(Philippine legal article and practical drafting guide, with templates and key reminders)

1) What a “VAWC case” is, in practical terms

A VAWC case generally refers to a complaint under Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004). It covers acts committed against a woman by a person who is or was her husband, former husband, live-in partner, former live-in partner, boyfriend, former boyfriend, or someone with whom she has a sexual or dating relationship, or a person with whom she has a common child. It also covers violence committed against the woman’s child (legitimate or illegitimate) under the same relationship context.

VAWC includes four broad categories of abuse:

Physical violence (e.g., hitting, slapping, choking, pushing, restraining, causing injury)
Sexual violence (e.g., coerced sexual acts, marital/dating sexual abuse, sexual harassment within the relationship context)
Psychological violence (e.g., threats, intimidation, stalking, humiliation, public shaming, repeated verbal abuse, harassment, controlling behavior)
Economic abuse (e.g., withholding financial support, controlling money, destroying property needed for livelihood, preventing the victim from working, forcing debt)

A witness affidavit becomes important because VAWC often happens inside the home or private spaces, and the case may depend heavily on credible, detailed, consistent narratives supported by documents and corroborating witnesses.

2) What a witness affidavit is—and what it is used for

A witness affidavit is a written, sworn statement of facts personally known to the witness. In VAWC matters, it is commonly used for:

Police complaint / blotter support
- While police blotter entries are not “proof” by themselves, affidavits help fix details early.
Filing the criminal complaint with the Prosecutor’s Office (preliminary investigation)
- VAWC complaints are typically supported by the victim’s affidavit and witness affidavits plus attachments.
Protection order applications
- Barangay Protection Order (BPO), Temporary Protection Order (TPO), and Permanent Protection Order (PPO) applications often rely on sworn statements to show urgency and risk.
Court proceedings (trial)
- A witness affidavit may become part of the records and can be used to test consistency. Ultimately, the witness usually must still testify in court if the case proceeds to trial, unless rules allow affidavit-based testimony in a particular situation and the other side’s rights are protected.

Core point: an affidavit is not a substitute for truthfulness and personal knowledge. It is a formal way to preserve testimony under oath and expose the affiant to perjury if the statement is deliberately false.

3) What makes a witness affidavit strong in VAWC cases

A strong affidavit is:

Based on personal knowledge (what the witness saw, heard, observed firsthand)
Specific (dates, times, places, exact words if remembered, sequence of events)
Chronological (easy to follow)
Fact-focused (avoid legal conclusions like “he is guilty,” “it was psychological violence” — describe the acts instead)
Consistent with other affidavits and documents
Corroborated by attachments when possible (photos, screenshots, medical records, chat logs, barangay records, CCTV, call logs)

4) Who can be a witness in a VAWC case

Common witnesses include:

Neighbors who heard shouting, threats, or witnessed injuries afterward
Relatives who saw injuries, received disclosures immediately after the incident, or witnessed harassment
Co-workers who witnessed stalking, repeated calls, workplace confrontations, or distress
Barangay officials / tanods who responded to an incident
Medical personnel (usually through medical records and testimony when needed)
Friends who received contemporaneous messages or calls and can identify the sender and context

Important: A witness can testify to:

What they personally observed (injuries, torn clothes, property damage, behavior, demeanor)
What they personally heard (threats, admissions, phone calls on speaker)
Messages they personally received or personally saw on the victim’s device (best if supported by screenshots and device identification)

But a witness should be careful with hearsay (repeating what others said). Some hearsay can still be useful for context and may fall under recognized exceptions depending on circumstances, but the safest affidavit emphasizes firsthand facts.

5) Notarization and oath requirements (Philippine practice)

A witness affidavit must generally be:

In writing, signed by the affiant
Sworn to before a notary public (or other officer authorized to administer oaths, depending on context)
Done with personal appearance of the witness before the notary and proper identity verification

Because VAWC involves safety concerns, witnesses sometimes worry about address disclosure. In practice, courts and prosecutors still need sufficient identity and contact details for due process, but counsel may take protective measures when warranted (e.g., requesting confidentiality protections, limiting public exposure, or invoking special rules for child witnesses). Never falsify address/identity—this can damage the case and expose the witness to liability.

