Complaint Affidavit

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Republic of the Philippines)

Province of Cagayan ) S.S.
City of Tuguegarao )
AFFIDAVIT-COMPLAINT
I, MELECIO B. PASCUA, of legal age, Filipino citizen and residing at Brgy.

Liwan Sur, Enrile, Cagayan, after first having been duly sworn to in accordance with
law depose and say:
1. I am the owner of a parcel of land located at Brgy. Liwan Sur, Enrile, Cagayan
as shown by the 27 June 2005 Order which was issued by the Department of
Environment and Natural Resources (DENR), Regional Office No. 2 in the case
of “Brgy. Council of Liwan Sur, Enrile, Cagayan et al. vs. Apolonio Domingo et
al.”;
2. Prior to the issuance of the aforesaid Order, we have long been exercising
dominical and possessory rights over the same parcel of land in a manner that
is open, continuous, exclusive, adverse and in the concept of owners up to the
present time;
3. On November 15, 2015 at about 11 o’clock in the morning, I was in the

company of my son Rogeric Pascua and my caretaker Gerry Dangiw of Kalinga.
The three of us went to visit the portion of my above-mentioned parcel of land
which is devoted to cornfield situated specifically at Sitio Cavuluan, Brgy. Liwan
Sur, Enrile, Cagayan;
4. Upon reaching the cornfield, I and my companions saw Apolonio Domingo Sr.,
Mariano Domingo, Joshua Domingo Beredo, Banny Marcelino, Jr., Banny
Marcelino, Sr., Rey Marcelino, Rodolfo De La Cruz, Jr., Totoy Domingo, Doming
Domingo, David Sibayan, Maria Sibayan, Rafael Domingo, Jr., Manny
Madamba who are all residing at Brgy. Liwan Sur, Enrile, Cagayan and a
certain Oliver Layugan of Brgy. Bakras, Tabuk, Kalinga and other identified
persons from Kalinga inside the premises of our said parcel of land;
5. I and my companions were shocked at what we saw when the group led by
Apolonio Domingo, Sr. were in the process of uprooting and/or detaching the
barbwires, bamboos and wooden posts that were installed and used as fence for
my said parcel of land. In fact, some of the barbwires, bamboos and wooden
posts were already removed and/or detached at the time when we arrived on
the said place;
6. As the group of Apolonio Domingo, Sr. could easily overpower the three of us
considering that they outnumber us and the fact that this is not the first time
that they have forcibly entered the premises of my parcel of land and unlawfully
destroyed/detached/carried/removed and took my barbwires, bamboos and
wooden posts, I and my companions immediately decided to proceed at the
house of Chief Tanod Loreto Peralta and Brgy. Kagawad Jesus Pasicolan both of
Brgy. Liwan Sur, Enrile, Cagayan in order to report the incident and likewise to
ask assistance from them to talk with the group of Apolonio Domingo, Sr.;
7. My son Rogerick Pascua, my caretaker Gerry Dangiw, barangay officials Loreto

Peralta and Jesus Pasicolan and I proceeded at the place of our parcel of land
where Apolonio Domingo, Sr. and his group were
uprooting/detaching/removing the barbwires, bamboos and wooden posts used
as fence thereof. Upon reaching the place, my companions and I including the
two barangay officials decided, however, not to talk with Apolonio Domingo, Sr.
and his group for fear that they might inflict bodily harm to us;
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8. At about 4:30 o’clock in the afternoon of November 15, 2015 at Brgy. Liwan
Sur, Enrile, Cagayan, my companions and I saw Apolonio Domingo, Sr. and his
group brought and carried with them the barbwires, bamboos and wooden
posts which they all unlawfully detached, removed and took from my cornfield
located at Sitio Cavuluan, Brgy. Liwan Sur, Enrile, Cagayan;
9. I am attaching a copy of the 16 November 2015 Certification issued by the PNP

Enrile Police Station, hereto attached as ANNEX “A”, showing that the incident
that transpired on November 15, 2015 at Brgy. Liwan Sur, Enrile, Cagayan was
duly reported with the police authorities. I am likewise attaching machine copy
of pictures that were taken after the incident that transpired on the date and
place aforementioned as “ANNEX “B” and sub-markings; and
10.I have executed this affidavit-complaint freely, voluntarily and intelligently to

attest to the truth of the foregoing and for the purpose of initiating the proper
criminal complaint against Apolonio Domingo Sr., Mariano Domingo, Joshua
Domingo Beredo, Banny Marcelino, Jr., Banny Marcelino, Sr., Rey Marcelino,
Rodolfo De La Cruz, Jr., Totoy Domingo, Doming Domingo, David Sibayan,
Maria Sibayan, Rafael Domingo, Jr., Manny Madamba who are all residing at
Brgy. Liwan Sur, Enrile, Cagayan and a certain Oliver Layugan of Brgy. Bakras,
Tabuk, Kalinga and other identified persons from Kalinga.
IN WITNESS WHEREOF, I have hereunto set forth my hand this 23 rd day of

November 2015 in Tuguegarao City, Cagayan.
MELECIO B. PASCUA
Affiant-Complainant
DILG ID No. 0202-14-003
SUBSCRIBED AND SWORN to before me this 23 rd day of November 2015 in

Tuguegarao City, Cagayan.
Doc. No.
Page No.
Book No.
Series of 2015
CERTIFICATION
I hereby certify that I have examined personally the affiant who professed
having understood the content of his affidavit-complaint to be true and correct of his
own personal knowledge and based on authentic documents and had manifested
having executed the foregoing freely, voluntarily and intelligently.
ATTY. VICTOR R. SALUD

Complaint Affidavit

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Republic of the Philippines)

I, MELECIO B. PASCUA, of legal age, Filipino citizen and residing at Brgy.

3. On November 15, 2015 at about 11 o’clock in the morning, I was in the

7. My son Rogerick Pascua, my caretaker Gerry Dangiw, barangay officials Loreto

9. I am attaching a copy of the 16 November 2015 Certification issued by the PNP

10.I have executed this affidavit-complaint freely, voluntarily and intelligently to

IN WITNESS WHEREOF, I have hereunto set forth my hand this 23 rd day of

SUBSCRIBED AND SWORN to before me this 23 rd day of November 2015 in

ATTY. VICTOR R. SALUD

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