REPUBLIC OF THE PHILIPPINES}

BAGUIO CITY }S.S.

X=========================X

AFFIDAVIT-COMPLAINT

I, MAW T. TONG of legal age, Filipino Citizen, single and

a resident of 72 Aurora Hill, Baguio City, after having been
sworn in accordance with law hereby state:

1. That on June 12, 2016 at around 11 in the evening, I was at

home playing “tong-its” with my friend RANDO M. DUDE and
my brother LAO T. TONG;

2. Rando and Lao engaged into a heated argument about who

was better looking between the two of them. I did not join in
since I thought at that time that the argument was insignificant;

3. Suddenly Lao stood up and accused Rando of cheating and

being a loudmouth. Rando then grabbed a bottle of beer and
smashed it to Lao’s face, then with the same broken bottle on
his hand, he stabbed Lao on the belly causing the latter to
bathe in his own blood;

4. Rando then ran off, and I called the police, but when they
arrived it was too late, and my brother was already dead;

5. I am therefore executing this affidavit-complaint in support of

the charges for homicide against RANDO M. DUDE.

IN WITNESS WHEREOF, I have hereunto set my hand this DATE

DATE DATE, in the City of Baguio, Philippines.

MAW T. TONG
Affiant

SUBSCRIBED AND SWORN to before me, in the City of

Baguio, Philippines, this DATE DATE DATE, I further Certify that I
have personally examined the affiant and that I am satisfied that he
gave his statement freely and that he understood the contents of his
affidavit-complaint.
Doc. No. _____;
Page No. _____;
Book No. _____;
Series of 2019.
REPUBLIC OF THE PHILIPPINES}
BAGUIO CITY }S.S.
X=========================X

AFFIDAVIT-COMPLAINT

I, MAW T. TONG of legal age, Filipino Citizen, single and

a resident of 72 Aurora Hill, Baguio City, after having been
sworn in accordance with law hereby state:

1. That on November 18, 2015 at around 11 in the evening, I was

at home drinking with my brother LAO T. TONG;

2. A red Honda Civic then stopped in front of our house. Then two
men alighted the vehicle, one was carrying a shotgun;

3. Suddenly the man with the shotgun, entered our house and
fired two shots at my brother, one to the face, the other to his
groin area;

4. The two men then ran off, and I called the police, but when they
arrived it was too late, and my brother was already dead;
5. It was later discovered that the man who shot my brother was
ADOLFO G. HILTER and his driver was RANDO M. DUDE;

6. I am therefore executing this affidavit-complaint in support of

the charges for murder against ADOLFO G. HILTER and
RANDO M. DUDE.

IN WITNESS WHEREOF, I have hereunto set my hand this DATE

DATE DATE, in the City of Baguio, Philippines.

MAW T. TONG
Affiant

SUBSCRIBED AND SWORN to before me, in the City of

Baguio, Philippines, this DATE DATE DATE, I further Certify that I
have personally examined the affiant and that I am satisfied that he
gave his statement freely and that he understood the contents of his
affidavit-complaint.
Doc. No. _____;
Page No. _____;
Book No. _____;
Series of 2019.
REPUBLIC OF THE PHILIPPINES}
BAGUIO CITY }S.S.
X=========================X

AFFIDAVIT-COMPLAINT

I, MAW T. TONG of legal age, Filipino Citizen, single and

a resident of 72 Aurora Hill, Baguio City, after having been
sworn in accordance with law hereby state:

1. That on January 13, 2016, at exactly 11:59 in the evening, I

was walking along Magsaysay Road. There was less than
usual people since it was already late;

2. I stopped at the Metrobank Building to withdraw an amount of

Php10,000.00;

3. Afterwards, I started walking again and suddenly a huge man

later identified as RANDO M. DUDE started matching my
walking pace and then pointed a gun at my waist and said
“holdap to, nakita kong nag-withdraw ka sa banko kaya wag ka
na magdahilan na wala kang pera”;

4. Fearing for my life, I gave all the money I withdrew from the
ATM amounting to Php10,000.00;

5. I am therefore executing this affidavit-complaint in support of

the charges for robbery against RANDO M. DUDE.

IN WITNESS WHEREOF, I have hereunto set my hand this DATE

DATE DATE in the City of Baguio, Philippines.