6) Anatomy of a proper witness affidavit

Most affidavits in the Philippines follow a familiar structure:

Caption (Republic of the Philippines, Province/City, “S.S.”)
Title (“AFFIDAVIT OF WITNESS”)
Personal circumstances (name, age, civil status, citizenship, address)
Oath clause (“after having been duly sworn…”)
Numbered statements of fact
Purpose clause (why executed)
Signature of affiant
Jurat (Subscribed and sworn…) with notary details and document entries

7) What to include (VAWC-focused checklist)

A witness affidavit is most helpful when it answers these:

A. Relationship & basis of knowledge

How the witness knows the victim and/or respondent
How often the witness sees them
Why the witness is in a position to know the facts

B. Incident details (for each relevant event)

Date and time (or best estimate)
Place
What happened step-by-step
What the witness saw/heard (include exact words of threats if remembered)
Condition of the victim afterward (injuries, crying, shaking, bruises, torn clothing)
Any property damage the witness personally saw
Presence of children and what they witnessed/experienced (be careful and factual)

C. After-incident actions

Whether police/barangay were called
Whether the witness accompanied the victim to the hospital, barangay, or police station
Whether the witness saw medical findings or took photos (attach if lawful and available)

D. Pattern evidence (if applicable)

Previous similar incidents the witness personally observed
Repeated harassment (calls, stalking, workplace visits)
Economic control the witness personally witnessed (e.g., respondent forcibly taking salary, refusing support while the witness was present)

E. Risk & threats

Threats to kill, harm, take the children, or self-harm threats used to control
Stalking behaviors witnessed
Weapons seen (only if personally seen)

F. Attachments

Label as Annex “A,” “B,” etc.
Briefly identify each attachment

8) Common mistakes that weaken affidavits

Avoid these:

Vague statements (“He always hurts her,” “He is abusive”) with no dates/details
Overstating or guessing (courts and prosecutors notice exaggerations)
Copy-paste affidavits that look identical across witnesses
Legal conclusions instead of facts
Hearsay-heavy narratives without firsthand observations
Inconsistencies with medical records, photos, or timelines
Omitting key identifiers (who, where, when, what exactly was said/done)

9) Sample Witness Affidavit Template (General VAWC Incident)

REPUBLIC OF THE PHILIPPINES ) CITY/MUNICIPALITY OF ________ ) S.S.

AFFIDAVIT OF WITNESS

I, [FULL NAME OF WITNESS], of legal age, [civil status], Filipino, and residing at [complete address], after having been duly sworn in accordance with law, hereby depose and state that:

I am the [relationship] of [NAME OF VICTIM] (“Victim”) and I have known her for about [number] years. I personally know [NAME OF RESPONDENT] (“Respondent”) as [husband/live-in partner/boyfriend/former partner] of the Victim.
I am executing this Affidavit to truthfully narrate facts that I personally witnessed/observed relevant to the complaint for violence against women and/or her child/children.

A. Incident on [DATE] at [PLACE]

On [date], at around [time], I was at [exact place/address or landmark] because [reason you were there].
At that time, I personally saw the Respondent [describe acts in detail: e.g., “grab the Victim by the arm,” “push her against the wall,” “strike her with his open hand,” “throw a chair,” etc.].
I also personally heard the Respondent shout the following words (or words to this effect): “[quote as accurately as possible]”. The Victim responded by [describe].
I observed that the Victim was [crying/shaking/trying to leave] and appeared [afraid/distressed]. I saw [visible injury] such as [bruise/redness/cut] on her [body part] immediately after the incident.
[If you intervened or sought help] I then [intervened/called for help/called barangay/police]. [Name of person/authority] arrived at around [time].

