The undersigned, _____________, accuses _____________ of the crime of FORCIBLE ABDUCTION, committed as follows, to wit:
That on or about _____________, at about __________ (a.m./p.m.), in the City/Municipality of _____________, Province of _____________ and within the jurisdiction of this Honorable Court, the said accused, did then and there willfully, unlawfully and feloniously abduct a woman named _____________ who is a minor of 14 years while she was on her way home from school, taking and carrying her away on board a black passenger van, against her will and with lewd designs.
Contrary to law.
_____________, Philippines, __Date__.