REPUBLIC OF THE PHILIPPINES)

MAKATI CITY, MANILA ) S.S

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

COMPLAINT-AFFIDAVIT

I, ALEJANDRO DIASES, of legal age, Filipino, residing at Block 1 Soliven Avenue,

Kalawaan, Brgy. Pembo, Makati City, after having sworn in accordance with the law, depose and
state that:

1. I am executing this Complaint-Affidavit to charge JAKE REYES y CRUZ, aka “JR”,

Filipino, of legal age, residing at Block 6 Soliven Avenue, Kalawaan, Barangay Pembo,
Makati City, of Attempted Murder in violation of Article 248 in relation to Article 6 of the
Revised Penal Code (RPC).

2. That JR and I have known each other since 2001 as we are living in the same barangay in
Northern Samar. It is in 2015 when we decided to go to Manila, together with our families
and resided in our present addresses stated herein. We had been in good terms not until 7
September 2020.

3. On the said date, as I was on my way home from work, I saw JR and his then girlfriend
and my churchmate Kate Roces (Kate). The two were having an argument as they were
both shouting as I was about to pass by. As their argument heated up and JR was about to
hit Kate, I went between them to stop him. JR was pissed, pushed me to the ground and
dragged Kate away. He then shouted “WAG KANG PAKELAMERO, GAGO KA!”.

4. I didn’t know what caused their argument until a few days after or on 14 September 2020
when we had a church meeting at my residence. Kate was present therein and she told me
that they already broken up. However, even before our meeting was over, JR showed up
and violently dragged Kate out of the house telling her that he was bringing her home. He
was mad about Kate being at my house.

5. The following day, 15 September 2020, Totie Marie owner of the sari-sari store in front
my house stated in her affidavit 1 that JR arrived at her store at around 11:30 AM and
immediately bought 1 liter bottle of red horse beer. He stayed there for a couple of hours
consuming 2 more bottles of beer. During his stay, he became violent and rude to other

1 ANNEX “B”.
 buyers. At one point he uttered “Tangi@#@ and tagal naman lumabas neto”. Totie Marie
asked who was he waiting for but she did not get a response.

6. At around 5:30 PM, on the same date, I went out to go to Paolo Tolentino’s (Paolo) house,
my neighbor to play sungka.
His back was facing the door pero when JR stormed in the
house he knows na he appered intoxicated?
7. At around 6:00 PM while I was playing, with my back facing the entrance door of Paolo’s
house, JR stormed in the house of Paolo, appearing to be intoxicated from alcohol, bringing
with him an ice pick. He then swung his ice pick hitting me twice at the upper right part of
my back and shouted “GAGO KA! PUTA@#@(#! SINULOT MO SYOTA KO!”. I then
stood up, faced JR and while trying to disarm him he then swung his weapon once again
hitting me at the right part of my chest. He continued hitting me with his ice pick while
blocking it with my arms. I'm not entirely sure but is this physically possible na 3x na siyang
nasaksak ng ice pick (on the same side) and he was able to stand up and
block the succeeding stabs with his arms?
8. When June Lima (June) and Nico Cruz (Nico) arrived, they saw JR continuously swinging
his ice pick. When Nico and June tried to stop JR, he then immediately run out of the house
and fled the scene. When did June and Nico arrive? How long was JR swinging his ice pick
at Alejandro before they arrived?

9. I was immediately brought by June, Nico and Paolo to Ospital ng Makati to be treated for
the wounds that I have suffered.

10. After which, I immediately went straight to the barangay to report the incident. A Barangay
Incident Report/Event Report2 was prepared by Kagawad Lusito Macadangdang signifying
that such incident transpired on 15 September 2020. A certificate was also issued by the
Barangay showing the incident of the attack. 3

11. On 16 September 2020, I submitted myself for examination and procured a Certificate of
Medico Legal4 attached in this affidavit. He was brought to the hospital on the night of Sept 15 but only
submitted himself for examination and got a medico legal
report the next day?
12. In order to support this complaint, attached herein are the affidavits of Kate Roces, 5 Totie
Marie Hernandez,6 Paolo Tolentino,7 Nico Cruz8 and June Lima. 9

