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Republic of the Philippines
Regional Trial Court

5th Judicial Region
Branch No. 25, Naga City
People of the Philippines , Criminal Case no. 18-1128

Plaintiffs,
vs. for
ARMANDO ENCHANDE, PARRICIDE

Accused,
x—-----------------------------x
COMPLAINT
The undersigned investigator of Patrolwoman of Calabanga Municipal office,

accuses ARMANDO ECHANDE of PARRICIDE penalized under Article 246 of the
Revised Penal Code committed as follow:
That on or about the 2nd day of March 2024 in the City of NAGA, Philippines,
and within the jurisdiction of this Honorable Court, the above-named accused, being
then armed with a knife weapon, with intent to kill, qualified by attack his wife and
evident premeditation, abuse of superior strength, did then and there, willfully,
unlawfully and feloniously attack, assault and, with the use of said knife weapon,
thereby inflicting upon the latter stab wounds in the different parts of her body
which caused his instantaneous death.
Contrary to law, Calabanga Camarines Sur, Philippines, March 2, 2024.
Pat. Hazel S Ollita

Investigator-on-case
SUBSCRIBED AND SWORN before me this 7th day of March 2024 in Calabanga,
Camarines Sur, Philippines.
Zamiel Concepcion
JUDGE
Republic of the Philippines……….…..)
Province of Camarines Sur…………...) S.S
Municipality of San Fernando….)
x—---------------------------------------x
AFFIDAVIT OF DESISTANCE
I, Marga Morteza, of legal age, single, a resident of Zone 5 Salvacion Baybay

Calabanga Camarines Sur after having duly sworn accordance with law hereby
depose and state:
That, I am the Complaining witness in the criminal case for PARRICIDE

against Armando Enchande in the case entitled “ People of the Philippines versus
Armando Enchande”, Criminal Case No. 18-1128, Regional Trial Court, Branch No.
25, Naga City.
That, After several conferences with the accused. I hereby declare that I am
continouosly interested in the pursuit of the said case against the accused Armando
Enchande, because he used knife as weapon and without hesitation he kill his wife.
That, I am not desisting or withdrawing my complaint against the accused

Armando Enchande, in prosecuting the above mentioned case.
That, I hereby inform the City Prosecutor of Naga that I not withdrawing my
complaint for PARRIDE in the Criminal Case No. 18-1128 entitled “ People of the
Philippines versus Armando Enchande”, Regional Trial Court, Branch No. 25, Naga
City.
That, I likewise request the Regional Trial Court, Branch no. 25, Naga City to
not release the accused from any and all criminal liabilities and waived any right of
action against the accused in connection with above case.
IN WITNESS WHEREOF, I hereby set my hand this 28th day of March 2024
at Calabanga Camarines Sur, Philippines.
Marga Morteza
Complaining Witness
SUBSCRIBED AND SWORN to before me this 9th day of March 2024 at
San Fernando Camarines Sur, Philippines.
Atty. Nathaniel Riego

Prosecutor
Republic of the Philippines………….……....)
Province of Camarines Sur…………………..) S.S
MUNICIPALITY OF CALABANGA……….....)
x—---------------------------------------------x
AFFIDAVIT OF LOSS
I, HAZEL S OLLITA, of legal age, Filipino citizen, married, and a

residence of Barangay Takulod Calabanga, Camarines Sur, after been sworn to in
accordance with law hereby deposes and states the following:
That, I am the owner of a black wallet which contains the following

identification card: my Driver’s license, 2x2 ID photos, ATM card, National ID and
PhilHealth ID.
That, on or about 4:45 PM February 25, 2024, while I was travelling going to
Sabang Calabanga, Camarines Sur driving my motorcycle and while about to reach
the said area, I noticed that my wallet is missing
That, I immediately went back the place where I passed by to search for my
wallet.
That despite diligent search of efforts to locate the above-mentioned item. I

could no longer find the same, such that I now believe that it is lost beyond
recovery.
That, I am executing this Affidavit of loss to attest to the truth of the

foregoig and for whatever legal purposes it may serve.
IN WITNESS WHEREOF, I have hereunto set my hand on the 25th day of

February 2024, at Calabanga Camarines Sur, Philippines.
Hazel S. Ollita
Affiant
SUBSCRIBED AND SWORN to before me this 7th day of March 2024 at

San Fernando, Camarines Sur, Philippines.
Atty. Nathaniel Riego

Prosecution

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Republic of the Philippines

Regional Trial Court

People of the Philippines , Criminal Case no. 18-1128

ARMANDO ENCHANDE, PARRICIDE

The undersigned investigator of Patrolwoman of Calabanga Municipal office,

Contrary to law, Calabanga Camarines Sur, Philippines, March 2, 2024.

Pat. Hazel S Ollita

I, Marga Morteza, of legal age, single, a resident of Zone 5 Salvacion Baybay

That, I am the Complaining witness in the criminal case for PARRICIDE

That, I am not desisting or withdrawing my complaint against the accused

Atty. Nathaniel Riego

I, HAZEL S OLLITA, of legal age, Filipino citizen, married, and a

That, I am the owner of a black wallet which contains the following

That despite diligent search of efforts to locate the above-mentioned item. I

That, I am executing this Affidavit of loss to attest to the truth of the

IN WITNESS WHEREOF, I have hereunto set my hand on the 25th day of

SUBSCRIBED AND SWORN to before me this 7th day of March 2024 at

Atty. Nathaniel Riego

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