MAW T. TONG
Affiant

SUBSCRIBED AND SWORN to before me, in the City of

Baguio, Philippines, this DATE DATE DATE, I further Certify that I
have personally examined the affiant and that I am satisfied that he
gave his statement freely and that he understood the contents of his
affidavit-complaint.
Doc. No. _____;
Page No. _____;
Book No. _____;
Series of 2019.
REPUBLIC OF THE PHILIPPINES}
BAGUIO CITY }S.S.
X=========================X

AFFIDAVIT-COMPLAINT

I, MAW T. TONG of legal age, Filipino Citizen, single and

a resident of 72 Aurora Hill, Baguio City, after having been
sworn in accordance with law hereby state:

1. That I am the owner of a 2010 Honda Civic with a plate no.

DCH 001;

2. I use my car to go from my house to my work which is at

University of the Cordilleras, Gov. Pack Road, Baguio City;

3. I usually park my car inside the school parking space but on

February 18, 2015, the carpark was full and I was forced to
park outside of the school;

4. After I left my car, a person later identified as RANDO M. DUDE

pointed a gun at me and demanded that I give him the keys to
my car. Out of fear I obeyed his order;

5. He then entered my car and drove off;

6. I then reported the incident to the police and the car was
recovered after 20 minutes at a checkpoint along Military Cut-
Off Road, and Bach was arrested;

7. I am therefore executing this affidavit-complaint in support of

the charges for carnapping against RANDO M. DUDE.

IN WITNESS WHEREOF, I have hereunto set my hand DATE

DATE DATE, in the City of Baguio, Philippines.

MAW T. TONG
Affiant
 SUBSCRIBED AND SWORN to before me, in the City of
Baguio, Philippines, this DATE DATE DATE, I further Certify that I
have personally examined the affiant and that I am satisfied that he
gave his statement freely and that he understood the contents of his
affidavit-complaint.

Doc. No. _____;

Page No. _____;
Book No. _____;
REPUBLIC OF THE PHILIPPINES}
BAGUIO CITY }S.S.
X=========================X

AFFIDAVIT-COMPLAINT

I, STEVE N. BUSCEMI of legal age, Filipino Citizen,

single and a resident of 112 Guisad Surong, Baguio City, after
having been sworn in accordance with law hereby state:

1. That on June 2, 2016 I was walking at with my friend SHEIS A.

GIRL in Burnham Park at around 11 in the evening;

2. While walking, we noticed a huge man, later identified as

RANDO M. DUDE;

3. The man was not doing anything suspicious, even though he

was in a dark corner, so we continued walking toward him;
4. All of a sudden, he pointed a gun at me and he grabbed my
friend;

5. He then tied my hands behind my back and grabbed us both to

a nearby vacant room;

6. After we went inside, he kicked in me in the face and told me

“panuorin mo kung ano gagawin ko sa girlfriend mo!”

7. He then proceeded to undress my friend Sheis. He ripped all of

her clothes until she was totally naked;

8. Afterwards, he took off his pants and forced his penis first to the
mouth of Sheis then into her private part;

9. When he was done with my friend, he kicked me again in the

face, and he left the room;

10. The next day, we were rescued by the police forces, and Rando
was arrested;

11. I am therefore executing this affidavit-complaint in support of

the charges for rape against RANDO M. DUDE.

IN WITNESS WHEREOF, I have hereunto set my hand DATE

DATE DATE, in the City of Baguio, Philippines.
 MAW T. TONG
Affiant

SUBSCRIBED AND SWORN to before me, in the City of

Baguio, Philippines, this DATE DATE DATE, I further Certify that I
have personally examined the affiant and that I am satisfied that he
gave his statement freely and that he understood the contents of his
affidavit-complaint.

Doc. No. _____;

Page No. _____;
Book No. _____;
REPUBLIC OF THE PHILIPPINES}
BAGUIO CITY }S.S.
X=========================X

AFFIDAVIT-COMPLAINT

I, BLIT Z. KRIEG of legal age, Filipino Citizen, single and

a resident of 117 Guisad Surong, Baguio City, after having
been sworn in accordance with law hereby state:

1. That on June 24, 2016, at about 11 in the evening, I was

walking along Magsaysay Road, Baguio City;
2. Suddenly two males approached me, and pointed a knife at my
neck;
3. I offered to give all my money to them, but apparently it was not
what they wanted;
4. The first guy, later identified as ADOLFO G. HILTER, held both
of my hands, and tied them up behind my back, while the
second guy, later identified as MAW T. DONG, acted as a
lookout;
5. There were no other persons while the incident happened;
6. I woke up with my whole body tied to a pole, and any
movement was impossible;
7. Hilter then talked to me and showed me a draft of a supposed
ransom letter. As much as I can recall, the letter indicated the
amount of Php2,000,000.00 in exchange of my freedom;
8. I heard them talk about the letter being sent to my address;
9. After about 2 weeks, they untied me and told me “laya ka na,
may nagbayad ng ransom mo!”
10. I was dragged outside of the building which turned out to
be a farmhouse somewhere in La Union.
11. Suddenly police officers swarmed the two and arrested
them;
12. I am therefore executing this affidavit-complaint in support of
the charges for kidnapping against ADOLFO G. HILTER and
MAW T. DONG.