2 Annex “A”
3 Annex “H”
4 Annex “C”
5 Annex “D”
6 Annex “B”
7 Annex “E”
8 Annex “F”
9 Annex “G”
There was no proof that JR had the ice pick at the time he was drinking at Totie Marie's store. He could have
been drunk and saw the ice pick there then dahil lasing, nagdilim paningin and went to JR. Murder needs evident
premeditation diba. When he said na "ang tagal naman neto" that's not enough proof na balak nyang patayin si
Alejandro, he could've went there to confront him lang, though treacherous dahil sa nakatalikod sinaksak, but
still, baka makalusot hahaha
13. The acts of JR clearly shows the intent to kill and without justiciable motive. JR who was
armed with an ice pick then and there willfully, unlawfully and feloniously attacked, and
stabbed me with an ice pick, and inflicting injuries which would ordinarily cause my death.

14. Thus, by virtue of this Complaint-Affidavit it is most respectfully prayed that a criminal
complaint be filed against JAKE REYES y CRUZ, aka “JR” for Attempted Murder,
contrary to Article 248 in relation to Article 6 of the Revised Penal Code.

15. I confirm that I fully understood all the foregoing and that I voluntarily and knowingly
executed this Complaint-Affidavit based on my own personal knowledge and authentic
records.

The affiant has nothing more to say.

SUBSCRIBED AND SWORN to before me this 21th day of September in the Makati City, affiant
exhibiting to me his Driver’s License No. 54321 issued by the Land Transportation Office on April
8, 2019 at Makati City.

ATTY. KING CHUA

Notary Public
Commission Expires Dec. 15, 2020
Roll of Attorney No. 12345
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila

Doc. No. _______;

Page No. _______;
Book No. _______;
Series of 2020
ANNEX A
 OFFICE OF THE PUNONG BARANGAY
Brgy. Pembo, Makati City

BARANGAY INCIDENT/EVENT REPORT

On 15 September 2020, at 8:00 PM, Brgy. Pembo, Makati City, one Alejandro Diases y Guillas
22 years old, student, native of Northern Samar, presently residing of Block 1 Soliven Avenue,
Kalawaan, Brgy. Pembo, Makati City, personally appeared to this barangay station and report the
failed stabbing incident against him that transpired on Kalyeng Ligas, JP Rizal, Brgy. Pembo,
Makati City at about 6:00 PM. The alleged perpetrator is identified as one JAKE REYES y CRUZ,
aka “JR”, 22 years old, single, laborer, a native of Northern Samar, and presently residing at Block
6 Soliven Avenue, Kalawaan, Brgy. Pembo, Makati City. According to Diases, he was playing
sungka with a neighbor when he and all the bystanders heard Reyes saying, GAGO KA!
PUTA@#@(#! SINULOT MO SYOTA KO!‟ and after that he stabbed the victim and fled.
Miraculously, Diases sustained only scratches and bruises because of the incident.
Sabi nya he was stabbed at the back 2x, tapos sa
right chest once, then he protected himself with his
Not good with places at hindi ko mahanap sa arms, pero scratches and bruises lang?
mapa. Di ko sure if may ganitong address, kung
meron man, magkalapit ba ang Soliven Avenue, Prepared by:
Kalawaan and Kalyeng Ligas JP Rizal? Kasi sa
complaint kapitbahay ni Alejandro si Paolo?
LUISITO MACADANGDANG
Barangay Kagawad on-duty

ANNEX B
Republic of the Philippines )
Makati City) s.s.
x- - - - - - - - - - - - - - - - - - - - - -x

AFFIDAVIT OF WITNESS

I, TOTIE MARIE HERNANDEZ, 37 years of age, single, resident of Block 3 Lot 2 Soliven
Avenue, Kalawaan, Brgy. Pembo, Makati City, after having sworn in accordance with law, do
hereby depose and state THAT:

1. I am the registered owner of "Totie's Tindahan", a sari-sari store located at Block 3 Lot 2
Soliven Avenue, Kalawaan, Brgy. Pembo, Makati City;

2. On Sept. 15, 2020, at around 11:30am, the accused Jake Reyes y Cruz, more commonly
known in the area as JR, arrived in my sari-sari store and ordered 3 bottles of red horse and
sat down on my bench to drink the same;

3. it appears at the time that he was waiting for someone from the Guillas' residence, which
was across the street from my sari-sari store; How can Totie Marie say na someone from Guillas ang
inaantay? Sabi sa complaint di nya alam?