B. After the incident (injuries, reporting, medical care)

After the incident, I accompanied / saw the Victim [go to the barangay/police station/hospital] on [date]. At the [place], I observed [what you personally observed—injuries, demeanor, etc.].
I also personally saw [photos/screenshots/medical certificate] on [date], which I understand are relevant. (If you are attaching copies, state: “Attached are true copies marked as Annex ‘A’, ‘B’, etc.”)

C. Other incidents / pattern personally known (optional)

Aside from the above, I personally witnessed the following prior incident/s involving the Respondent and the Victim:

a. On [date] at [place], I saw/heard [describe]. b. On [date] at [place], I saw/heard [describe].

I also personally observed the Respondent [harass/stalk/threaten/control finances] by [describe specific acts: repeated calls, showing up, taking money, refusing support while present, etc.] on [dates or date range].

D. Threats and risk (optional but important if true)

I personally heard the Respondent threaten the Victim by saying “[quote]” on [date] at [place]. Because of this, I believe the Victim has reason to fear for her safety.

E. Closing

I am willing to testify in any investigation or court proceeding regarding the foregoing facts.
I am executing this Affidavit to attest to the truth of the foregoing and for whatever legal purpose it may serve.

IN WITNESS WHEREOF, I have hereunto affixed my signature this ___ day of ______ 20__ in [City/Municipality], Philippines.

[NAME OF WITNESS] Affiant

SUBSCRIBED AND SWORN to before me this ___ day of ______ 20__ in [City/Municipality], Philippines, affiant exhibiting to me competent proof of identity, [ID type and number], with [date/place of issuance].

Notary Public

Doc. No. ____; Page No. ____; Book No. __; Series of 20.

10) Sample Witness Affidavit Template (Psychological Violence / Harassment via Calls & Messages)

REPUBLIC OF THE PHILIPPINES ) CITY/MUNICIPALITY OF ________ ) S.S.

AFFIDAVIT OF WITNESS

I, [FULL NAME], of legal age, [civil status], Filipino, and residing at [address], after having been duly sworn, depose and state:

I personally know [Victim] as my [relationship] and I have known her since [year].
On [date], at around [time], while I was with the Victim at [place], I personally observed her receive repeated calls/messages from the Respondent [name].
The Victim placed the call on speaker / showed me her phone screen. I personally heard/read the Respondent say/message: “[quote or paraphrase accurately]”.
The calls/messages were made repeatedly from [time range], totaling about [estimate] times. The Victim appeared [crying/shaking/panicking] and told the Respondent to stop contacting her. Despite this, the Respondent continued.
On [date], I personally witnessed the Respondent appear at [place/workplace/home] and [describe: shouted, demanded to see her, blocked her path, followed her].
Attached are screenshots that the Victim showed me, which I saw on [date], marked as Annex “A” to “__”. I can identify these as the same messages I personally saw on her phone at that time.
I am executing this Affidavit to attest to these facts and I am willing to testify if required.

IN WITNESS WHEREOF, I sign this ___ day of ______ 20__ in [City/Municipality], Philippines.

[NAME] Affiant

SUBSCRIBED AND SWORN to before me… (notarial jurat block as above)

11) Practical tips for witnesses (comfort + credibility)

Write what you personally know, not what you assume.
If you can’t remember the exact time, state it as an estimate (“at around 10:00 p.m., more or less”).
If quoting words, be honest if you only remember the substance (“words to this effect”).
Don’t minimize or dramatize—neutral, detailed narration is powerful.
If you fear retaliation, document that fear (threats you personally heard/received) and coordinate safety steps with the victim and appropriate authorities.

12) Quick “fill-in” guide (to speed drafting)

When you draft, gather:

Complete names, relationship, and addresses (as required)
A clean timeline: date → time → place → act → aftermath
Attachments and labels (Annex A, B, C…)
A valid ID for notarization
Consistency check with the victim’s affidavit and documents

If you want, paste the basic facts (who/when/where/what happened and what the witness saw/heard), and I’ll convert them into a polished, notarization-ready witness affidavit in the same format—without changing any facts.