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Republic of the Philippines

Regional Trial Court


Branch 10
La Trinidad, Benguet
THE PEOPLE OF THE PHILIPPINES
Plaintiff,
CRIMINAL CASE
NO. 102355
For
MURDER
-versusDINA A. VERGEN
X-----------------------------------------------------------------------X

JUDICIAL AFFIDAVIT OF
JOSE E. DELA AMZONA

I, JOSE E. DELA AMZONA, of legal age; married; living at


Unit 666 Megawood Tower Condominiums, Gen. Luna St.,
Barangay Upper Session, Baguio City; and the Police Chief
Inspector/ Medico-Legal Officer of the Regional Crime Laboratory
Office-Cordillera, Philippine National Police, Camp Bado Dangwa.
La Trinidad, Benguet; witness in this case, state under oath as
follows:
The person examining me is Atty. Christian Van A. Talawec
with address at Room 69, Living La Vida Loka Bldg., Bokawkaw
Road, Baguio City, for purposes of executing my judicial affidavit
as witness in this case. The examination was held at the same
address. I am answering his questions fully conscious and aware
that Im executing such under oath and may face criminal liability
for false testimony and perjury.
QUESTIONS were advanced and propounded by defendant`s
counsel, Atty. Christian Van A. Talawec in English-British Accent,
which the affiant fully comprehends , while ANSWERS were
delivered by witness Jose E. Dela Amzona, also in English-British
Accent and the corresponding translation of his answers is
provided after each question.
Q1: Do you swear to tell the truth and nothing but the truth?

A1: I do.
Q2: Are you aware that you may face criminal liability for false
testimony or perjury if you will not tell the truth?
A2: I`m definitely aware of such consequences.
Q3: Please state your complete name, age and occupation.
A3: I am Jose E. Dela Amzona, 50 years old. I am a Medical Doctor
and a Medico-Legal Officer.
Q4: Dr. Dela Amzona, where do you work as a Medico-Legal
Officer?
A4: I am a Medico-Legal Officer with a rank of Police Chief
Inspector at the Regional Crime Laboratory Office-Cordillera,
Philippine National Police, Camp Bado Dangwa. La Trinidad,
Benguet.
Q5: How long have you been practicing your profession as a
Medico-Legal Officer Dr. Dela Amzona?
A5: 20 years sir.
Q6: Before you became a Medico-Legal Officer of the Philippine
National Police, have you been working as a private medical
practitioner?
A6: Yes I am.
Q7: During your stint as a private medical practitioner, have you
conducted autopsies?
A7: Yes, in private capacity, I have conducted autopsies.
Q8: When did you start practicing your profession as a MedicoLegal Officer in the Regional Crime Laboratory Office-Cordillera,
Philippine National Police, Dr. Dela Amzona?
A8: From 1995 up to present sir.
Q9: In your capacity as a Medico-Legal Officer of the Regional
Crime Laboratory Office-Cordillera, Philippine National Police how

many cadavers have you conducted autopsies from 1995 up to


present Dr. Dela Amzona?
A9: If my memory serve me best, around two thousand (2,000)
bodies excluding autopsies done during the Typhoon Yolanda?
Q10: What do you mean excluding autopsies done during the
Typhoon Yolanda?
A10: We were called to help in the identification of bodies after
the typhoon in Leyte and some of the bodies were subject to
autopsies.
Q11: Dr. Dela Amzona, where were you on June 20, 2006 at
around 9:00 am?
A11: I was in the Regional Crime Laboratory Office-Cordillera,
Philippine National Police, Camp Bado Dangwa. La Trinidad,
Benguet.
Q12: Aside from being the head of your office, what are you doing
there?
A12: I conducted an autopsy requested by the Chief of Police of La
Trinidad, Benguet.
Q13: May I ask to whose remains have you conducted the
autopsy?
A13: I conducted the autopsy on the remains of Ana A. Khankita
sir.
Q14: How are you able to identify that the remains belongs to one
Ana A. Khankita.
A14: Aside from her dental records sir, the remains were
personally and visually identified by the mother of the victim,
Maria A. Khankita.
Q15: Did Ms. Khankita died in La Trinidad, Benguet?
A15: Yes sir, to be more specific at Betag, La Trinidad, Benguet.
Q16: When was the body of Ms. Khnakita found?
A16: On June 19, 2006 at around 5:00 pm.

