Republic of the Philippines

7th Judicial Region

REGIONAL TRIAL COURT
Branch 31, Cebu City

PEOPLE OF THE PHILIPPINES,

Plaintiff,
CRIM. CASE NO. 1234
- versus - For: Grave Threats

ROMMEL ALFREDO
Accused.

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

COMPLAINT-AFFIDAVIT

I, RUCHIE U. ETOLLE, of legal age, Filipino, with residence at 253 E, Singson St., Zapatera,
Cebu City, after being sworn in accordance with the law, hereby depose and state:

1. That I know the person of ROMMEL ALFREDO, of legal age, Filipino, with residence at
Archbishop Reyes Avenue, Cebu City;
2. That the accused and I executed a contract of loan, whereby he borrowed from me the
amount of Twenty Thousand Pesos (P20,000.00), evidenced by a promissory note dated
January 2, 2018. A copy of the promissory note is hereto attached as Annex A;
3. That on November 25, 2018 at around 3pm, I, together with my driver, MARLON
RIVERA approached the residence of the accused in Brgy. Zapatera, Cebu City, to
demand payment of the said loan. The affidavit of MARLON RIVERA is hereto attached
as Annex B;
4. That the accused refused to pay the said loan and instead demanded that I leave
immediately. However, I expressed my insistence on the payment of the loan;
5. That the accused then clutched the handle of a bolo fastened around his waist and uttered
the following words in a resentful and threatening manner: “Di mo kasabot? Di pa lage
ko mubayad. Tagaan ra nako mo ug trenta segundos. Kung naa pa gale mo diri,
panigbason na nako mo! Ilabay pa nako inyong mga patay nga lawas sa suba!”
6. That out of fear for my life, I gave in to his demands and left unsatisfied;
7. That immediately after the said incident occurred, I reported the matter to the Barangay
Councilor IRENE ECLEO, who was the Officer of the Day stationed in the Barangay
Hall of Luz. The affidavit of Barangay Councilor Irene Ecleo is hereto attached as Annex
C;
8. That on November 29, 2018, I went to the Office of the City Prosecutor to file charges
against the accused;
9. That upon consultation with my lawyer, I understand that the acts of the accused qualify
for the crime of GRAVE THREATS punishable under Article 282 of the Revised Penal
Code; and
10. That I am executing this affidavit to attest to the truth of the foregoing facts and for the
purpose of filing a criminal complaint for GRAVE THREATS against the accused, who
may be served with subpoenas and other court processes at his last known address at
Archbishop Reyes Avenue, Cebu City.
IN WITNESS WHEREOF, I hereunto set my hand on this 29st day of November 2018 at Cebu
City, Philippines.

Ruchie U. Etolle
Affiant-Complainant

SUBSCRIBED AND SWORN to before me this 29th day of November 2018, Cebu City,
Philippines, affiant appearing before me with his Philippine Driver’s License Number 123 issued
by the Land Transportation Office on January 1, 2014 at Cebu City and presenting to me a
document entitled AFFIDAVIT, affiant is identified through his official ID card bearing his
photograph and signature, and who signed the said document in my presence and swore that he
understood the contents thereof and that the same was his free and voluntary act and deed.

Karyl E. Pepito
Office of the City Prosecutor
Cebu City, Cebu
Roll No. 234
IBP No. 234; 01-01-15; Cebu City
PTR No. 234; 01-01-15; Cebu City
MCLE Compliance No. 234

CERTIFICATION

I hereby certify that I have examined the Affiant and that I am fully satisfied that he has
voluntarily executed and understood the contents of the Complaint-Affidavit.

Karyl E. Pepito
Office of the City Prosecutor
Cebu City, Cebu
Roll No. 234
IBP No. 234; 01-01-15; Cebu City
PTR No. 234; 01-01-15; Cebu City
MCLE Compliance No. 234
 ANNEX A

PROMISSORY NOTE

I, ROMMEL ALFREDO, of legal age, Filipino, with residence at Archbishop Reyes Avenue,
Cebu City, promise to pay RUCHIE U. ETOLLE or order Twenty Thousand Pesos (P20,000),
with interest at a rate of 12% per annum, on or before November 25, 2018.

