COMPLAINT AFFIDAVIT for Murder (Sample)

Republic of the Philippines
Province of Agusan del Norte,
City Butuan, S.S.

COMPLAINT AFFIDAVIT

I, Roberto Nores, Filipino, 65, male, single, and a resident of Lopez Jaina Street, Butuan City, Philippines, after being sworn to in accordance with law, depose and state:

1. Defendant Carles Renso, is my driver residing at Agao, Butuan City, Philippines;
2. That, at around 10:00 in the evening of August 8, 2017, after dinner, my driver arrived at our house;
3. That, he saw my wife, Cecilia Nores in the kitchen washing the dishes, the kitchen being at least 5 feet from the dining table;
4. Without provocation, the defendant pulled a knife from the sink and proceeded to stab my wife with it.
5. That, upon seeing what my driver did, rushed to my wife’s aid and called the hospital;
6. That, upon seeing that I was approaching he left immediately without even saying anything;
7. Upon calling for medical assistance and reaching the hospital, my wife was dead on arrival because of severe blood loss from the stabbing;
8. After attending to my wife, I reported the said incident to the nearest police station. A true and faithful machine copy of the police report is hereby attached here as “Annex A”;
9. I am therefore executing this Complaint-Affidavit against my driver Carles Renso who may be served with subpoena and other processes of this Honorable Office at his residence at Agao, Butuan City, Philippines;

RELIEF

WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable Court that, after hearing, judgment be rendered ordering the defendant:

12. To pay moral damages
13. To pay the plaintiff the cost of the suit;
14. Such other relief as the court may deem proper.

City of Butuan, August 11, 2017.

Felixberto Guiritan LAW OFFICE
Counsel for the Plaintiff
Unit 123, Victoria Tower I
Villanueva Street, Butuan

By:

G-one T. Paisones
Roll of Attorney No. 198631
IBP No. 12345/2-5-12/Butuan
PTR No. 87654/12-22-11/Butuan