REPUBLIC OF THE PHILIPPINES
DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE PROSECUTOR
BATANGAS CITY
JUAN DELA CRUZ
Complainant,
-vs-
Case No. 09-0420
Adultery
MARIA DELA CRUZ, and CRISOSTOMO IBARRA
Respondent,
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COMPLAINT-AFFIDAVIT
I, JUAN DELA CRUZ, 41 years old, married and a resident of Rosario, Batangas, after
being sworn in accordance with law depose and say that;
1. On November 5, 2001, Maria Clara De Guzman, the respondent, and I got married in a
church wedding ceremony at Most Holy Rosary Parish in the Municipality of Padre Garcia.
Our marriage did not produce a child.
2. On July 13, 2022, I saw the respondents, Maria Clara and Crisostomo, in Tulyase Resto,
eating together. Having doubts of my wife’s fidelity, I decided to investigate. I hurriedly left
the establishment and stayed in my car for a few minutes before seeing them leave together
and rode a Raider 150 FI belonging to Crisostomo. I saw Maria Clara give Crisostomo a kiss
before leaving Tulyase Resto’s parking lot.
3. On July 15, 2022, while I was looking for my prescription glasses, I accidentally saw a
purchase receipt for a Silverware bracelet purchased under the credit card of Crisostomo
Ibarra hidden in the drawers of our bedside table.
4. Because of my suspicion, I tried opening my wife’s cellphone and social media accounts
several times but I couldn’t since she changes all of her passwords.
5. On August 3, 2022, my wife went to Lipa City for an alumni homecoming at Lipa City
Colleges. Because my mind had already been tainted with suspicion of her infidelity, I
followed her to Lipa City without her knowledge. She told me she would stay at her mother’s
house in Ecoverde Subdivision, but she never stayed there. I saw her leave the Lipa City
Colleges at around 12 o’clock in the evening and rode the same Raider 150 FI that
Crisostomo owned. I followed the motorcycle and it stopped at a Motorist Lodge located at
Lodlod, Lipa City where I saw both the respondents enter the lodge premises. Their stay
together at the motel had made me believe that the two of them already have been doing
sexual intercourse.
6. On the next day, when my wife came home, I told her that someone saw her with another
man entering a motel but she denied it. She told me that it was her friend and they are not
alone. She said that her other friends were with them and they stayed in the motel together
since they were drunk and it was already late so they cannot drive home.
7. On September 8, 2022, I told my wife that I am going to a convention in Batangas City and
that I will be gone for five (5) days. The truth was that I did not go to the convention but was
staying at a local hotel in the city and the purpose of my pretense was to catch the two of
them in their act of infidelity.
8. The mission to catch them both was a success. On the evening of September 19, 2022,
around 9:30 PM, I went home and caught them having sexual intercourse inside our
bedroom. Crisostomo was on top of my wife and they are both naked. To their surprise,
Crisostomo jumped out of bed and hurriedly picked up his clothes on the floor, and bolstered
out of the room and out of our house. I confronted her and she confessed to their infidelity.
9. After the incident, I packed my things and leave the house. I stayed in my family’s home at
San Jose, Batangas.
10. It is most unlikely that Mr. Crisostomo Ibarra had not been aware of my wife’s current
marital status seeing as this affair has been going on for more than a year and that they have
been meeting discreetly in our family home where a large portrait of me and my wife during
our wedding had been displayed in the living room, visible enough to be seen when entering
the house premise.
11. That all these stated herein are true and were stated freely without any force or intimidation
done against me.
12. To attest to the truthfulness of the foregoing, I, Juan Dela Cruz, complainant, attaches my
signature below.
Juan Dela Cruz
Complainant
SUBSCRIBED and SWORN to before me, the undersigned prosecutor, this 25th day of
September 2022 in the Municipality of Rosario, Philippines. I hereby certify that I have
personally examined the above-named affiant and that I am satisfied that the foregoing
statements were given by him voluntarily and of his own free will.
Atty. Apolinario Mabiling
City Prosecutor
