Republic of the Philippines)

City of Manila )s.s.

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

COMPLAINT-AFFIDAVIT

I, JAENA KATE B. SICAT, of legal age, single, Filipino

and a resident of San Vicente, Santa Ignacia, Tarlac, under oath,
hereby depose and say, that:

1. I am a veteran rower of the National Dragon Boat Race

Women’s Division team under the Philippine Dragon Boat
Federation. As a veteran rower, I received numerous
achievements in my field, namely: two gold medals in the
2019 SEAG; 2019 Honorary Awardee (Dragon Boat
Category) from San Miguel Corporation-Philippine
Sportswriters Association (SMC-PSA) Annual Awards;
Athlete of the Year (2019) awarded by the Philippine
Sports Commission; and other awards and recognitions by
different sports associations. Copies of the said awards
and recognitions are hereto attached as ANNEX “A” with
series;

2. That the respondent JERWIN AGUINALDO is the

Head Coach of the National Dragon Boat Race Women’s
Division and the President of Philippine Dragon Boat
Federation, and a resident of 123 Makata St., San Lorenzo
Village, Makati City, where he may be served with
summons and other processes of this Honorable Court;

3. That the respondent MHEDY JOY VILOG is the author

of the news article “All is well for Pinay rowing team to
SEAG” of The Daily Bulletin with principal business
address at 2nd floor, Tamayo Arcade, Roces Ave., cor.,
Recolletos St., Intramuros, Manila, where she may be
 served with summons and other processes of this
Honorable Court;

4. That the respondent RONALYN ORPIANO is the

Sports Editor of The Daily Bulletin and a resident of 2nd
floor, Tamayo Arcade, Roces Ave., cor., Recolletos St.,
Intramuros, Manila, where she may be served with
summons and other processes of this Honorable Court;

5. That, on December 15, 2021, I received several calls and

messaged from my family, friends and colleagues,
informing me that a malicious article against me was
published in the December 15, 2021 issue of The Daily
Bulletin, a newspaper of considerable circulation within
the said City of Manila and throughout the Philippines.
They called my attention to the malicious imputations and
dishonorable acts in the said article against me, which
assassinated my character and good reputation. Excerpts
from the said article entitled: ALL IS WELL FOR
PINAY ROWING TEAM TO SEAG, is attached hereto
as ANNEX “B”, and hereby cited as follows --

“We were given before noon of 22 November to come

up with an explanation.” Aguinaldo, also the squad’s
head coach and technical director, said “Though we
complied, they didn’t give us any clear answer
whether we will go (to the SEA Games) or not. Good
thing when I personally approached task force head
Jason David, he told me that my explanation is
acceptable and we will all go to the SEA Games.”

Aguinaldo justified that Sicat was not

included in the line-up because of her poor showing in
their training, as reflected on her attendance sheet
and evaluation records.
 Also, the SEA Games and the organizing
committee of Vietnam decreased the number of
participants in the traditional dragon boat from 25
rowers two years ago to only 15 this year, leaving no
slot for 10 other outstanding paddlers, including the
dowdy 39-year old Sicat, arguably the oldest in the
group.”

6. Because of the article entitled: ALL IS WELL FOR

PINAY ROWING TEAM TO SEAG, published by the
herein respondents, I gain a lot of trolls and bashful
messages on my personal account. Copies of the said
bashful messages are attached hereto as ANNEX “C”;

7. True enough, said article published by respondents,

without observing the ethical standards of journalism,
contained malicious imputations with bad intentions and
unjustifiable motives, purposely to malign, dishonor,
discredit, insult and assassinate my character and good
reputation to the public as well as to my constituents;

8. That the respondents clearly exposed me to dishonor,

public contempt, discredit, and public ridicule;

9. The article written and published by respondents has no

factual basis, is highly speculative and was all false
statements made to destroy my reputation as a veteran
rower of the renowned RP Dragon boat team. That the
Respondent JERWIN AGUINALDO is motivated by
bad faith in uttering said defamatory statement in view of
our previous altercation that had happened during one of
our training where I, together with my other teammates,
questioned the trainings provided by the said respondent
as we were exposed to high intensity training for a period
of ten (10) hours a day, without time for us to recuperate
our strength;
 10. That in view of the defamatory statements made by
respondent JERWIN AGUINALDO and libelous article
written and edited by MHEDY JOY VILOG and
RONALYN ORPIANO, I am constrained to file this
criminal case against them for libel as defined in Article
353 of the Revised Penal Code, which expressly provides
that:

“ART. 353. Definition of liber. – A libel is a public

and malicious imputation of a crime, or of a vice
or defect, real or imaginary, or any act, omission,
condition, status, or circumstance tending to
cause the dishonor, discredit or contempt of a
natural or juridical person, or to blacken the
memory of one who is already dead.”

