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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


7th Judicial Region
Branch 50
Cebu City

FATIMA SARAH G. BONGO


Complainant,

- versus - NPS Docket No. 234561


Complaint for: Violation of
R.A 9262 Violence Against
Women and their Children

LANZ AIDAN L. OLIVES


Respondent.

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

JUDICIAL COMPLAINT – AFFIDAVIT

COMPLAINANT, by and through the undersigned


counsel, unto this Honorable Office, most
respectfully submits this Judicial Complaint
Affidavit and states, that –

PERSONAL CIRCUMSTANCES OF THE COMPLAINANT:

Complainant, FATIMA SARAH G. BONGO, single, of


legal age, Filipino, with residence at 248 Salcedo
St., Labangon, Cebu City,

Witness is a contractor.

PRELIMINARY STATEMENT

The person examining the complainant is Atty.


Sandra Jane N. Soon, of legal age, Filipino, with
postal address at M. Gov. Cuenco Ave., Banilad, Cebu
City, Philippines. The examination was held at the
postal address of the undersigned counsel and the
complainant answered the questions fully conscious
and did so under oath and may face criminal liability
for false testimony or perjury.
PURPOSE OF THE TESTIMONY

The purposes of the testimony are as follows:


1. To prove that the complainant and the
respondent are partners cohabiting with each
other;

2. To prove that the respondent has inflicted


violent behaviors toward the complainant on
several occasions after the former has lost
his employment;

3. To prove that the respondent has committed


physical abuse against the complainant’s son;

4. To prove that the respondent has been


committing psychological abuse against the
complainant by maliciously accusing the latter
of having a paramour in front of the former’s
friends; and

5. To prove other facts and circumstances in


relation to this case.

DIRECT EXAMINATION

1. Ms. Witness, do you know why you are here?


Ans. Yes, I am here because I want to file a
complaint for the violation of R.A. 9262 against
my live in partner, LANZ AIDAN L. OLIVES.

2. Where does your partner live?


Ans. He is a resident of 248 Salcedo St.,
Labangon, Cebu City where he may be served with
summons and other processes emanating from this
Honorable Court.

3. How did you and your partner meet?


Ans. We were college sweethearts for more than
three years. On March 28, 2010, our third
anniversary and right after our graduation, we
both decided to live together in the house which
his parents bought for him located at 248 Salcedo
St., Labangon, Cebu City.
4. You said you lived in together, did you and
respondent have kids?
Ans. After being live-in partners for more than
five years, we were blessed with two wonderful
kids, Lance Alden V.C Olives aged 4, and Mish
Aveline V.C Olives aged 2.

5. Did you and respondent have a harmonious


relationship together?
Ans. 1The first five years of our common-law
relationship have been harmonious. He was a
great provider for his family. He showed nothing
but being a loving and caring man. 1. However,
things changed starting July 29, 2017, when he
was terminated from the firm where he was
working. Since then, he became jobless and
depressed.

6. You said that you were filing a case for


Violation of R.A. 9262, why are you filing a
case for violation of R.A. 9262 against the
respondent?
Ans. Yes. I am filing a case against him because
of the physical and psychological abuse that he
has committed against me and my children Sir.

7. Have you and your children experienced these


abuses?
Ans. Yes Sir. Weeks after he was terminated, he
persistently looked for jobs but to no avail.
All other firms and companies where he applied
rejected him. Because of this, he became
frustrated. He easily gets mad to me and our
children. On September 18, 2017, after he went
from a job interview, I talked to him and told
him that the electricity bills and telephone
bills are already due. He responded violently
and said, “Pisting yawa, bayranan nasad! Sige
nalang ta ug bayranan ani wa nani kahumanan ang
bayranan bogoa ka!” His response shocked me
because I have never heard my common-law husband
cursed like that. Knowing him since college, I
know that he does not curse not use bad words
especially in front of our children.

8. Was this the only incident that he showed such


behavior?
Ans. On September 20, 2017, around 10:00 p.m, he
arrived home drunk. I offered him dinner.
However, when he found out that our food was
only fish and vegetables, he was enraged. He
said, “Utan? Utan ra imung ipakaon nako? Atay
pisting yawa! Maganahan gyud ko mangitag trabaho
ani nga utan ra pirmi ang sud-an? Di ko nimu
pakan-on ug tarong? Wa gyud kay silbi oi bogo!!”
After he uttered those words, he threw the plates
and the food in my face. He even poured the glass
of water on my face. On September 22, 2017, I
went to my mother’s house and asked for money
for the payment of electricity bills. After
such, I paid our bills and went home. When my
husband arrived home, I informed him that I was
able to pay the bills by borrowing money from my
mother. This angered him again. In front of our
kids, he grabbed my arm and pressed my face and
told me, “Ipamukha gyud nimu nako nga wa koy
kwenta nga amahan? Bogo kang bayhana ka!” He
proceeded to hit me in the face causing me to
lose my consciousness.