4. At around 12:30pm I went inside my house, which was connected to my sari-sari store, to
cook and eat lunch with my a cousin who lives with me;

5. When I came back the sari-sari store at around 1:15pm, JR was still there but this time
pacing back and forth in what appears like an agitated mood, which I thought was brought
about by the alcohol he drank; If you stopped drinking from 1:15 to 4:30pm, wala ka na masyadong amats
nun diba?
6. At around 4:30pm he again ordered a bottle of red horse and I asked him, "oh iinom ka
nanaman? Hindi ba may pasok ka dapat ngayon?" to which he replied, "Te Totie yung
order ko ho pakibigay nalang mag babayad naman ako oh!" I then agreed to give his drink
but told him, "oh sige bahala ka, siguraduhin mo lang makakauwi ka mag isa.";

7. At around 5:30pm, I heard the gate to the Guillas' residence open and saw Alejandro
Guillas walking out and around eight (2) minutes later JR followed; Ilang minutes talaga?

8. By 6:50pm while watching Raffy Tulfo Action from my phone, a suki came to the store to
buy corned beef and told me, "Te narinig mo yung sigawan kanina? May saksakan pala sa
kanto. Si JR daw sinaksak si Alejandro, duguan daw sabi ni aling bebang eh." To which I
replied, "huh?! Eh nandito lang si JR kanina ah. Sigurado ka ba? Ano na daw nangyare?
Nahuli na ba? Asan na si Alejandro?" And I was told, "ewan ko lang ho, yun lang narinig
ko kay aling bebang eh, sige ho uuwi muna ako daan nalang po ako bukas pag may nalaman
ako." Kanto lang ng Kalawaan yung Kalyeng Ligas? Almost 1 1/2 hr bago nangyari yung saksakan so
medyo malayo yung bahay or JR waited 1 1/2 hr before doing the stabbing?

9. At around 8:30PM when I was closing my store I saw the Guillas' family car arrive and
Alejandro being assisted by his father inside their house. Sabi ni Alejandro, after the stabbing, he was
bought by June and Nico to Ospital ng Makati,
6pm yung saksakan daw. Again, what time did
June and Nico arrive and what time was he
bought to the hospital? Tapos nagpunta pa
brgy. Sabihin na natin 6:30 sya nadala ospital.
Parang kulang yung time na nakauwi na sya?
 AFFIANT SAYETH NAUGHT.

IN WITNESS WHEREOF, I hereunto affixed my signature this 21st day of September, 2020
at Makati City.

TOTIE MARIE HERNANDEZ

Affiant

SUBSCRIBED AND SWORN to before me this 21st Day of September, 2020 at Makati City.
I HEREBY CERTIFY that I have personally examined the herein affiant and I am satisfied that he
voluntarily executed and understood his given affidavit.

ATTY. CHRISTIAN DELOS SANTOS

Notary Public

Commission Expires
February 18, 2022
Roll of Attorney No. 67899
IBP No. 67899/5-17-12/Manila
PTR No. 55273/08-15-14/Manila

ANNEX C
 OSPITAL NG MAKATI
MAKATI CITY
16 September 2020

MEDICAL CERTIFICATE
FOR MEDICO-LEGAL CASES

TO WHOM IT MAY CONCERN:

This is to certify that Alejandro Diases, 22 years old, male residing at Block 1 Soliven
Avenue, Kalawaan, Brgy. Pembo Makati City was examined on this hospital on 16 Septmeber
2020 with the following findings:

• Upper right back Sabi sa Barangay the night

before, scratches and bruises
o Incision: length approx. 5.2cm, 1cm deep
lang (na dapat hindi at dapat
obvious if he was stabbed 2x
• Left chest sa right back adn right chest)..
o Incision: length approx. 3.4cm, .6 cm deep Sa ospital the next day he had
incisions na.

