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Republic of the Philippines)

Muntinlupa City )s.s.


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

AFFIDAVIT-COMPLAINT

I, ROGER M. CANLAS, of legal age, single, Filipino and


resident of 21 Acasia St. Filinvest, Muntinlupa City, under oath,
hereby depose and say, that:

1. I am the sports editor of the Manila Star Bulletin since


July 2013. I hereby formally charge the following persons
for the crime of Libel under section 4, (c) paragraph 4 of
R.A. 10175 also known as the Cybercrime Prevention Act
of 2012;

1.a. JONATHAN “JON” ASUNCION, Editor-In-


Chief, MIKAELA “KYLA” RAMOS, Columnist and
Features Editor of the Manila Mirror Inquirer all of
legal age and with business address at Unit 305-307,
4th Floor, HBD Building, Commerce Avenue,
Muntinlupa City, herein referred to as
RESPONDENTS.

2. Manila Mirror Inquirer is a newspaper of general


circulation in Metro Manila with business address at at
Unit 305-307, 4th Floor, HBD Building, Commerce
Avenue, Muntinlupa City.

3. On February 26, 2o15, respondents by conspiring and


confederating to malign my person, character and honor
caused the publication through theManila Mirror Inquirer
Website (www.TheManilaMirrorInq.com.ph), under the
Opinion page, an article entitled “In the Absence of
Sportsmanship: A Grossly Biased Writer” written by
Columnist Mikaela “Kyla” Ramos, published for all to see
through their office in Muntinlupa City on even date.

Attached is the full text of libelous article hereto referred


as Annex "A".

4. Said article published by respondents, without observing


the ethical standards of journalism, contained malicious
imputations with bad intentions and unjustifiable
motives, purposely to malign,dishonor, discredit, insult
and assassinate my characeter and good reputation to the
public as well as to my constituents, an excerpt of which
are hereby quoted:

“However, what Canlas does not understand - even


after being in the field of news writing for years - is
that when one is an editor who writes articles made
available to the public, all biases should be eliminated.
His lack of proper research in writing his recent
article on the PBA shows his incompetence and
unworthiness. He wrote like an amateur, as if an
apprentice that was only recently hired to write for a
renowned paper. Unfortunately for the company he
works and writes for, Canlas has exposed his and the
company’s weakness, inefficiency and ineffectiveness
as deliverers of news which failed to be factual, actual
and truthful. His work was defamatory as against the
PBA, without him even knowing it.”

5. The afore-quoted portion ofthe online article authored by


respondent Mikaela “Kyla” Ramos published by the herein
respondents created in the minds of the readers that I am
liar, deceitful and biased in my workas a sports editor of
Manila Star Bulletin.

6. The article written and published by respondents has no


factual basis, is highly speculative and was all false
statements made to destroy my reputation as a writer and
an editor of one of the country’s renowned newspapers.
Respondents were motivated by bad faith in the
publishing of the said article online to defame, embarrass
and discredit me to my colleagues, friends, family and to
the readers and patrons of our publication;

7. The libelous article having been published through the


Manila Mirror Inquirer Website, a website accessible to
and is made available to the general public was read by
the said general public, including my colleagues, friends
and family among others;

8. Due to the said malicious public imputations by


respondents, I suffered and continue to suffer serious
anxiety, besmirched reputation, mental anguish, sleepless
nights, not to mention the damage they have caused to my
career, reputation and honor among the readers and
patrons of the Manila Star Bulletin and the general public;

9. Due to such grossly injustifed malicious and libelous


imputations, I therefor pray that respondents be made to
pay jointly and severally, the damages I was made to
suffer as a result of the online published article in
whatever amount the Honorable Court deems sufficient
and proper together with the attorney’s fees and the cost
of this suit.

I here by execute this affidavit to attest to the truth of the


foregoing facts and hereby request the investigating prosecutor to
file the crime of Libel under R.A. 10175 against the herein
Respondents.

IN WITNESS WHEREOF, I have hereunto set my hand


this 14th day of March 2016 in Muntinlupa City, Philippines
Affiant

SUBSCRIBED AND SWORN TO before me this 14th day of


March 2016 at Muntinlupa City, Philippines the following affiant
MONICA A. MARIANO exhibiting to me her Government issued
Non-Professional Driver’s License no. 8293-9173-19 being
sufficient and competent evidence of his/her identity in pursuant
to the 2004 Rules of Notarial Practice.

Doc. No. ____;


Page No.____;
Book No. ____;
Series of 2016