9. Did you do anything after these incidents with


the respondent?
Ans. With our savings gradually deteriorating
and my husband still jobless, I decided to apply
for work. I informed my husband of my plan but
he was silent about it. On October 25, 2017, I
informed him that I got accepted as a call center
agent in Teleperformance IT Park and was about
to start my training the next week. Ever since,
he stopped looking for jobs and stayed home.

10. Did you and respondent come into good terms


after you finding a job?
Ans. No. November 2, 2017, I started my job as
a call center agent. My shift was from 2:00pm to
10:00pm. When I arrived home from work, I found
him drinking with his college friends in our
garden. He then approached me and punched me in
the stomach, in front of his friends and our
children. He proceeded in accusing me that I
have a paramour. I remember him saying, “Ikaw’ng
bayhana ka. Buang man diay ka. Kabigaon nimu.
Nganong pirmi nalang ka dakong gabie na muuli
ha? Kinsa’y kabit nimu? Puta!” His college
friends and our children tried to stop him but
he even pushed our son away causing Lance to
fall and sustain minor injuries. I was then
rushed to the nearest clinic to treat my wounds
and contusions. On November 15, 2017, my
birthday, I went to my mother and confessed to
her what the respondent has been doing to me.
Unknowingly, my mother talked to respondent
about it. When I went home that night, the
respondent pulled my hair and pressed my face
against the wall. He said, “Buang ka! Sumbong-
sumbong gyud kas imung inahan bogo ka?” On
November 20, 2017, right after my shift, I
arrived home early and noticed some bruises to
my son’s legs. I asked him how he sustained them.
My son started crying. I asked him who did that
to him and he said, “Si Papa ani Ma” while
crying.

11. After these incidents, were you still living


with the respondent under the same house?
Ans. No. Since I could not bear his hitting
anymore, I decided to move to my mother’s place
together with my children.

12. What do you seek in filing this complaint?


Ans. I want to seek the issuance of temporary
protection order from respondent and for the
payment of support to his children.

13. Do you wish to add anything else?


Ans. No Sir.

Respectfully submitted.

Cebu City, Philippines, April 24, 2018.

FATIMA SARAH G. BONGO


Government Issue ID: Passport No. 736437947
Witness
CERTIFICATION

I, SANDRA JANE N. SOON, faithfully recorded the


questions I asked Ms. FATIMA SARAH G. BONGO and the
corresponding answers he gave me; and neither I nor
any other persob coached and/or suggested any answer
to the witness.

Deposing Lawyer:

By:

ATTY. SANDRA JANE N. SOON


Counsel for the Petitioner
Soon and Dionaldo Law Offices
Governor M. Cuenco Ave.,
Banilad, Cebu City

SUBSCRIBED AND SWORN to before me this 24th day of


April 2018 at Cebu City, Philippines. Affiants FATIMA
SARAH G. BONGO and ATTY. SANDRA JANE N. SOON are
personally known to me to be the same persons who
executed the foregoing instrument. I FURTHER CERTIFY
that I have examined the Judicial Affidavit and that
I am satisfied that he had fully understood and
voluntarily executed this Judicial Affidavit.

Doc. No. ;
Page No. ;
Book No. ;
Series of 2018.
REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
7th Judicial Region
Branch 50
Cebu City

FATIMA SARAH G. BONGO


Complainant,

- versus - NPS Docket No. 234561


Complaint for: Violation of
R.A 9262 Violence Against
Women and their Children

LANZ AIDAN L. OLIVES


Respondent.

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

COMPLIANCE

Complainant, FATIMA SARAH G. BONGO, through ATTY.


SANDRA JANE N. SOON, most respectfully submits the attached
judicial complaint affidavit in compliance with the order of this office.

April 24, 2018, Cebu City, Philippines.

By:

ATTY. SANDRA JANE N. SOON


Counsel for the Petitioner
Soon and Dionaldo Law Offices
Governor M. Cuenco Ave.,
Banilad, Cebu City
Email: attysoon@gmail.com

Copy Furnished:

LANZ AIDAN L. OLIVES


248 Salcedo St., Labangon, Cebu City

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