criminal complaint

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 de V era, Kri s t in a C . July 21, 2 015 4 t h  Y ear Law REPUBLIC OF THE PHILIPPINES DEPARTMENT OF JUSTICE OFFICE OF THE PROSECUTOR LAGUNA THE PE PLE ! THE PH"L"PP"#E$, C%&'lainant, ()ersus(  *++used, P* L . * VEL "# and EL- *. EE /((((((((((((((((((((((((((((((((((((((((((((/ CRIMINAL COMPLAINT AFFIDA VIT ", J%&ar C. C%r)ite, the undersi ned, % leal ae, and a resident % 1051 -end%3a $treet, Cr%ssin, Cala&a Launa, a++uses Paul . *)elin% and El&%  *. ee % the +ri &e % % ery , +%&&itted as %ll%ws6 1. *t ar%u nd 1060 0 P- % $at urda y , #%) e&er 7, 2014, ", J%&a r C%r) ite was at the st%re in Cr%ssin Cala&a Launa. 2. 8hi le " and s%&e % &y +rew s were usy te nderin inside, tw% ar&ed &en waled in and 'retended t% e +ust%&ers went at the +%unter and de+lared h%ld(u' while %ne re&ained %utside as a l%% %ut. 9. That %ne % the ar&ed &an 'r% +e ede d t% &y tale and %rd er ed &e t% %'en the )ault. 4. es 'ite % te rri le ear th at the &an w %uld sh %t &e, " dei ed hi& and di d n%t %'en the )ault. 5. *s a res ult, a +%&&%ti% n +r%'' ed u' as he '%i nted th e un %n &e and +%&&anded &e t% d% what he say :. Tha t u'%n heari n the &an +%&&a ndi n &e anrily , the tw% %the r +ul'ri t +a&e in aid % the %ther. ;. Tha t &aye e +au se % twis t % lu+, %n e % &y +rews had the +h an+e t% % %ut % the st%re t% as %r hel'. H%we)er, u'%n n%ti+in the es+a'e % -i+hael, %ne i&&ediat ely tie d &e u' while the tw% %thers %r+eu lly %'ened the )ault and su++eeded sei3in the &%ney. 7. That the tw% &en, as " re&e&ered, were %t h weari n %nnets and  <a+ets= the &an wh% waled in r%nt % &y tale was wearin a lue  <a+et and &a%n 'ants while the &an wh% uarded >lan+a da was wearin a la+ <a+et and a la+ +a'.

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de Vera, Kristina C.July 21, 20154th Year Law

REPUBLIC OF THE PHILIPPINESDEPARTMENT OF JUSTICEOFFICE OF THE PROSECUTOR LAGUNA

THE PEOPLE OF THE PHILIPPINES,Complainant,

-versus- Accused, PAUL O. AVELINO and ELMO A. DEE

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

CRIMINAL COMPLAINT AFFIDAVIT

I, Jomark C. Corvite, the undersigned, of legal age, and a resident of 1051 Mendoza Street, Crossing, Calamba Laguna, accuses Paul O. Avelino and Elmo A. Dee of the crime of Robbery, committed as follows:

1. At around 10:00 PM of Saturday, November 8, 2014, I, Jomark Corvite was at the store in Crossing Calamba Laguna.

2. While I and some of my crews were busy tendering inside, two armed men walked in and pretended to be customers went at the counter and declared hold-up while one remained outside as a look out.

3. That one of the armed man proceeded to my table and ordered me to open the vault.

4. Despite of terrible fear that the man would shot me, I defied him and did not open the vault.

5. As a result, a commotion cropped up as he pointed the gun on me and commanded me to do what he say

6. That upon hearing the man commanding me angrily, the two other culprit came in aid of the other.

7. That maybe because of twist of luck, one of my crews had the chance to go out of the store to ask for help. However, upon noticing the escape of Michael, one immediately tied me up while the two others forcefully opened the vault and succeeded seizing the money.

8. That the two men, as I remembered, were both wearing bonnets and jackets; the man who walked in front of my table was wearing a blue jacket and maong pants while the man who guarded Blancada was wearing a black jacket and a black cap.

9. That they used a blue Yamaha motorcycle and instead of a plate number, a plate with the words for registration was visible from the back.

10. Both men are of normal built, appeared to be kayumanggi or brown-skinned and of average height.

11. That immediately after Blancada went back to the store and untied me. We instantaneously reported the incident to the authorities where I narrated everything.

12. After about an hour in the police station, there were two policemen, later on identified as PO2 Miguel Sumaya and PO2 Philip Castillo who were accompanying two men who appeared to be the men who robbed the store.

13. Later on, I positively identified the two men as those who were in the motorcycle because of the black cap, the blue and black jackets that they wear respectively.

14. That the cash that was stolen from me with force and intimidation was with PO2 Castillo who alleged that he got the same during the apprehension that they did. All money earned that day is still intact.

15. That all these stated herein are true and were stated freely without any force or intimidation done against me.

16. To attest to the truthfulness of the foregoing, I, Jomark C. Corvite, complainant, attaches my signature below.

_________________________Jomark C. CorviteComplainant

SUBSCRIBED AND SWORN to before me, in the city of Calamba, this 9th day of November, 2014, the affiant exhibiting to me his Passport issued by Department of Foreign Affairs Manila on 15th of April 2012 at Roxas Blvd, Manila.

___________________________ Assistant City Prosecutor