IN WITNESS WHEREOF, I have hereunto set my hand this DATE

DATE DATE, in the City of Baguio, Philippines.

BLIT Z. KRIEG
Affiant

SUBSCRIBED AND SWORN to before me, in the City of

Baguio, Philippines, this DATE DATE DATE, I further Certify that I
have personally examined the affiant and that I am satisfied that he
gave her statement freely and that he understood the contents of his
affidavit- complaint.
 REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 1
Baguio City

PEOPLE OF THE PHILIPPINES

Plaintiff,
CRIMINAL CASE NO. CC-9
-versus- FOR: Theft
RANDO M. DUDE
Accused.
x--------------------------------------------------x

APPLICATION FOR PROBATION

The accused, thru counsel, states;

1. He is of legal age, single, Filipino citizen, and a resident of 123

Gibraltar Rd., Baguio City, Philippines;

2. On June 12, 2015 the Court rendered a Judgment on the case

convicting him of the crime of theft and sentencing him to suffer
the penalty of imprisonment, the dispositive portion read as
follows:

“WHEREFORE, judgment is hereby rendered, finding the

accused guilty beyond reasonable doubt of the crime of
Theft under Article 309 (2) of the Revised Penal Code.
They are hereby sentenced to suffer the indeterminate
penalty of imprisonment ranging from Six (6) Months and
One (1) day of Prision Correccional, as minimum, to Four
(4) Years and Two (2) Months and One (1) Day also of
Prision Correccional, as maximum.

SO ORDERD.”

3. In view of the foregoing judgment, the accused hereby applies

before the Court for probation;

4. The accused further states that he is not one among those

offenders disqualified to avail of the benefits of probation, as
provided under Section 9, of Presidential Decree No. 968, as
amended, to wit:
 Section 9. Disqualified Offenders. The benefits of this
Decree shall not be extended to those:
(a) sentenced to serve a maximum term of
imprisonment of more than six years;
(b) convicted of any offense against the security of
the State;
(c) who have previously been convicted by final
judgment of an offense punished by imprisonment
of not less than one month and one day and/or a
fine of not less than Two Hundred Pesos;
(d) who have been once on probation under the
provisions of this Decree; and
(e) who are already serving sentence at the time the
substantive provisions of this Decree became
applicable pursuant to Section 33 hereof.

5. The accused has not perfected nor does he intend to perfect an

appeal from the aforementioned judgment of the Honorable
Court;

6. He further undertakes to faithfully and religiously comply with

the conditions of the probation as provided for under P.D. 956
(Probation Law of 1976) or as may be ordered by the
Honorable Court should this application for probation be
granted.

PRAYER

WHEREFORE, it is prayed that this pleading be noted and

made part of the records of the above-entitled case and that this
Application for Probation filed by the accused RANDO M. DUDE be
granted.

Baguio City, Philippines this DATE DATE DATE

EDIT MO TONG PART NA TO:

RONIC ALBERT D. TREPTOR
Counsel for the Accused
Suite 420, Random Building, Session Road,
Baguio City
Roll No. 67777; IBP No. 101311
PTR No. 7777 – April 30, 2019
SN. 670101-13-221; Baguio City
MCLE Comp. No. 7778877-19
 REQUEST FOR AND NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Regional Trial Court
Branch 1, Baguio City

Please submit the foregoing Motion to the Court for its

consideration and approval immediately upon receipt hereof and
kindly include the same in the court’s calendar for hearing on
Tuesday, July 23, 2019 at 9:30 in the morning.

RONIC ALBERT D. TREPTOR

Counsel for the Accused
Suite 420, Random Building, Session Road,
Baguio City

Copy furnished:

Office of the City Prosecutor

Baguio City, Philippines
 REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 1
Baguio City

PEOPLE OF THE PHILIPPINES

Plaintiff,
CRIMINAL CASE NO. CC-9
-versus- FOR: Violation of Domicile
RANDO M. DUDE
Accused.
x--------------------------------------------------x

ENTRY OF APPEARANCE AS COUNSEL

The undersigned counsel states:

1. That the undersigned counsel has just been retained by the

accused in the above-entitled case;

2. That henceforth, he respectfully prays that all copies of

pleadings, notices and orders be furnished to the undersigned
at his address indicated below.

