Republic of the Philippines ]

City of Zamboanga ] s.s.

X. . . . . . . . . . . . . . . .X]

COMPLAINT-AFFIDAVIT
We, RIHANNA S. GRANDE and AREANNE B. GRANDE,
62 and 19 years old, married and single, respectively, Filipinos,
and residents of Poblacion, Kabasalan, Zamboanga Sibugay,
after having been duly sworn to in accordance with law, do
hereby depose and say that:

1 On January 17, 2016, around 5 oclock in the

afternoon, we disembarked from KL Blabla of the
World vessel which departed from Kuala Lumpur,
Malaysia and docked at Zamboanga International
Seaport. After a month-long vacation with our
relatives in Kuala Lumpur, we decided to go
home to our province in Kabasalan, Zamboanga
Sibugay;

2 When we arrived at the sea port, we proceeded

to the exit gate (the one located near the
National Bureau of Investigation) to look for a
ride that will bring us to Integrated Bus Terminal
(IBT, for brevity) in Divisoria, this City;

3 Upon reaching the exit area, we were swarmed

by a crowd of porters and barkers. One barker in
particular, whom he introduced himself to us as
Rap Rap, approached us. We later knew him to
be Rap Rap S. Diutay;

4 Rap Rap grabbed our two (2) luggage without our

permission and urged us to follow him to a for-
hire tricycle;

5 We tried to retrieve our luggage from him and

told him that we were planning to ride a jitney
instead because it was cheaper and we know our
way to downtown;

6 However, Rap Rap was really insistent. He told us

that it was better to ride a tricycle because its
1 Complaint-Affidavit of Rihanna S. Grande & Areanne B. Grande
 faster and lesser of a hassle. To enforce his
words, he even started to walk, with some of our
belongings with him, towards a group of idle
tricycles parked near the sea port area;

7 To tired and weary from the recent voyage to

argue further, we followed him. He headed to a
pink tricycle bearing plate number HA 123 and
immediately placed some of our things inside the
vehicle. While he was talking to the driver, whom
he called and acknowledged as Harjado, (later
known to be Harjado I. Buenbrazo) he tied the
rest of our things at the back of the vehicle and
told us to get inside;

8 When we were already inside, he told the driver

that we are headed to the bus terminal. We were
expecting for him to ask for money in exchange
for his help and leave us to help other
passengers but he did nothing of the sort.
Instead, he sat at the vacant space at the back of
the tricycle driver when the latter started the
engine;

9 We were somehow surprised when he went with

us, but we did not ask him about it as it seemed
to be not much of a big deal for us that moment.
Eventually, Rap Rap and the driver Harjado
started conversing in a dialect we are not familiar
with;

10Few distance away, along Chong Hua High

School, the tricycle slowed down and another
man (big in built, with moustache and beard, in
green shirt and maong shorts, and a black
backpack placed in front of him) boarded the
vehicle. He immediately positioned himself in
front of us and Harjado resumed his driving. At
that time, we were already giving each other
questioning and annoying looks because we
expected our brief trip to the bus terminal to be
exclusive and that Harjado could have asked for
our permission before he decided to pick other
passengers;

2 Complaint-Affidavit of Rihanna S. Grande & Areanne B. Grande

11Nevertheless, we kept quiet as, with the three (3)
men surrounding us, we felt overwhelmed. In
addition, the three (3) lapsed into a conversation
which we could not understand and follow
because the dialect they were using was
unfamiliar to us;

12When we were already near the IBT, along Maria

Clara L. Lobregat Highway, we asked the driver
Harjado how much the fare was. We were beyond
shocked when he replied, Only P 2, 500.00. We
know for a fact that tricycles ask for higher fares
compared to PUJs as we usually pay P 100.00 to
P 150.00 for the same route but the fare being
charged is nowhere near the normal price.
Hence, we vehemently protested;

13 However, the man in front of us (later known as

Kuyanash L. Delacros) started to exhibit a
menacing expression. Subsequently, he angrily
uttered, You are lucky we are not staging a hold-
up. In other cases, you were already robbed.
While Kuyanash was talking to us, we noticed
Harjado was driving slower than usual while Rap
Rap was moving his head as if he was on a look
out for someone;

14When those words came out of his mouth and

the accompanying silence from the other two (2)
men, we immediately felt intimidated and
scared. So we did not put a fight anymore;

15Unfortunately, we only have P 750.00 combined

cash left in our possession so we pleaded that we
just give said amount to them. At first, Harjado
and Kuyanash did not give their consent. They
even accused us of lying. After more begging and
crying, they eventually conceded although with
hesitation;

16Against our will and without a choice, we

surrendered our remaining money worth P
750.00 to Rap Rap when we were almost at the
bus terminal. They dropped us and our luggage

3 Complaint-Affidavit of Rihanna S. Grande & Areanne B. Grande

 just outside the entrance of the IBT and
immediately left afterwards;

17When the tricycle was already a safe distance

from us, we ran towards a patrolling security
guard and immediately reported the incident to
him;

18Hours later, we heard that the three (3) men

were apprehended by police officers.
Unfortunately, we were stranded at the IBT for
the rest of the night as we were interviewed by
the authorities and we could not ride the bus
because we no longer have the money to buy
tickets;

19Likewise, we suffered sleepless nights and

mental anguish after the incident fearing for
our safety and thinking of possible retributions
from the three (3) men. However, their appalling
actions should not be tolerated and, if left to
their own devises, they might have continued
their act of victimizing unsuspecting and helpless
passengers if not properly apprehended; and

20 Therefore, we are executing this affidavit to

attest to the truth of the foregoing on our own
free will and volition and to file a formal
complaint for Highway Robbery under P.D.
532also known as the Anti-Piracy and Anti-
Highway Robbery Law of 1974 against RAP RAP
S. DIUTAY, HARJADO I. BUENBRAZO and
KUYANASH L. DELACROS.

AFFIANTS FURTHER SAYETH NAUGHT.

IN WITNESS WHEREOF, we have hereunto affixed our

signatures this 18th day of January 2016, at Zamboanga City,
Philippines.

RIHANNA S. GRANDE AREANNE B. GRANDE

Affiant Affiant

4 Complaint-Affidavit of Rihanna S. Grande & Areanne B. Grande

 SUBSCRIBED AND SWORN TO before me this 18th day of
January 2016 at Zamboanga City, Philippines.

THIS IS TO CERTIFY that I have personally examined the

herein affiants and that I am fully satisfied that they voluntarily
executed this affidavit and understood the contents thereof.

5 Complaint-Affidavit of Rihanna S. Grande & Areanne B. Grande