• Right arm // Left arm

o Scratches: length approx. 6.4cm, 2cm // .8cm, 4cm

• Contusions, upper left arm 2 diameters – left chest, 3 diameters

xxx

Patient was: ( ) ADMITTED (x) NOT ADMITTED

HEALING PERIOD GIVEN BELOW SUBJECT TO THE FOLLOWING:

( ) X-RAY EXAM. Taken and official results, NOT YET AVAILABLE, may change duration of healing period

( ) Referral to ___________________ specialist made, findings of which are not yet available but may change
duration of healing period

HEALING PERIOD xxxx ( ) TO xxx ( )

Barring complications

KATRINA MAE SANTOS, MD

License no: 24528-732
ANNEX D

Republic of the Philippines )

____________, ________ ) s.s.
x- - - - - - - - - - - - - - - - - - - - - -x

AFFIDAVIT OF WITNESS

I, Kate Roces, 25 years old age, single, resident of Block 3 Soliven Avenue, Kalawaan, Brgy.
Pembo, Makati City, after having sworn in accordance with law, do hereby depose and state
THAT:

1. I can personally attest that accused, JAKE REYES y CRUZ, aka “JR”, committed the
crime of Attempted Murder in violation of Article 248 in relation to Article 6 of the Revised
Penal Code (RPC).
2. Jake Reyes was introduced to me by my mom Rosana Roces last December 2019. Since
then, we started hanging out and spent most of our time together. Last June 12, 2020, we
decided to make things official. I loved JR because he would always show me utmost
attention, but sometimes, it can go way beyond limits.
3. JR is the jealous type of boyfriend. He would check my inbox and misinterpret friendly
conversations with my friends and work mates. I thought I could tolerate this type of
attitude but the more I remain silent, the more he creates a toxic relationship for me.
4. I’ve been giving him signals that I wanted to end things with him since last month. Finally,
I got the courage to break up with him last September 7, 2020 because he had me at my
best and I had him at his worst. He did not take the break up lightly so he started shouting
at me in the middle of the road. He uttered words like: "Hoy, babaeng sinungaling!
Walanghiya kang malandi kang haliparot ka." He was about to hit me on the face, luckily,
Alejandro Diases came to the rescue.
5. JR was pissed, pushed Alejandro to the ground and dragged me away. He then shouted at
Alejando saying, “WAG KANG PAKELAMERO, GAGO KA!”.
6. Alejandro was my church mate. We were on the same bible study group. We would meet
once or twice a week with our church group for either hanging out or life sharing. Last
September 14, 2020, we had a church meeting in Alejandro’s house. Suddenly, JR texted
me saying he would pick me up. We had a few exchanges but I decided to allow him to
pick me up just to stop him from creating a scene. This time, we were already on a break.
7. JR saw Alejandro and for one reason or the other, he thought there was something going
on between Alejandro and me. JR then dragged me out of the house and said: “Hindi pa
tapos ang three month rule, nakikipaglandian ka na! Papatayin ko kayo ng Kabit mong si
Alejandro.” Self-serving. She may have said this kasi galit sya kay JR. Wala tayo proof nito.
8. I am executing this to attest JR’s intent to kill and cause injury towards Alejandro. JR is
capable of hurting people as he did so when during and after our relationship.

I executed this affidavit to attest the truthfulness of the foregoing facts and to support the filing of
Criminal Case against JAKE REYES y CRUZ, aka “JR”, for committing the crime of Attempted
Murder against Alejandro Diases, in violation of Article 248 in relation to Article 6 of the Revised
Penal Code (RPC).
AFFIANTS SAYETH NAUGHT.

IN WITNESS WHEREOF, I hereunto affixed my signature this 22nd day of September, 2020 at
Makati City.

KATE ROCES
Affiant

SUBSCRIBED AND SWORN to before me this 22nd Day of September, 2020 at Makati City. I
HEREBY CERTIFY that I have personally examined the herein affiants and I am satisfied that
they voluntarily executed and understood their given affidavit.