ROMMEL ALFREDO
Debtor
 ANNEX B

AFFIDAVIT

I, MARLON RIVERA, of legal age, Filipino, with residence at Barangay Zapatera, Cebu City,
after being sworn in accordance with the law, hereby depose and state:

1. That I know the person of ROMMEL ALFREDO, of legal age, Filipino, with residence at
Archbishop Reyes Avenue, Cebu City;
2. That I know the person of RUCHIE U. ETOLLE of legal age, Filipino, with residence at
at 253 E, Singson St., Zapatera, Cebu City;
3. That I have been employed as the driver of RUCHIE U. ETOLLE since January 1, 2014;
4. That on November 25, 2018 at about 3:00 pm, I accompanied RUCHIE U. ETOLLE to
Archbishop Reyes Avenue, Cebu City, in order to collect from ROMMEL ALFREDO
payment for a particular loan;
5. That ROMMEL ALFREDO refused to pay the said loan and instead demanded that we
leave immediately. However, RUCHIE U. ETOLLE expressed his insistence on the
payment of the loan;
6. That ROMMEL ALFREDO then clutched the handle of a bolo fastened around his waist
and uttered the following words in a resentful and threatening manner: “Di mo kasabot?
Di pa lage ko mubayad. Tagaan ra nako mo ug trenta segundos. Kung naa pa gale mo
diri, panigbason na nako mo! Ilabay pa nako inyong mga patay nga lawas sa suba!”
7. That out of fear for our lives, we gave in to his demands and left unsatisfied;
8. That immediately after the said incident occurred, we reported the matter to the Barangay
Councilor IRENE ECLEO, who was the Officer of the Day stationed in the Barangay
Hall of Luz and
9. That I am executing this affidavit to attest to the truth of the foregoing facts.

IN WITNESS WHEREOF, I hereunto set my hand on this 29th day of November 2018 at Cebu
City, Philippines.

MARLON RIVERA
Affiant
SUBSCRIBED AND SWORN to before me this 29th day of November 2018, Cebu City,
Philippines, affiant appearing before me with his Philippine Driver’s License Number 237 issued
by the Land Transportation Office on January 1, 2013 at Cebu City and presenting to me a
document entitled AFFIDAVIT, affiant is identified through his official ID card bearing his
photograph and signature, and who signed the said document in my presence and swore that he
understood the contents thereof and that the same was his free and voluntary act and deed.

Karyl E. Pepito
Office of the City Prosecutor
Cebu City, Cebu
Roll No. 234
IBP No. 234; 01-01-15; Cebu City
PTR No. 234; 01-01-15; Cebu City
MCLE Compliance No. 234
Doc No. 02
Page No. 02
Book No. 02
Series of 2018
 ANNEX C

AFFIDAVIT

I, IRENE ECLEO, of legal age, Filipino, with residence at Barangay Luz, Cebu City, after being
sworn in accordance with the law, hereby depose and state:

1. That I know the person of ROMMEL ALFREDO, of legal age, Filipino, with residence at
Archbishop Reyes Avenue, Cebu City;
2. That I know the person of RUCHIE U. ETOLLE, of legal age, Filipino, with residence at
253 E, Singson St., Zapatera, Cebu City;
3. That I am a duly elected Barangay Councilor of Barangay Luz, Cebu City;
4. That on November 25, 2018 at about 3:00 pm, I was the assigned Officer of the Day
stationed in the Barangay Hall of Luz;
5. That on the same day, RUCHIE U. ETOLLE reported an alleged GRAVE THREAT
made by ROMMEL ALFREDO upon the person of the former;
6. That according to the report of RUCHIE U. ETOLLE, ROMMEL ALFREDO clutched
the handle of a bolo fastened around his waist and uttered the following words in a
resentful and threatening manner: “Di mo kasabot? Di pa lage ko mubayad. Tagaan ra
nako mo ug trenta segundos. Kung naa pa gale mo diri, panigbason na nako mo! Ilabay
pa nako inyong mga patay nga lawas sa suba!”
7. That out of fear for his life, RUCHIE U. ETOLLE gave in to ROMMEL ALFREDO’s
demands and immediately made the aforementioned report; and
8. That I am executing this affidavit to attest to the truth of the foregoing facts.

IN WITNESS WHEREOF, I hereunto set my hand on this 27th day of November 2018 at Cebu
City, Philippines.

IRENE ECLEO
Affiant
SUBSCRIBED AND SWORN to before me this 29th day of November 2018, Cebu City,
Philippines, affiant appearing before me with his Philippine Driver’s License Number 908 issued
by the Land Transportation Office on January 1, 2014 at Cebu City and presenting to me a
document entitled AFFIDAVIT, affiant is identified through his official ID card bearing his
photograph and signature, and who signed the said document in my presence and swore that he
understood the contents thereof and that the same was his free and voluntary act and deed.

Karyl E. Pepito
Office of the City Prosecutor
Cebu City, Cebu
Roll No. 234
IBP No. 234; 01-01-15; Cebu City
PTR No. 234; 01-01-15; Cebu City
MCLE Compliance No. 234
Doc No. 06
Page No. 04
Book No. 05
Series of 2018