Make a Counter Complaint of the following complaint.

Republic of the Philippines) IlocosNorte )s.s. x x

COMPLAINT AFFIDAVIT

I, BINGBONG R. MARCOS,of legal age, married, Filipino and resident of Brgy. Lacub, Batac, Ilocos Norte, under oath, hereby depose and say, that:

1. I am presently employed as cashier at PACMAN ENTERPRISES located at 10th Floor Lacson Bldg. ,Brgy. Lacub, Ilocos Norte . I hereby formally charge the following person for the crime of Libel under section 4, (c) paragraph 4 of R.A. 10175 also known as the Cybercrime Prevention Act of2012;

1. LEN LEN ROBREDO, Accounting Manager of Pacman Enterprises legal age and with business address at 10th Floor Lacson Bldg. ,Brgy. Lacub, Ilocos Norte, herein referred to asRESPONDENT.

1. Both I and the respondent are employees of Pacman Enterprises and work on the Finance department of the said company.

1. The respondent through the Facebook Application posted a picture of myself captioned "Hoy Bingbong Marcos isa kang magnanakaw. Walanghiya ka ibalik mo ang mga perang ninakaw mo sa amin." The photo in itself was edited the statement "Magnanakaw wag tularan!" sprawled across my image, posted in social media for everyone tosee.

Attached is the libelous Facebook post hereto referred as Annex "A".

1. Said Captioned photo was posted by the respondent, without observing the workplace professionalism, contained malicious imputations with bad intentions and unjustifiable motives, purposely to malign, dishonor, discredit, insult and assassinate my character and good reputation to the public as well as to ourcolleagues.

1. The Captioned photo posted by respondent has no factual basis, is highly speculative and was all false statementsmade

to destroy my reputation as a cashier and a trustworthy employee of Pacman Enterprises. The respondent was motivated by bad faith in the posting of the photo online to defame, embarrass and discredit me to my colleagues, friends, family and to the top management of Pacman Enterprises who were considering me as a good candidate for the position held by the respondent.

1. The libelous captioned photo having been posted through the Facebook application, an application accessible to and is made available to the general public was read by the said general public, including my colleagues, friends and family amongothers;

1. Due to the said malicious public imputations by respondents using social media, I suffered and continue to suffer serious anxiety, besmirched reputation, mental anguish, sleepless nights, not to mention the damage they have caused to my career, reputation andhonor.

1. Due to such grossly injustifed malicious and libelous imputations, I therefor pray that respondent be made to pay the damages I was made to suffer as a result of the Facebook post in whatever amount the Honorable Court deems sufficient and proper together with the attorney's fees and the cost of thissuit.

I hereby execute this affidavit to attest to the truth of the foregoingfactsandherebyrequesttheinvestigatingprosecutortofile the crimeofLibel under R.A.10175againstthe hereinRespondents.

IN WITNESS WHEREOF, I have hereunto set my hand this 14th dayof March 2016in Muntinlupa City,Philippines

Affiant

SUBSCRIBED AND SWORN TO before me this 14th day ofJune 2021at Ilocos Norte, Philippines the following affiant BINGBONG R. MARCOS exhibiting to me his Government issued Non- Professional Driver's License no. 8293-9173-19 being sufficient and competentevidenceofhis/heridentityinpursuanttothe2004Rules of Notarial Practice.

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