Sample - Affidavit - Complaint - For - E-Libel CASE

 

Republic of the Philippines) Muntinlupa City )s.s. x------------------------------x  AFFIDAVIT-COMPLAINT  AFFIDAVIT-C OMPLAINT

I, __________, of legal age, single, Filipino and resident of 21___________, under oath, hereby depose and say, that: 1.  I am the sports editor of the _________ since July 2013. I hereby formally charge the following persons for the crime of Libel under section 4, (c) paragraph 4 of R.A. 10175 also known as the Cybercrime Prevention Act of 2012; 1.a. XXXX, Editor-In-Chief Editor-In-Chief,, XXXXXXXX, Columnist and Features Editor of the ___________all of legal age and with business address at______________________, herein referred to as RESPONDENTS. 2.  Manila Mirror Inquirer is a newspaper of general circulation in Metro Manila with business address at at  ______________  _______ _______________ ____________. ____. 3.  On_____, respondents respondents by conspiring and confederating to malign my person, character and honor caused the publication through the ____________________ under the Opinion page, page, an article entitled “In the Absence Abse nce of Sportsmanship: A Grossly Biased Writer”  written by ColumnistXXXXX, published for all to see through their office in Muntinlupa City on even date.  Attached is the full te text xt of libelous article hereto hereto referred as  Annex "A".

 

4.  Said article published by respondents, without observing the ethical standards of journalism, contained malicious imputations with bad intentions and unjustifiable motives, purposely to malign, dishonor, discredit, insult and assassinate my characeter and good reputation to the public as well as to my constituents, c onstituents, an excerpt of which are hereby quoted: “ However, what ____ does not understand - even after being in the field of news writing for years - is that when one is an editor who writes articles made available to the public, all biases should be eliminated.  His lack of proper research in writing his recent article on the_____ shows his incompetence and unworthiness. He wrote like an amateur, as if an apprentice that was only recently hired to write for a renowned paper. Unfortunately for the company he works and writes for, Canlas has exposed his and the company’s weakness, inefficiency and ineffectiveness as deliverers of news which failed to be factual, actual and truthful. His work was defamatory as against the  PBA, without him even knowing it.”    5.  The afore-quoted portion of the online article authored by respondent __________published by the herein respondents in the of the I am liar, deceitfulcreated and biased inminds my work    as readers a sportsthat editor of Manila Star Bulletin. Bulletin. 6.  The article written and published by respondents has no factual basis, is highly speculative and was all false statements made to destroy my reputation as a writer and an editor of one of the country’s renowned newspapers. Respondents were motivated by bad faith in the publishing of the said article online to defame, embarrass and discredit me to my colleagues, friends, family and to the readers and patrons of our publication;

 

  7.  The libelous article having been published through the  ___________Website,  _______ ____Website, a website accessible to and is made available to the general public was read by the said general public, including my colleague colleagues, s, friends and family among others; 8.  Due to the said malicious public imputations by respondents, I suffered and continue to suffer serious anxiety, besmirched reputation, mental anguish, sleepless nights, not to mention the damage they have caused to my career, reputation and honor among the readers and patrons of the Manila Star Bulletin and the general public; 9.  Due to such grossly injustifed malicious and libelous imputations, I therefor pray that respondents be made to pay jointly and severally, the damages I was made to suffer as a result of the online published article in whatever amount the Honorable Court deems sufficient and proper together with the attorney’s fees and the cost of this suit. suit. I hereby execute this affidavit to attest to the truth of the foregoing facts and hereby request the investigating prosecutor to file the crime of Libel under R.A. 10175 against the herein Respondents. IN WITNESS WHEREOF, I have hereunto set my hand this 14th day of March 2016 in Muntinlupa City, Philippines

 Affiant SUBSCRIBED AND SWORN TO before me this 14th day of March 2016 at Muntinlupa City, Philippines the following affiant  _________exhibiting  _______ __exhibiting to me her Government issued NonProfessional Driver’s License no.  _____19 being sufficient and

 

competent evidence of his/her identity in pursuant to the 2004 Rules of Notarial Practice.

Doc. No. ____; Page No.____; Book No. ____; Series of 2016