Republic of the Philippines)
Province of La Union
)
City of San Fernando
) s.s.
AFFIDAVIT-COMPLAINT
I, RIZALYN HIDALGO y JUNIO, 28 years old, Filipino, single
and a resident of Dallangayan Este, City of San Fernando, La Union,
after having sworn to an oath in accordance with law, hereby depose
and state that:
1. I am filing a complaint for LIBEL, UNJUST VEXATION and
Violation of Republic Act No. 10175, otherwise known as the
“Cybercrime Prevention Act of 2012” specifically Section 4(c)(4) of
the said Act and/or other necessary charge/s against FRAULINE
BROWN y FLORES a.k.a. Lai Flores (hereinafter referred to as
“LAI” for brevity), of legal age, married and a resident of #2 Handel
St. Ideal Subdivision, Fairview, Quezon City;
2. At about 6:00 A.M. of January 31, 2019, as I opened my
mobile data and checked my facebook account, a notification from
the messenger popped up and I saw that LAI messaged me. When I
opened it, I read her message saying, “Humanda ka sa akin. Uuwe
ako at isusubsub ko mukha mo kapal mukha mo. Ipagkakalat ko sa
eskwelahan na pinagtratrabahuan mo na kumakabit ka sa asawa ng
mama ko”;
3. LAI’s name in her facebook account is Lai Flores. She is my
grandmother’s adopted daughter and actually our cousin also since
her biological father and my father are cousins;
4. Her adoptive mother, Aurelia Behr who is the sister of my
paternal grandmother, is married to a German national, Burkhard
Behr (“MR. BURKHARD” for brevity). They live in Germany but come
to visit Philippines for vacation usually every November or December
and go back again to Germany by March or April. They were the ones
who financed my studies so with my other two female siblings;
5. I hurriedly replied LAI, saying: “Ano na naman po ba yan ate?
Tama naman na po kasi wala akong ginagawang masama. Saan na
naman po nagmula yang pinaparatang mo sa akin? Nanahimik kami
then may ganyan ulit.” I asked her these questions because this was
PAO_SFC
Affidavit-Complaint
Hidalgo v.
Brown
Page 1 of 4
the second time she is accusing me of having an affair with her
adoptive mother’s husband, MR. BURKHARD;
6. When I told this to my mother, my sister, RACHELLE J.
HIDALGO (“RACHELLE”), said she received a screenshot picture
from our aunt, JOVY HIDALGO DULAY (“AUNTIE JOVY”). The
respective Affidavits of RACHELLE and AUNTIE JOVY are hereto
attached and marked as ANNEXES “A” and “B” respectively;
7. It was a screenshot of LAI’s post in her facebook account
containing allegations of me being a mistress, thick faced and a flirt,
to wit: “Ang kapal ng mukha mong malandi ka at pumayag kang
maging kabit at asawa pa ng Lola mo Ang pinatos mo!!!! Hindi
ka magiging teacher kung di ka pinaaral ng mama ko at gusto
mo pang angkinin ang Dapat sa mama ko. Hintayin mo at
magkikita tayo sa husgado!!! Ang properties napapalitan, kaya
kong kitain yan Pero pag buhay ng mama ko nawala dahil sa
sakit na ginawa mo. Hinding Hindi kita lulubayan!!!!” In this post it
contains also a screenshot of my profile account with my name on it
and another picture that was taken from my photos. Copy of the said
post with comments is hereto attached and marked as ANNEX “C”
and ANNEX “C-1” respectively;
8. I later found out that her allegation was based from what was
told to her by Auntie Gemma Flores (“AUNTIE GEMMA”) who is living
in Canada. AUNTIE GEMMA was told by our Auntie Erlinda Flores
Probst (AUNTIE ERLINDA) that I received a letter from MR.
