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Complaint Affidavit

Ms. Social Worker filed a complaint affidavit against Mary Rose Tendanan for child abuse under RA 7610, detailing her involvement in a rescue operation that led to the arrest of Tendanan and the rescue of minors BBB and TTT. The affidavit accuses Tendanan of procuring BBB as a child prostitute and offering explicit performances involving minors in exchange for money. The document outlines the legal basis for the complaint and includes evidence of the alleged crimes.

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Mr. Ed Tatel
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12 views4 pages

Complaint Affidavit

Ms. Social Worker filed a complaint affidavit against Mary Rose Tendanan for child abuse under RA 7610, detailing her involvement in a rescue operation that led to the arrest of Tendanan and the rescue of minors BBB and TTT. The affidavit accuses Tendanan of procuring BBB as a child prostitute and offering explicit performances involving minors in exchange for money. The document outlines the legal basis for the complaint and includes evidence of the alleged crimes.

Uploaded by

Mr. Ed Tatel
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines)

In the Municipality of Virac )s.s


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

COMPLAINT AFFIDAVIT

I, Ms. Social Worker, of legal age, married, a social worker, resident of Purok
2, Barangay Rawis Virac Catanduanes, after having sworn in accordance with
law, do hereby depose and state that:

1. Upon a verification of information that there was a child abuse going


on in Brgy. Rawis Virac Catanduanes, I coordinated with the PNP-WCPC-
BFU (Bicol Field Unit) and Barangay Official of the said barangay.
2. On 19 November 2024, I joined entrapment and rescue operation
conducted at Barangay Rawis Virac Catanduanes to safeguard the
welfare of the clients and ensure the proper handling of their cases.
3. The team was able to arrest MARY ROSE TENDANAN and rescue minors
BBB and TTT.
4. After the conduct of rescue, I prepares a brief assessment report
incorporating summary of actions taken and ensure the proper
turnover of rescued minors to the Regional DSWD officer located at
Virac Catanduanes, attached as Annex ?.
5. Under Section 27 of RA 7610 also known as Special Protection
of Children Against Abuse, Exploitation and Discrimination Act,
complaints on cases of unlawful acts committed against the
children as enumerated herein may be filed by the following:
(a) Offended party;
(b) Parents or guardians;
(c) Ascendant or collateral relative within the third degree of
consanguinity;
(d) Officer, social worker or representative of a licensed child-caring
institution;
(e) Officer or social worker of the Department of Social Welfare
and Development;
(f) Barangay chairman; or
(g) At least three (3) concerned responsible citizens where the violation
occurred.
6. I am accusing MS. MARY ROSE TENDANAN, a resident of Brgy. Rawis,
Virac Catanduanes of Violations of Sections 5(a) and 9 of RA 7610 also
known as Special Protection of Children Against Abuse, Exploitation
and Discrimination Act.
7. Under Section 5(a) of RA 7610:

Section 5. Child Prostitution and Other Sexual Abuse. –


Children, whether male or female, who for money, profit, or any
other consideration or due to the coercion or influence of any adult,
syndicate or group, indulge in sexual intercourse or lascivious
conduct, are deemed to be children exploited in prostitution and other
sexual abuse.
The penalty of reclusion temporal in its medium period to reclusion
perpetua shall be imposed upon the following:
(a) Those who engage in or promote, facilitate or induce child
prostitution which include, but are not limited to, the following:
(1) Acting as a procurer of a child prostitute;
(2) Inducing a person to be a client of a child prostitute
by means of written or oral advertisements or other similar
means;
(3) Taking advantage of influence or relationship to
procure a child as prostitute;
(4) Threatening or using violence towards a child to engage him
as a prostitute; or
(5) Giving monetary consideration, goods or other pecuniary
benefit to a child with intent to engage such child in prostitution.
8. That MARY ROSE TENDANAN, procured BBB as a child prostitute when
she let the latter performed oral sex with one girl aged around 3-4, and
sent three photos of the act to Joe Black, in exchange for some
consideration from Joe Black. (Annex photo from FBI)
9. MARY ROSE TENDANAN induced the undercover agent to be a client by
offering to send to the latter nude photos and videos of BBB, through
Facebook messenger, in exchange of sending her money as financial
assistance because according to her, BBB is sick. (Annex Screenshot)
10. MARY ROSE TENDANAN, is the mother of the minor BBB, as
evidenced in the Birth Certificate of the latter (annex birth cert), having
the moral ascendancy over BBB thereby taking advantage of her
influence to procure the latter as prostitute.
11. Under Section 9 of RA 7610:

Section 9. Obscene Publications and Indecent Shows. –


Any person who shall hire, employ, use, persuade, induce or coerce
a child to perform in obscene exhibitions and indecent shows,
whether live or in video, or model in obscene publications or
pornographic materials or to sell or distribute the said materials
shall suffer the penalty of prision mayor in its medium period.
If the child used as a performer, subject or seller/distributor
is below twelve (12) years of age, the penalty shall be imposed
in its maximum period.
Any ascendant, guardian, or person entrusted in any
capacity with the care of a child who shall cause and/or allow
such child to be employed or to participate in an obscene play,
scene, act, movie or show or in any other acts covered by this
section shall suffer the penalty of prision mayor in its medium
period.
12. MARY ROSE TENDANAN, the mother of BBB, sent a message to
the undercover agent through messenger, offering the latter that BBB
and TTT, her three-year old niece, will do a live show where according
to her, TTT will suck BBB’s penis, in exchange for consideration.
13. MARY ROSE TENDANAN, sent explicit sexual images supporting
her promise of the live show.
14. BBB, at the time of the offer, and taking of the explicit sexual
images, was just 9 years old. (Annex Birth cert BBB)
15. TTT at the time of the offer, and taking of the explicit sexual
images, was just 3 years old. (Annex Birth cert TTT)
16. Attached hereto as Annexes to prove the elements of the crime
of theft:

“A” –
“B” –

That I am executing this Complaint-Affidavit for the purpose of filing the


complaint for Child Abuse under RA 7610 against MS. MARY ROSE
TENDANAN

IN WITNESS WHEREOF, I have hereunto set my hand this____day of April


2017, in Quezon City, Philippines.

BRYAN VALDERAMA EGUIA Complainant/Affiant

SUBSCRIBED AND SWORN TO before me this _____ day of April,2017, in


Pasig City, Philippines, and hereby certify that I havepersonally examined
the Affiant and I am satisfied that he voluntarilyexecuted and understood
his complaint affidavit

Assistant City Prosecutor

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