Republic of the Philippines)

City of Surigao ) S.S.

COMPLAINT-AFFIDAVIT

I, RONEL E. LIZA, of legal age, Filipino, married and a resident of

Barangay San Miguel, San Isidro, Surigao del Norte, under oath, hereby
state that:

1. I am charging Jesriel Petallo alias Decling (Mr. Petallo for

brevity), of legal age, single, Filipino, a resident of Brgy. Del
Carmen, San Isidro, Surigao Del Norte for Grave Threat under
Article 282 of the Revised Penal Code. Said incident is
extensively discussed below;

2. At about 9: 30 A.M. of April 22, 2016, I was driving my motorcycle

together with my wife, Robelyn Liza and my six-year old son going
to Dapa for Medical Examination.

3. On my way, I stopped along the highway of Brgy. Roxas, San

Isidro, Surigao del Norte for a short conversation with Bemboy
Petallo, my co-worker in DPWH who was working at that time.
After such conversation, I decided to proceed to Dapa.

4. As I was about to leave, a Ford Everest vehicle bearing Plate No.

TQU 741 blocked my way. Then, a certain Jesriel Petallo alighted
from the vehicle holding with him a handgun believed to be a .45
caliber firearm. Said Jesriel Petallo cocked his gun and thereafter
aimed at me ordering me to kneel down and shouted: Jawa kaw,
patjon ta kaw, buk-on ko imo uyo!

5. However, a certain Richie Dramayo Linnell arrived and shouted at

Jesriel Petallo telling him not to shoot me and conceal the gun
because of the election gun ban.

6. Thereafter, Jesriel Petallo tucked said gun in his waist.

7. The entire incident was witnessed by Bimboy Petallo and Robelyn

Liza and their corresponding affidavits are hereto attached as
 Annex A and Annex B respectively.

8. In the case of Paera vs People of the Philippines (GR No. 181626,

May 30,2011), the Supreme Court held that Article 282 holds
liable for Grave Threats any person who shall threaten another
with the infliction upon the person x x x of the latter or his family
of any wrong amounting to a crime. This felony is consummated,
as sson as the threats come to the knowledge of the person
threatened.

10.1. Applying these parameters, it is clear that Mr. Petallos

threat to kill and to crack open the complainants skull are
wrongs on the person amounting to (at the very least) homicide
and serious physicial injuries as penalized under the Revised
Penal Code. These threats were consummated as soon as the
complainant Mr. Liza heard Mr. Petallo uttered his threatening
remarks.

9. I execute this complaint-affidavit to attest to the truth of the

foregoing facts.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

____ day of April 2016 in Dapa, Surigao del Norte.

RONEL E. LIZA
Affiant

SUBSCRIBED AND SWORN to before me this ___ day of

__________, 2016 in ______________________________. I
hereby certify that I have personally examined the above-named affiant and
that I am satisfied that the foregoing statements were given by him
voluntarily and of his own free will.

Prosecutor