BURKHARD telling endearment words and that MR. BURKHARD will
come to the Philippines and will transfer all his properties to me; that
also MR. BURKHARD will bring me to Germany and that I am her
mistress. But these are not the exact translations given to us by
AUNT ERLINDA when we asked her to translate the contents of the
letter. Copy of the said letter dated September 6, 2018 is hereto
attached and marked as ANNEX “D” hereof;
9. Sometime in December 2018, I received the said letter from
MR. BURKHARD. Since the language used was German language,
my sisters and I opted to seek for AUNTIE ERLINDA’s help to
translate the said letter in Filipino language since her husband is a
German national;
10. I and my sisters, RACHELLE and Ruffalyn Hidalgo
(RUFFALYN) went to AUNTIE ERLINDA’s house sometime in
December 2018 at around 4 or 5 in the afternoon to ask her to
PAO_SFC
Affidavit-Complaint
Hidalgo v.
Brown
Page 2 of 4
translate the contents of the letter. The translations that I
remembered that was given by AUNTIE ERLINDA with her German
husband, Hans Probst, was that MR. BURKHARD said on his letter
an endearment “lieben Sheneki”, meaning “Dearest Sheneki”
(Sheneki is my nickname). According to AUNTIE ERLINDA, MR.
BURKHARD also said in his letter that he was happy of my letter that
I sent him for his birthday. He also told about his problems with my
relatives in Fairview. He invited me to come and visit Germany for
three weeks since according to him his visit this 2019 would be his
last. And he wants to transfer some of his properties to me and my
other three female siblings: RUFFALYN, Annabel Hidalgo and
RACHELLE;
11. During the translation AUNTIE ERLINDA and her
husband congratulated us with the inheritance that we are to receive.
They also kiddingly said “Haan dak tu liplipatan. Agparaman kau met
ah” (Do not forget me. You also share ha). We replied that we do not
believe what was stated in the letter that we will be inheriting
properties from MR. BURKHARD unless an attorney will approached
us giving document that shows that the properties were already
transferred to us;
12. When my sisters and I went home, we relayed the
contents of the letter to our parents. We decided that we should not
tell the same to anyone since we don’t believe about the transfer of
properties;
13. Hence when I received the messages of LAI on January
31, 2019, I went immediately to AUNTIE ERLINDA’s house to ask her
if what did she tell to her sister, AUNTIE GEMMA, and why is LAI
accusing me of being a mistress. She said she just told AUNTIE
GEMMA about the contents of the letter but she never said that I am
a mistress and that maybe it was just a misunderstanding;
14. While I was at TITA ERLINDA’s house, LAI continued to
send messages of her accusations and her threats of filing a case
against me being a mistress of MR. BURKHARD, that she will make
ways to have my Civil Service Commission license revoke and make
me lose my job as a public teacher, and that she will broadcast me of
being a flirt and a mistress in the entire La Union and Department of
Education. Copy of said messages are hereto attached and marked
as ANNEX “E” and series;
PAO_SFC
Affidavit-Complaint
Hidalgo v.
Brown
Page 3 of 4
15. She also continued to post statements against me on her
facebook as evidenced by hereto attached printed screenshot post
marked as ANNEXES “F” and “F-1” hereof;
16. Because of LAI’s posts, I was deeply hurt and felt so
insulted and humiliated. My reputation was immensely tarnished. A
lot of people were able to read her posts even our kabarangays.
Worse, some of our relatives spread the same to others. This incident
caused me so much stress, mental anguish, fright and serious
anxiety. Thus, on January 31, 2019, I sought for a legal advice and
caused the recording of the incident in the Police Blotter of San
Fernando City Police Station as evidenced by hereto attached Police
Blotter marked as ANNEX “G” hereof; and
17. I am executing this sworn statement to attest to the truth
of foregoing and in the support of the filing of appropriate criminal
charges against FRAULINE FLORES BROWN a.k.a. Lai Flores
under Articles 353 and 287 (paragraph 2) of the Revised Penal
Code and Republic Act No. 10175, otherwise known as the
“Cybercrime Prevention Act of 2012”.
IN WITNESS WHEREOF, I have hereunto set my hand this 8th
day of February, 2019 at San Fernando City.
RIZALYN
J.
HIDALGO
Affiant-Complainant
SUBSCRIBED AND SWORN to before me this 8th day of
February, 2019 at San Fernando City, La Union, Philippines and
further certify that I personally examined the affiant and I am
convinced and satisfied that he gave his statement freely and
voluntarily and understood the contents hereof.
PAO_SFC
Affidavit-Complaint
Hidalgo v.
Brown
Page 4 of 4