Republic of the Philippines
Department of Justice
OFFICE OF THE PROVINCIAL PROSECUTOR
Virac, Catanduaness
AAA and BBB as represented by Sophia Wenceslao NPS CASE NO. _____
Complainant, For: Violation of Section 4 (a), (b), (c), (d), (e), (k), (l)
- versus - and (r) of Republic Act 11930
Mary Rose Tendanan
_________________________________
Respondent.
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COMPLAINT
The undersigned private complainant hereby accuses MARY ROSE TENDANAN of Child Abuse under Section 4 (a),
(b), (c), (d), (e), (k), (l), and (r) of Republic Act No. 11930 also known as Anti-Online Sexual Abuse or Exploitation of
Children (OSAEC) and Anti-Child Sexual Abuse or Exploitation Materials (CSAEM) Act, committed as follows:
“That on or about 3:00 o’clock in the afternoon of November 18, 2024 or sometime prior or subsequent thereto
in Barangay Rawis, Municipality of Virac, Province of Catanduanes, Philippines and within the jurisdiction of
this Honorable Court, the above-named accused then and there willfully, unlawfully and feloniously,
committed online sexual abuse against children AAA, a 9-year old boy and BBB, a 3-year old girl, by inducing
another person (UA, undercover agent of PNP-WCPC-BFU) to be a client through actually sending to the
latter explicit sexual images and offering a livestream sex video of AAA and BBB, through Facebook
messenger, in exchange of sending her money as financial assistance and having the moral ascendancy over
AAA as his mother and AAB as her aunt, thereby taking advantage of her influence to use named victims as
prostitutes.”
CONTRARY TO LAW.
Virac, Catanduanes. November 21, 2024.
Sophia Wenceslao
Complainant
st
SUBSCRIBED AND SWORN to before me this 21 day of November 2024 in Virac, Catanduanes. I certify
that I have personally examined the complainant and that I am satisfied that he/she voluntarily executed
and understood his/her complaint.
Mutya P. Zaragosa
Associate Provincial Prosecutor
WITNESSES:
1. The complainant
2. Undercover Agent (real name withheld)
3. Andres Obligado, Team leader, Entrapment and Rescue
Operations
4. Sergio B. Olivarez, Executor of Search Warrant
5. Uno B. Mamanu, RACU V