Republic of the Philippines
Department of Justice
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
City of San Jose Del Monte, Bulacan
INVESTIGATION DATA FORM
To be accomplished by the Office
DATE RECEIVED: NPS DOCKET NO.:
(stamped and initiated): ________________________ XV- ____________________
Time Received: ________________________ Assigned to: ____________________
Receiving Staff: _________________________ Date Assigned: ____________________
To be accomplished by the complainant/ counsel/ law enforcer:
(Use back portion if space is not sufficient)
COMPLAINANT/S: Name, Sex Age & Address RESPONDENT/S: Name, Sex, Age & Address
Roxanne V Balancio, of legal age residing at Rodalyn Ramos, of legal age residing at
No. 17 Lopez Jaena, Barangay Dona Aurora, Blk.1 Lot 6, Carissa 2-A, Barangay
Quezon City. Kaypian, San Jose Del Monte City, Bulacan.
OFFENSE/s COMMITTED/ LAW/s VIOLATED: WITNESS/es: Name and Address
Article 316, paragraph 1 of the Revised Penal Code Roxanne V Balancio, of legal age residing at
No. 17 Lopez Jaena, Barangay
Dona Aurora
Quezon City.
DATE & TIME OF COMMISSION: PLACE of COMMISSION:
October 28, 2021 Lot 26, Blk.6 Carissa 2-A, Barangay
Kaypian, San Jose Del Monte City, Bulacan.
1. Has a similar complaint been filed before any other office? NO
2. Is this complaint in the nature of a counter-charge? NO
3. Is this complaint related to another case before this office? NO
I.S./NPS Docket No. _____________________
Handling Prosecutor _____________________
CERTIFICATION
I CERTIFY, under oath, that all the information on this sheet are true and correct to the best of my
knowledge and belief, that I have not commenced any action or filed any claim involving the same issues in
any court, tribunal, or quasi-judicial agency, and that if I should thereafter learn that a similar action has
been filed and/or is pending, I shall report that fact to this Honorable Court within five (5) days from
knowledge thereof.
Roxanne V Balancio
Complainant
SUBSCRIBED AND SWORN TO before me this ______ day of February 2022 at City of San
Jose Del Monte, Bulacan
____________________________________
Administering Prosecutor/ Officer
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*1,2,3 and CERTIFICATION need not be accomplished for inquest cases
Republic of the Philippines )
San Jose Del Monte, Bulacan) S.S.
Complaint-Affidavit
I, Roxanne V Balancio, Filipino, of legal age, with residential
address at No. 17 Lopez Jaena, Barangay Dona Aurora, Quezon City, under
oath, depose and state:
1. That the herein Respondent, Ms. Rodalyn Ramos, is a Filipino, of
legal age with residential address at Blk.1 Lot 6, Carissa 2-A,
Barangay Kaypian, San Jose Del Monte City, Bulacan, where
copies of correspondences from this Honorable Office may be
served;
2. That I am the registered owner of a house and lot located at Lot
26, Blk.6 Carissa 2-A, Barangay Kaypian, San Jose Del Monte
City, Bulacan, embraced Tansfer Certificate of Title No. 040-
2021027472;
2.1. attached herein are copies of the land title and tax
declaration marked as Annex “A”and “A-1”;
3. That sometime in November 2021, I visited my property to make
renovation, to my surprise, the same was being occupied by
unknown persons without my authority;
4. Upon inquiry to the aforesaid occupants, the same responded that
they are lawful tenants and had been paying monthly rental fees of
Ten Thousand Pesos (Php10,000) per month to the Respondent,
who represented herself as the owner of the above-mentioned
property;
5. This matter was brought to the attention of the Home Owners
Association and the Baranggay wherein the preceding statement
was recorded by the Officials of the Baranggay, same as, with
Respondent’s persistent representation as the owner of the same
subject property without any supporting documents or authority
from law;
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5.1. Attached are copies of the minutes of the HOA,
Baranggay hearings and the occupant’s statement
regarding the lease are marked as Annex ___ ,
respectively;
6. That despite notice provided to herein Respondent, the same
maintained her representation as the owner of the property before
the Baranggay Officials and to the public to justify its acts of
ownership by gaining profit over my property and to my
prejudice;
7. In the case of People of the Philippines vs. Clarita Estrallado-
Mainar1, the Supreme Court ruled that Article 316 (1) of the
Revised Penal Code penalizes any person who pretends to be an
owner of any real property and execute acts of ownership such as
leasing, to the prejudice of the owner or third person;
8. Since, the act complained of was committed by Respondent
within Baranggay Kaypian, City of San Jose Del Monte, Bulacan,
the venue of this case is proper within the Trial Courts of City of
San Jose Del Monte, Bulacan;
9. That I am issuing this Complaint-Affidavit to attest to the truth of
the foregoing facts based on my personal knowledge and the
records of this case, and for purpose of filing a criminal complaint
for violation of Article 316, paragraph 1 of the Revised Penal
Code against Respondent Rodalyn Ramos.
February______, 2022, City of San Jose Del Monte,
Bulacan.
____________________
Roxanne V Balancio
SUBSCRIBED AND SWORN to before this February ___, 2022 at
San Jose Del Monte City, Bulacan. I hereby certify that I have personally
examined the affiant, and I am satisfied that she voluntarily executed and
understood her complaint-affidavit.
1
CLARITA ESTRELLADO-MAINAR vs. PEOPLE OF THE PHILIPPINES, G.R. No. 184320
July 29, 2015
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ASST. CITY PROSECUTOR
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