his
overseas employer as respondent alleged that he
contracted malaria, however, respondent did not stayed
with me and our children at Marikina City when he came
back on the allegation that we might be infected by his
malaria and at this point, he rarely stays with us and only
provide us with measly One Thousand Pesos (P1, 000.00)
a week;

6. Sometime on February 2016, respondent again

left for overseas employment / job. At that time, certain
young woman sen me a photograph of her and respondent
closely together in bed. I confronted respondent
about the matter while he was abroad but he constantly
made denials. I discovered later from trusted information
that respondent already arrived in the Philippines from
overseas employment and as of July 2016, he is living with
the aforementioned woman together as husband and wife
at San Mateo, Rizal;

7. That at present, I and our children are living at

my Sister’s address at San Juan City, Metro Manila, since
we were constrained by respondent’s Mother to leave our
house – residence in Marikina City as according to her, the
same will be sold and thereafter, its owner informed me
that respondent was not paying the purchase price of the
house;

8. From July 15, 2016 and continuously up to

present time, respondent deliberately and completely
refuse and fail to provide our two minor children with
financial and economic support despite my repeated pleas
for him to provide such support and, despite the fact of
receipt by him of my Letter of Demand for Support hereto
appended as Annex “D”, respondent remain heedless an
adamant as he persistently refuses and fails to provide
our minor children with financial or economic support;
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9. That respondent’s deliberate, continuous and

complete refusal and failure to give support to our
children occurred at the time I and the children were
residing in Mandaluyong City, and such refusal and failure
to provide support continues up to present time;

10. That, because of this, I was forced to put up my

own on-line shop in selling bags but is not that
profitable to meet and sustain our children’s financial,
economic and school needs causing me to be reliant for
little financial help extended by my Brother and Sister;

11. That the afore-narrated actuations of the

respondent without any justifiable reasons in depriving
our two (2) minor children of financial or economic support
and/or monthy financial or economic support constitutes
economic violence under Section 5, paragraph (2) of R.A.
9262 known as Violence Against Women and Children Act
that is, - Depriving or threatening to deprive the woman or
her children of financial support legally due her or her
family, or deliberately providing the woman's children
insufficient financial support;

12. That respondent’s actuations likewise constitutes

economic violence under Section 5, paragraph (3) of R.A.
9262, that is - Depriving or threatening to deprive the
woman or her child of a legal right;

13. That as may be culled from the Overseas Filipino

Worker (OFW) Information issued by the Philippine
Overseas Employment Administration (Annex “A” hereof),
respondent is earning rich, abounding and handsome
salary of One Thousand One Hundred Seventy Five United
States Dollars (US$ 1, 175. 00) per month exclusive of his
other overseas employment benefits, thus, there is no
reason that he should deprived our two (2) children the
monthly support or economic or financial report;

14. That respondent’s acts has caused so much

emotional and financial distress not only to me but to our
two (2) children, specially our first Child who may already
have trauma or stigma, since without my encouragement
and insistence, he would not want to go to school as he is
being branded of having no Father;

15. That I alone tend to and take care our minor

children thus, I could not take full time job or employment,
except the on-line shop in selling bags I mentioned to help
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a little somehow in our daily needs or sustenance though

it is not very profitable;

16. That I execute this Complaint-Affidavit to attest

to the truth of the foregoing facts and for the purpose of
filing a Complaint for Violation of Republic Act 9262 known
as the Violence Against Women and Their Children Act
against respondent ROMELL MEDINA
LUCERO with the Office of the City Prosecutor of
Mandaluyong City.

IN WITNESS WHEREOF, I have hereunto affixed my

signature this ______ day of October 2016 at Mandaluyong
City, Metro Manila, Philippines.

ELGIE SARAMOSING JUGAR

Affiant

SUBSCRIBED AND SWORN to before me this ______ day

of October 2016 and I hereby Certify that I have examined
the Affiant and I am fully satisfied that she voluntarily
executed her Complaint-Affidavit and that she understood
the same.

ASSISTANT CITY PROSECUTOR