11. In the landmark case of Manila Bulletin Publishing

Corporation v. Domingo1, the Supreme Court held
that “for an imputation to be libelous under Art. 353 of the
Revised Penal Code, the following requisite must be
present: a) is must be defamatory; b) it must be malicious;
c) it must be given publicity and d) the victim must be
identifiable.”

12.It is clear that all the aforementioned elements of the

offense are present.

13.Due to the said malicious public imputations by

respondents, I suffered and continue to suffer serious
anxiety, besmirched reputation, mental anguish, sleepless
nights, not to mention the damage they have caused to my
career, reputation and honor among the readers and
patrons of The Daily Bulletin and the general public;

14. I am executing this Complaint-Affidavit to attest to the

truth and veracity of all the foregoing and to file a case

1
G.R. No. 170341, July 5, 2017.
 for LIBEL against JERWIN AGUINALDO, MHEDY
JOY VILOG and RONALYN ORPIANO.

I hereby execute this affidavit to attest to the truth of the

foregoing facts and hereby request the investigating prosecutor to
file the crime of Libel under the Revised Penal Code of the
Philippines against the herein Respondents.

IN WITNESS WHEREOF, I have hereunto set my hand

this 25th day of May 2022 in the City of Manila, Philippines

JAENA KATE B. SICAT

Affiant

SUBSCRIBED AND SWORN TO before me this 25 th day of

May 2022 in the City of Manila, Philippines, exhibiting to me her
Government issued Non-Professional Driver’s License no. C-
0123456.

Doc. No. 25;

Page No. 8
Book No. XV;
Series of 2022.
ANNEX “A”
ANNEX “A-1”
ANNEX “A-2”

ANNEX “B”
 ANNEX “C”

Annex C-1

Annex C-2

Annex C-3
Annex C-4

Annex C-5
 REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
Branch ___, Manila

PEOPLE OF THE PHILIPPINES,

Complainant,

— versus — INV. No. 22-00937

Crim Case No.
_____________
For: Libel

JERWIN AGUINALDO, MHEDY

JOY VILOG, RONALYN
ORPIANO,
Accused.
x---------------------------------------x

JUDICIAL AFFIDAVIT

I, JAENA KATE B. SICAT, of legal age, Filipino and a resident

of San Vicente, Santa Ignacia, Tarlac, having been duly sworn in
accordance with law, hereby depose and state:

This Judicial Affidavit has been prepared in English language and

fully understood by me;

I am answering the questions propounded by Atty. Kernell Sonny

Salazar at his office located at Salazar Duque Law Office, 69 Tower C
MPlace Condominium, Panay Ave., South Triangle, QC, fully conscious
that I do so under oath, that I may face criminal liability for false
testimony or perjury, and that my answers are based on my personal
knowledge and authentic documents;
 I respectfully submit herein my judicial affidavit in lieu of my
direct testimony in the above-captioned case;

The following are the questions asked of me and the answers I

gave him consecutively numbered to wit:

PURPOSES

This testimony of JAENA KATE B. SICAT is being offered as

support to prove the following:

a. To prove the material allegations in the Information; and

b. To testify on relevant matters related thereto;

JUDICIAL AFFIDAVIT PROPER

Q1: Do you know the accused in this case?

A1: Yes, they are JERWIN AGUINALDO, MHEDY JOY VILOG and
RONALYN ORPIANO.

Q2: How do you know them?

A2: JERWIN AGUINALDO is the Head Coach of the National Dragon

Boat Race Women’s Division and the President of Philippine Dragon
Boat Federation, while MHEDY JOY VILOG is the author of the
news article entitled “All is well for Pinay rowing team to SEAG” of
The Daily Bulletin and RONALYN ORPIANO is the Sports
Editor of The Daily Bulletin.

Q3: And what is your relationship with the accused, Jerwin

Aguinaldo?
A3: He is my Head Coach as I am a veteran rower of the National
Dragon Boat Race Women’s Division team under the Philippine
Dragon Boat Federation.

Q4: And as the rower of the National Dragon Boat Race

Women’s Division team, what can you say about your
performance?
A4: Well, I believe that I am doing great as I am awarded two gold
medals in the 2019 SEAG; 2019 Honorary Awardee (Dragon Boat
Category) from San Miguel Corporation-Philippine Sportswriters
Association (SMC-PSA) Annual Awards; Athlete of the Year (2019)
awarded by the Philippine Sports Commission; and other awards
and recognitions by different sports associations.

(Copies of the said awards and recognitions are hereto attached as

ANNEX “A” with series)

Q5: And how long have you been a rower in the National
Dragon Boat Race Women’s Division team?
A5: I’ve been a rower for around ten (10) years now.