PRAYER

WHEREFORE, it is prayed that the appearance of the

undersigned be noted.

Baguio City, Philippines, DATE DATE DATE. Palitan mo nlng:

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2019.

Copy Furnished: (personal delivery)

OFFICE OF THE CITY PROSECUTOR
Baguio city, Philippines
 REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 1
Baguio City
MAW T. DONG
Plaintiff,
CIVIL CASE NO. CC-2231
-versus- FOR: Collection for Sum of Money
RANDO M. DUDE
Defendant.
x--------------------------------------------------x

MOTION TO WITHDRAW

The undersigned counsel state that:

1. The undersigned counsel has already terminated his attorney-

client relationship with the Defendant RANDO M. DUDE,
particularly because of the latter’s act of insisting that the
undersigned introduce forged documentary evidence to have
an advantageous decision in this case;

2. The undersigned had continuously explained to the defendant

such act would violate the former’s Code of Professional
Responsibility, since lawyers are not permitted to do any
falsehood nor consent to the doing of any in court ;

3. Rule 22.01 paragraph (b) of the Code of Professional

Responsibility states that a lawyer may withdraw his services
when the client insists that the lawyer pursue a conduct
violative of the canons and rules;

4. As such, undersigned requests that he ba allowed by this Court

to withdraw his appearance in this case as counsel for the
defendant RANDO M. DUDE without the latter’s express
conformity.

PRAYER

WHEREFORE, it is prayed that the undersigned be allowed to

withdraw his appearance in this case as counsel for the defendant,
dispensing with the latter’s express conformity, and the he be relieved
of all his responsibilities relative to this case.
Baguio City, Philippines, this DATE DATE DATE.

EDIT MO TO:
RONIC ALBERT D. TREPTOR
Counsel for the Defendant
Suite 420, Random Building, Session Road,
Baguio City
 REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 1
Baguio City

MAW T. DONG
Plaintiff,
CIVIL CASE NO. CC-2231
-versus- FOR: Collection for Sum of Money
RANDO M. DUDE
Defendant.
x--------------------------------------------------x

MOTION TO WITHDRAW AS COUNSEL

The undersigned states that:

1. The undersigned counsel can no longer fully represent the

interest of the respondent due to the workload of the
undersigned and the inability of the defendant to consult
regularly with the undersigned considering the distance
between the office of the undersigned and the home address of
the defendant;

2. The defendant also signified their intention to seek the services

of another lawyer such that the foregoing motion is with the
conformity of the defendant.

PRAYER

WHEREFORE, it is prayed to this Court that the undersigned

be now relieved of his duties as counsel for the defendant.

Baguio City, Philippines, DATE DATE DATE

RONIC ALBERT D. TREPTOR

Counsel for the Defendant
Roll No. 67777; IBP No. 101311
PTR No. 7777 – April 30, 2019
SN. 670101-13-211; Baguio City
MCLE Comp. No. 7778877-19
Suite 420, Random Building, Session Road,
 Baguio City

WITH CONFORMITY:

RANDO M. DUDE
Defendant

Copy furnished:
ATTY. Adolfo G. Hilter
Counsel for the Plaintiff
Nein Nein Nein, Random Building
Nein Road, Baguio City
 REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 1
Baguio City

MAW T. TONG
Plaintiff,
CIVIL CASE NO. CC-2231
-versus- FOR: Collection for Sum of Money
RANDO M. DUDE
Defendant.
x--------------------------------------------------x

MOTION TO WITHDRAW AS COUNSEL WITH SUBSTITUTION

THE CLERK OF COURT

Regional Trial Court of the City of Baguio
Branch 1

ATTY. Name mo, counsel on record for the defendant and to

this Court moves to withdraw as counsel of said defendant with the
express consent of the defendant as shown in this motion;

That in substitution thereof, ATTY. SIXIS T. MANN, whose

services have been engaged by defendant hereby enters his
appearance as counsel for the defendant;

That upon approval of this Court, all pleadings, notices, and

papers in connection with this case be addressed to new counsel
ATTY. SIXIS T. MANN with address at Suite 88, Porta Vaga, Session
Road, Baguio City.

Baguio City, Philippines, DATE DATE DATE.

OLD COUNSEL

LAGAY MO INFO MO

NEW COUNSEL

ADOLFO G. HILTER
Roll No. 59188; IBP No. 103321
PTR No. 8872 – April 28, 2017
 SN. 670101-13-212; Baguio City
MCLE Comp. No. 7123477-17
Suite 88, Porta Vaga, Session Road,
Baguio City