Republic of the Philippines

Department of Justice
CITY PROSECUTION OFFICE
________________

SOFIA VEGARA and Docket No: 12345

JONATHAN VERGARA
Complainants
, For: Violation of R.A 9262
-versus- Violence Against Women
ACE VENTURA and their Children
Respondent.

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

COMPLAINT – AFFIDAVIT

I, SOFIA VERGARA, of legal age, Filipino, common-law

wife of the respondent and a resident of #311 Mabini St., Sta.
Mesa, Manila, after having been duly sworn in accordance
with law, hereby depose and state:
1. I am the complainant in the instant case;
2. The respondent is my common-law husband and
who is of legal age, currently residing at #311 Mabini
St., Sta. Mesa, Manila;
3. That we used to be working in the same company,
ABC Corporation where we met. I was the HR
manager and the respondent was a supervisor in the
Operations Department;
4. That some time on October 2008, the respondent
received a complaint from his subordinate, Diana
Ramos for sexual abuse. The complaint was sent to
my office, copy of which is hereto attached as Annex
“A”;
5. That on the same month, the respondent have
expressed his love for me, hence, I did not impose
any disciplinary action against the former;
6. That on March 2009, we officially became lovers
which was kept as a secret being disallowed by
reason of the positions we hold in the company.
7. That we begot 1 (one) child named Jonathan Vergara
and was born on December 23, 2009. Copy of
Certificates of Live Birth are hereto attached and
marked as Annex “B”.
8. That on June 2010, we cohabitated and moved to
the respondent’s house at #311 Mabini St., Sta.
Mesa, Manila while still keeping our relationship a
secret at work;
9. That on November 2011, I have read text messages
from his phone from a woman named Jenny which
read,
“Miss na miss na kita babe. Gusto na kita makita.”

10. That I ignored those messages and have decided not

to read text messages from his phone anymore due
to my immense love for the respondent;
11. That on February 2012, I resigned from ABC
Corporation and moved to XYZ Corporation where I
was hired as the Vice-President of Human Resource
Department;
12. That on April 2013, the respondent lost his job for
continuously failing to reach his targets and
attendance issues;
13. That the respondent have tried but failed to find
another job and has been unemployed since then;
14. That I have been paying for everything, biils and
daily needs and was also giving him a personal
allowance of Php 5000 monthly;
15. That on June 2013, the respondent admitted to me
that he was previously married to a certain Teresa
Ventura on June 12, 2006, a fact that was not
disclosed to me initially. A copy of the marriage
certificate is hereto attached as Annex “C”.
16. That I have met with the respondent’s wife on
August 2013 and I was told that she left the
respondent by reason of his bad temper and the
physical abuse she received from the same;
17. That on December 15, 2013, I went home early from
work and around 3 o’clock in the afternoon, I saw
the respondent with his left hand around the waist
of another woman while the two of them were about
to enter SOGO HOTEL Cubao.
18. That I waited for the respondent to arrive home
around 11pm and confronted the same about the
woman he was with;
19. That the confrontation led to a heated argument
which eventually led to physical abuse in front of our
child where the respondent punched me in the face
causing a black eye on my left eye;
20. That on the next day, the respondent prepared
breakfast and promised me that he will never hurt
me again;
21. That I believed him and forgave him after that;
22. That on April 2, 2014, the respondent hurt me again
by pouring hot water on my legs which caused first
degree burn after I asked him about the text
message I have been reading in his phone from
woman named Jenny;
23. That later that evening, the respondent apologized
and explained that Jenny was only a friend and he
 asked me to forgive him for hurting him. I forgave
him right away;
24. That on May 5, 2015, our son came to me saying
that his father (respondent) wanted him to work in
a gay bar for additional income;
25. That I confronted the respondent about it which led
to a heated argument which again led to violence
where the respondent threw his phone on her face
causing pain and bruises;
26. That the respondent continually cursed her after that
outside their house where their neighbors can heart
causing scandal;
27. That some time in September 2017, I found a packet
of shabu inside the pocket of his used polo;
28. That I asked him about it causing him to act
violently, dragged me and our son outside the house
where he punched both of us in the face and on the
stomach causing us pain and injury;
29. That me and my son where both sent to the hospital
and was confined for 3 days;
30. That we didn’t go back to our house after we were
discharged but instead we went directly to the house
of my parents at Taguig City.
31. That on September 28, 2017, I filed for a Barangay
Protection Order and was approved after 5 days from
the filing.
32. That on October 15, 2017, I went back to their house
in Sta. Mesa to get a few things they left there but
was surprised to see that another woman was
already living there who introduced herself as Jenny;
33. That the respondent has been continuously sending
me messages asking me to forgive him;
34. That on November 25, 2017, I finally agreed to talk
to the respondent where Iforgave the former and got
back together after the respondent promised to
change his acts;
35. That the respondent also promised that he will also
ask Jenny to leave the house;
36. That on January 8, 2018, I went back with our child
Jonathan to our house at Sta. Mesa;
37. That I discovered that the respondent did not change
at all but instead got worse. She found that their
house already became a drug den where the friends
of the respondent would go there on a usual basis
for a drug session;
38. That on February 5, 2018, the respondent again hurt
me and our son causes us bruises and injuries;
39. That on the same day, I left the house together with
our son and went back to my parent’s house at
Taguig City;
40. That I was constrained to seek legal assistance from
a lawyer to file an application for a Temporary
Restraining order which was granted on May 8,
2018;
41. That our application for a Permament Protection
order was also granted on September 10, 2018;
42. That his act is tantamount to physical abuse under
under R.A. 9262 or Violence Against Women and
their Children prompting me to file a complaint
against the respondent;
43. Moreover, we suffer and continuously suffering of
mental and emotional anguish, public ridicule and
humiliation which is a violation of paragraph (i)
Section 5 of R.A 9262;
 44. That because of this criminal act and gross
misconduct, my husband deserves to suffer from
consequences of his act; AND
45. That I cause the preparation of this affidavit to
support my complaint.

IN WITNESS WHEREOF, I have hereunto set my hand

this ____________________ at ____________, Philippines.

SOFIA VERGARA
Complainant-Affiant

SUBSCRIBED AND SWORN to before me this 14th day of

February, 2019.

_____________________
City Prosecutor