Position Paper
Position Paper
-versus-
POSITION PAPER
Complainant, unto this Honorable Office, most respectfully submits this
paper in support of her complaint and avers the following:
THE PARTIES
FACTS
1
4. Complainant and Paul Vincent Ducta Detecio have a daughter named
Hope Vhyncent Llovit Detecio born on December 30, 2009, copy of her Certificate
of Live Birth is herein attached as EXHIBIT C;
8. On July 11, 2013, complainant reported to the police the illicit affair of
her husband Paul Vincent Ducta Detecio with respondent and subsequently filed
a case for violation of Republic Act No. 9262 or the Anti-Violence Against Women
and their Children Act of 2004, attached herewith as EXHIBIT E and EXHIBIT
F respectively is the certification of police blotter and Complaint for violation of
R.A. 9262;
2
11. That respondent’s continued and willful act of being the concubine of
complainant’s husband is a crime involving moral turpitude and a clear
violation of NAPOLCOM Memorandum Circular No. 2016-002 and constitutes
Grave Misconduct and Conduct Unbecoming of a Police Officer, grave
offenses that warrant dismissal from the service;
13. That respondent’s claim that complainant herself is involved with another
man is unproven and unsubstantiated and thus warrants no consideration from
this Honorable Office;
PRAYER
WHEREFORE, in view of the foregoing, complainant respectfully prays that
respondent be meted the penalty of DISMISSAL FROM THE SERVICE for being
guilty of gross immorality constituting Grave Misconduct and Conduct
Unbecoming of a Police Officer.
MARNELE M. LLOVIT-DETECIO
Complainant
3
VERIFICATION
That I read and understood its contents which are true and correct of my
personal knowledge and/or based on authentic records.
MARNELE M. LLOVIT-DETECIO
Affiant
NOTARY PUBLIC
Doc. No. _____
Page No. _____
Book No. _____
Series of 2020