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JUKE DE COM JUDE Republic of the Philippines)

Province of South Cotabato) S.S.


Municipality of Polomolok)
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AFFIDAVIT OF COMPLAINT
I, NORMA MAQUIDATO-LAYAGAN, Filipino, of legal age, married to Tony B.
Layagan and a resident of Purok Maligaya, Silway -8, Polomolok, South Cotabato, Philippines,
after having duly sworn to in accordance with law do hereby depose and say THAT.

1.) I stand as the Complainant against the person of TONY B. LAYAGAN, my


husband, as Respondent of this complaint for violation of section 5,
paragraphs a, h (5) and i, of RA 9262 and with his office address at New
Society National High School, Sinawal, General Santos City,

2.) Respondent Tony B. Layagan and Complainant were legally married on November
28, 1987, in a religious wedding ceremony conducted by Rev. Fr. Jose Legaria at
Polomolok, South Cotabato. Machine copy of their Marriage Contract is hereto
is hereto attached as Annex “A” and forms part of this Complaint;

3.) They lived together as husband and wife in a residence located at Purok Maligaya,
Silway 8, Polomolok, South Cotabato. Out of their union, they begot five (5)
children named Tony Jr., Toni Rose, Tony Love, Tony III and Tony Antonette,
who were born on July 14, 1988, July 5, 1989, July 18, 1990, April 15, 1993 and
April 3, 1997. Machine copies of their Birth Certificates are hereto attached
respectively as Annexes “B, C, D, E & F” and form part of this Complaint;

4.) Complainant and Respondent are both government employees (Public High
School Teacher) under the Department of Education. Complainant is assigned at
Silway 8 National High School, Polomolok, South Cotabato while Respondent is
likewise assigned at New Society National High School, Sinawal, General Santos
City;

5.) Respondent started to fail performing his obligation in the year 1997 when he
devoted most of his free time engaging in drinking sprees with his barkadas at
different Karaoke Bars in General Santos City. He came home very late in the
evening and or even at already dawn in the following morning;

6.) When he became a member of Guardians Brotherhood, he had no more time for
his family. Instead of going home from his class, he went with his brothers in the
said organization to somewhere else in General Santos City. Worst, his free time
in Saturday and Sunday was already committed not to his family anymore but to
his brotherhood;

7.) Respondent’s financial obligations therefore to his spouse, the herein Complainant
and his children were already affected. He only gave his salary (if any) to his
family whenever he wanted to. His loans were only spent for his mistress and
barkadas;
8.) For three (3) times already Respondent made loans without the consent of the
Complainant. He only copied or forged her signature whenever loans required
marital consent. It was only discovered later when it appeared in the pay slip of
the Complainant that payments of loans were deducted from her salary.
Respondent had no more contribution to the management of the household;

9.) These acts of Respondent are the reasons of their frequent quarrels during the time
they lived in one roof. What was Complainant’s regret is that every time they
quarreled, Respondent who was reckless and foolish when drunk, would hit her
and their children causing them some physical injuries;

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