Q6: Now, for the accused Jerwin Aguinaldo, what can you say
about his performance as a Head Coach?
A6: At first, he is really a great coach. But his method has changed
which cause the team great suffering as he is employing high intensity
training which is really not suitable for the team as we believe that it will
result to poor performance during the competition.

Q7: Why did you say that it will result to the poor
performance of the team?
A7: Because he is subjecting us to high intensity training for over 10
hours without rest.

Q8: And when your Head Coach Aguinaldo is subjecting you

to that training method, what happened next, if any?
A8: I together with my team had an open forum with our coach where
we relay our sentiments on the training regime and told him that the
training schedule provided by the Fitness and Nutrition Department
should prevail.

Q9: And when you confronted such with your Head Coach,
what happened next, if any?
A9: He just burst out and continued shouting at us. Then he pointed at
me and said, “Wag kang makialam ako ang coach dito. Mga wala
kayong kwenta.”
Q10: And after such incident, what transpired next, if any?
A10: After that, the team just let it past. Then here comes the line-up for
the SEAG, and I found out that I was not included in the list.

Q11: And when you found out that you are not included in the
list, what happened next?
A11: I confronted Aguinaldo and asked him for the reason on why I am
not included in the list, and he just said “Wala kang pake”.

Q12: And when he said that to you, what did you do, if any?
A12: I said that he is being unprofessional to me and that it is
unreasonable for the team if I am not included as I am the reason why
we have gold medals last season.

Q13: And when you said that to him, what happened next?
A13: Nothing. My sentiments fell on deaf ears.

Q14: And after that, what happened next?

A14: on December 15, 2021, I received several calls and messaged from
my family, friends and colleagues, informing me that a malicious article
against me was published in the December 15, 2021 issue of The Daily
Bulletin.

Q15: And what is the article all about?

A15: The article is entitled: All is Well for Pinay Rowing Team to SEAG.
It contains malicious imputations and dishonorable acts in the said
article against me, which assassinated my character and good
reputation. The article said that I have poor showing in training,
which is clearly erroneous.

(Copy of the said article is attached hereto as ANNEX “B”)

Q16: And when you learned about this article, what transpired
next?
A16: After that, I received numerous bashers and they messaged me to
the point that I do not want to go out of my house.

(Copies of the bash messages are attached hereto as ANNEX “C”)

Q17: And what transpired next, if any?
A17: My self-esteem completely became low and I suffered serious
anxiety, besmirched reputation, mental anguish, and sleepless
nights.

Q18: And after that, what happened next?

A18: I confronted my Head Coach and asked him to retract that
statement but again, he disregard me. And that is why I am filing this
case of Libel.

Q19: I have nothing further, anything you want to say before

we conclude the process?
A19: Nothing more Atty.

IN WITNESS WHEREOF, I have hereunto set my hand this 25 th day

of May 2022, hereat the City of Manila.

JAENA KATE B. SICAT

Affiant

SUBSCRIBED AND SWORN to before me this 25th day of May

2022 by Jaena Kate B. Sicat who exhibited to me her Non-Professional
Driver’s License No. C-0123456 bearing her pictures and signature
thereon and he acknowledged to me that he executed the foregoing
Judicial Affidavit of his own free will.

WITNESS MY HAND AND SEAL OF OFFICE

Doc No. 29;

Page No. 6;
Book No. XV ;
Series of 2022.
 ATTESTATION

I, ATTY. KERNELL SONNY J. SALAZAR, of legal age, Filipino,

and with the office address at Salazar Duque Law Office, 69 Tower C
MPlace Condominium, Panay Ave., South Triangle, QC, under oath and
state that:

1. I conducted the examination of witness JAENA KATE B.

SICAT, on 25 May 2022 in connection with the above-
mentioned case.

2. I faithfully recorded or caused to be recorded the

questions that I asked and the answers that the witness
gave as stated in her Judicial Affidavit.

3. Neither I nor any other person present or assisting the

witness coached her regarding her answer stated in her
Judicial Affidavit.

ATTY. KERNELL SONNY J. SALAZAR

Affiant

SUBCRIBED AND SWORN to before me this May 25, 2022 at

City of Manila. I have identified the affiant through his driver’s license,
License No. N31-22-516239, Issued on April 10, 2018, LTO Manila.

Doc No. 30;

Page No. 6;
Book No. XV ;
Series of 2022.

ANNEX “A”
ANNEX “A-1”
ANNEX “A-2”

ANNEX “B”
ANNEX “C”
Annex C-1

Annex C-2

Annex C-3

Annex C-4
Annex C-5