ATTY. CHRISTIAN DELOS SANTOS

Notary Public
Commission Expires
February 18, 2022
Roll of Attorney No. 67899
IBP No. 67899/5-17-12/Manila
PTR No. 55273/08-15-14/Manila

ANNEX E
Republic of the Philippines )
Makati City) s.s.
x- - - - - - - - - - - - - - - - - - - - - -x
 Sabi sa incident report the stabbing
happened in Kalyeng Ligas, JP Rizal? Eh
hindi naman yung ang address pala ni
AFFIDAVIT OF WITNESS Paolo?

I, PAOLO TOLENTINO, 26 years of age, single, resident of Block 1 Lot 4 Soliven Avenue,
Kalawaan, Brgy. Pembo, Makati City, after having sworn in accordance with law, do hereby
depose and state THAT:

1. I was present and personally saw the accused, JAKE REYES y CRUZ, aka “JR”,
committed the crime of Attempted Murder in violation of Article 248 in relation to Article
6 of the Revised Penal Code (RPC).

2. On Sept. 15, 2020, at around 5:30 pm, I invited my friend and neighbor, Alejandro Diases
over to my house to play sungka and to have drinks afterwards.

3. At around 6:00 pm, I excused myself to use the toilet since my stomach felt upset. A few
moments later, I heard JR shouting “GAGO KA! PUTA@#@(#! SINULOT MO SYOTA
KO!”. Then I started rushing to the sala when I saw my neighbors, June Lima and Nico
Cruz trying to stop JR from stabbing again Alejandro with an icepick. So 6pm din nandun na si June and
Nico? Sa complaint parang they
arrived lang after
4. Thereafter, JR immediately ran out of my house and fled the scene. June, Nico and I
immediately brought Alejandro to Ospital ng Makati to treat his wounds.

5. Moreover, prior to the incident, on Sept. 12, 2020, JR came over to my house to play cards
and later that night we had a few drinks of Red Horse. JR started sharing about his problems
and he then admitted that he has still feelings over his ex-girlfriend, Kate Roces. He also
said that he wished for JR to be dead. His exact utterances were, “Papatayin ko yang JR na
yan! Gagawan ko ng paraan para mawala na siya!”. I told him to calm down but instead he
hit the wall with his hands. Self-serving ulit. No proof of this convo. Their words against his.
6. I am executing this to attest JR’s intent to kill and cause injury towards Alejandro.

AFFIANT SAYETH NAUGHT.

IN WITNESS WHEREOF, I hereunto affixed my signature this 22nd day of September, 2020
at Makati City.

PAOLO TOLENTINO
Affiant
 SUBSCRIBED AND SWORN to before me this 22nd Day of September, 2020 at Makati City.
I HEREBY CERTIFY that I have personally examined the herein affiant and I am satisfied that he
voluntarily executed and understood his given affidavit.

ATTY. KING CHUA

Notary Public
Commission Expires Dec. 15, 2020
Roll of Attorney No. 12345
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila

ANNEX F
 Republic of the Philippines )
Makati City) s.s.
x- - - - - - - - - - - - - - - - - - - - - -x

AFFIDAVIT OF WITNESS

I, NICO CRUZ, of legal age, single, resident of Block 1 Lot 3 Soliven Avenue, Kalawaan,
Brgy. Pembo, Makati City, after having sworn in accordance with law, do hereby depose and state
THAT:

1. I was present and personally saw the accused, JAKE REYES y CRUZ, aka “JR”,
committed the crime of Attempted Murder in violation of Article 248 in relation to Article
6 of the Revised Penal Code (RPC);

