The villain files the complaint first. (The wrongdoer accuses others first.)
Tips
usage
做恶人 or 当恶人 often means 'to be the one who delivers bad news or enforces unpopular rules' - not necessarily truly evil, just the person willing to say no.
memory
恶 (è) has the heart radical 心 at the bottom - evil comes from the heart. An 恶人 is a person with an evil heart.