Republic of the Philippines
Department of Justice
Quezon Province
Catanauan Sub-Office
Catanauan, Quezon
JONAS PADULAS NPS Docket No. 1234-56
Complainant, Municipality of Mulanay, Quezon
- versus -
LUCY CULAS For: VIOLATION OF RA 282 GRAVE THREATS
Respondents
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COMPLAINT - AFFIDAVIT
I, JONA PADULAS, of legal age, Filipino, with residence at Sitio Sumagonsong Brgy.
Pakiing Mulanay, Quezon after being sworn in accordance with the law, hereby depose and
state:
1. That I know the person of LUCY CULAS, of legal age, Filipino, with residence at Sitio
Sumagonsong Brgy. Pakiing Mulanay, Quezon.
2. That the accused and I were neighbors and residing at the same address for almost 5
years.
3. That on August 7, 2024 at about 3:00 pm, I, together with my husband, JOSE
PADULAS, approached LUCY CULAS to adjust her fence because it covers our lot
area. The affidavit of JOSE PADULA is hereto attached as Annex B;
4. That the accused got mad and claimed that it was included in her lot and demanded that I
leave immediately. However, I expressed my insistence on not building a fence that near
our lot because there is a “mohon” that shows it was our lot.
5. That the accused then clutched the handle of a bolo fastened around her waist and uttered
the following words in a resentful and threatening manner: “Subukan ninyong
pagbawalan ninyo kaming magbakod at siguradong matatanggal ang leeg ninyo dini sa
itak ko!”
6. That out of fear for my life, I gave in to his demands and left unsatisfied;
7. That during the altercation, I noticed that ROSANNA FORTES, our neighbor, was
observing the events as they transpired from her own house. The affidavit of ROSANNA
FORTES is hereto attached as Annex C;
8. That immediately after the said incident occurred, I reported the matter to the Barangay
Councilor ALLAN GO, who was the Officer of the Day stationed in the Barangay Hall
of Brgy. Pakiing. The affidavit of Barangay Councilor Allan Go is hereto attached as
Annex D;
9. That on August 15, 2024, I went to the Office of the City Prosecutor to file charges
against the accused;
10. That upon consultation with my lawyer, I understand that the acts of the accused qualify
for the crime of GRAVE THREATS punishable under Article 282 of the Revised Penal
Code; and
11. That I am executing this affidavit to attest to the truth of the foregoing facts and for the
purpose of filing a criminal complaint for GRAVE THREATS against the accused, who
may be served with subpoenas and other court processes at his last known address at
Barangay Pakiing Mulanay, Quezon.
IN WITNESS WHEREOF, I hereunto set my hand on this 15 th day of August 2024 at
Catanauan, Quezon Philippines
RHIUM TRUCE SALVADOR
Affiant-Complainant
SUBSCRIBED AND SWORN to before me this 15 th day of August 2024 at Catanauan,
Quezon Philippines, affiant appearing before me with his Philippine Driver’s License
Number 123 issued by the Land Transportation Office on January 1, 2023 at Catanauan,
Quezon and presenting to me a document entitled AFFIDAVIT, affiant is identified through
his official ID card bearing his photograph and signature, and who signed the said document
in my presence and swore that he understood the contents thereof and that the same was his
free and voluntary act and deed.
JOSHUA R. GARCIA
Office of the City Prosecutor
Catanauan Quezon
Roll No. 910
IBP No. 234; 01-01-2020; Quezon Province
PTR No. 234; 01-01-15; Quezon Province
MCLE Compliance No. 234
CERTIFICATION
I hereby certify that I have examined the Affiant and that I am fully satisfied that he has
voluntarily executed and understood the contents of the Complaint-Affidavit.
JOSHUA R. GARCIA
Office of the City Prosecutor
Catanauan Quezon
Roll No. 910
IBP No. 234; 01-01-2020; Quezon Province
PTR No. 234; 01-01-15; Quezon Province
MCLE Compliance No. 234