2. I am a neighbor of Alejandro Diases, who is residing at Block 1 Soliven Avenue, Kalawaan,

Brgy. Pembo, Makati City;
Sabi ni Paolo,
pumunta sa bahay
nya si Alejandro. 3. On Sept. 15, 2020, at around 5:30 pm, I was lounging outside our house when I saw
Bakit dito sabay na Alejandro Diases and Paolo Tolentino head over to the house of the latter, located on Block
silang pumunta? 1 Lot 4 Soliven Avenue, Kalawaan, Brgy. Pembo, Makati City;
At sabi sa incident
report, the
stabbing 4. On the same day, at around 6:00 pm, my friend, June Lima, arrived and we headed inside
happened at my house. A few moments later, I heard someone shout, “GAGO KA! PUTA@#@(#!
Kalyeng Ligas, JP
Rizal, Brgy. Pembo.
SINULOT MO SYOTA KO!” from the house of Paolo Tolentino. June and I went rushing
Dito sabi ang to the house of Paolo and saw JR swinging an ice pick and repeatedly trying to stab
address na ni Alejandro on his chest. I tried to stop JR and he immediately ran out of the house and fled
Paolo is Blk 1 Lot 4 the scene; Okay so they arrived at around 6pm din when the stabbing started?
Soliven Ave.

5. June, Paolo and I brought Alejandro to the Ospital ng Makati to be treated for his wounds.
He was bleeding on his back, chest and arms; And yet the incident report sa brgy only said bruises
and scratches?
6. I am executing this to attest JR’s intent to kill and cause injury towards Alejandro.

AFFIANT SAYETH NAUGHT.

IN WITNESS WHEREOF, I hereunto affixed my signature this 21st day of September, 2020
at Makati City.

NICO CRUZ
Affiant
 SUBSCRIBED AND SWORN to before me this 21st Day of September, 2020 at Makati City.
I HEREBY CERTIFY that I have personally examined the herein affiant and I am satisfied that he
voluntarily executed and understood his given affidavit.

ATTY. CHRISTIAN DELOS SANTOS

Notary Public
Commission Expires
February 18, 2022
Roll of Attorney No. 67899
IBP No. 67899/5-17-12/Manila
PTR No. 55273/08-15-14/Manila

ANNEX G

Republic of the Philippines )

Makati City) s.s.
x- - - - - - - - - - - - - - - - - - - - - -x

AFFIDAVIT OF WITNESS

I, JUNE LIMA, of legal age, single, resident of Block 3 Lot 5 Soliven Avenue, Kalawaan,
Brgy. Pembo, Makati City, after having sworn in accordance with law, do hereby depose and state
THAT:

1. I was present and personally saw the accused, JAKE REYES y CRUZ, aka “JR”,
committed the crime of Attempted Murder in violation of Article 248 in relation to Article
6 of the Revised Penal Code (RPC);

2. On Sept. 15, 2020, at around 6:00 pm, I arrived at the house of my friend, Nico Cruz, who
lives at Block 1 Lot 3 Soliven Avenue, Kalawaan, Brgy. Pembo, Makati City. We were
heading inside his house when I heard someone shout, “GAGO KA! PUTA@#@(#!
SINULOT MO SYOTA KO!” from the house of Paolo Tolentino who lives next door at
Block 1 Lot 3 Soliven Avenue, Kalawaan, Brgy. Pembo, Makati City. Nico and I went
rushing to the house of Paolo and saw JR swinging an ice pick and repeatedly trying to stab
Alejandro on his chest. Nico shouted at JR to tell his to stop and the latter immediately run
out of the house and fled the scene;

3. Nico, Paolo and I brought Alejandro to the Ospital ng Makati to be treated for his wounds.
He was bleeding on his back, chest and arms;

4. I am executing this to attest JR’s intent to kill and cause injury towards Alejandro.

AFFIANT SAYETH NAUGHT.

IN WITNESS WHEREOF, I hereunto affixed my signature this 21st day of September, 2020
at Makati City.

JUNE LIMA
Affiant
 SUBSCRIBED AND SWORN to before me this 21st Day of September, 2020 at Makati City.
I HEREBY CERTIFY that I have personally examined the herein affiant and I am satisfied that he
voluntarily executed and understood his given affidavit.

ATTY. CHRISTIAN DELOS SANTOS

Notary Public
Commission Expires
February 18, 2022
Roll of Attorney No. 67899
IBP No. 67899/5-17-12/Manila
PTR No. 55273/08-15-14/Manila

ANNEX H
Republic of The Philippines
City of Makati
BARANGAY PEMBO

Office of the Sangguniang Barangay

BARANGAY CERTIFICATION