Q17: Dr. Dela Amzona, what was the state of the body of Ms.
Khnakita when you conducted such autopsy?
A17: The body was previously embalmed adult female with
embalming incisions on the different parts of the body. Her body
is fairly developed and fairly nourished. There were external
injuries that were visibly seen in Ms. Khankita`s body sir.
Q18: What are these external injuries, Dr. Dela Amzona?
A18: These comprise of multiple stab wounds located on the
head, neck, thorax, abdomen and some incised wound on her
extremities.
Q19: Can you described to us these external injuries?
A19: Yes sir, based on my external findings, there was a stab
wound, penetrating, at the right anterior neck region, measuring
3 x 0.5cm in widest dimension and a stab wound, penetrating, at
the left anterior neck region, measuring 3x 0.5cm in widest
dimension.
Q20: What is the effect of such stab wounds in the neck region Dr.
Dela Amzona?
A20: Basically, it has injured the right and left neck muscles and
major blood vessels of the same area.
Q21: As you said there were also stab wounds on the thorax and
abdominal area, can you please described it to us?
A21: Yes sir, there was a stab wound, non-penetrating, left
pectoral region, measuring 1x1 cm in widest dimension; also
there were stab wounds, penetrating, at the level of Vth rib and
VIIth rib, along the left anterior axillary line, both measuring
3x0.5cm in widest dimension; and stab wounds, penetrating, at
the level of the VIIIth and IIIrd ribs, along the left mid-axillary line,
measuring 3x0.5cm in widest dimensions.
Q22: Dr. Dela Amzona, these various or should I say multiple stab
wounds, what injuries it had caused internally on the victim`s
body based on your finding?
A22: Sir, such multiple stab wounds had penetrated the left
thoracic cavity, causing injuries to the lower lobe of the left lung
and the stab wound at the level of VIIth rib, along the left anterior

axillary line and the stab wound, at the level of the VIIIth rib,
along the left mid-axillary line had also caused injury at the apex
of the heart. These stab wounds had also caused massive
hemothorax on the victim, around 800 ml of blood clots.
Q23: Based on your findings doctor, what is the cause of the
death of Ms. Khankita?
A23: The cause of death sir is heart and left lung injuries,
secondary to multiple stab wounds which had resulted to massive
blood loss in the victim causing her death. Further, based on my
finding you can categorize such manner of death to be a violent
death due to stabbing.
Q24: Are all your findings reduced in writing Dr. Dela Amzona?
A24: Yes sir, there is an autopsy report.
Q25: Where is the autopsy report?
A25: It is currently in my possession at this moment, sir.
Q26: Am I permitted in marking this autopsy report as Exhibit A
and the bracketed signature above the name of Jose E. Dela
Amzona as Exh. A-1?
A26: Yes sir.
Q27: Are you the same Jose E. Dela Amzona, the Medico-Legal
Officer who conducted the autopsy in this case?
A27: Yes, sir.
Q28: Is the signature affixed in the autopsy report your signature
doctor?
A28: Yes, the signature affixed in the autopsy report of Ms.
Khankita is my signature.
Q29: I am attaching Exhibit A to your judicial affidavit to form part
of it. Do you confirm my action?
A29: Yes, sir.
.................................

Affiant further sayeth naught.


IN WITNESS WHEREOF, I have hereunto set my hand this 3 rd
Day of September 2006 at Room 69, Living La Vida Loka Bldg.,
Bokawkaw Road, Baguio City.

JOSE E. DELA AMZONA, MD


Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in


and for Baguio this 3rd Day of September 2006. Affiant personally
came and satisfactorily proven his identity with license id issued
on May 5, 1992 by the Professional Regulation Commission on the
2nd Day of September 2006 at my office located at Room 69,
Living La Vida Loka Bldg., Bokawkaw Road, Baguio City bearing
his photograph and signature, known to me as the same person
who personally signed the foregoing instrument before me and
avowed under penalty of law to the whole truth of the contents of
said instrument.

ATTY. CHRISTIAN VAN A. TALAWEC


Notary Public
Until December 31, 2006
Commission Serial No. 85-NC-!!
Office: Room 69, Living La Vida Loka Bldg., Bokawkaw Road,
Baguio City.
(076) 442-0986/ 09999663496
PTR No. 7890678; 8-22-90
IBP Lifetime Membership No. 08976564 Baguio-Benguet
MCLE No. IV-0006789, 7-21-05

Doc. No. _________.


Page No. _________.
Book No. _________.
Series of 2006

ATTESTATION
I, Atty. Christian Van A. Talawec, of legal age, Filipino, with
postal address 23 Baliwag St. Kalapati Hill, Baguio City, after
being duly sworn depose and say:
1. I was the one who conducted the examination of witness
Jose E. Dela Amzona at my aforementioned office in Room
69, Living La Vida Loka Bldg., Bokawkaw Road, Baguio City;
2. I have faithfully recorded or caused to be recorded the
questions I asked and the corresponding answer that the
witness gave;
3. I nor any other person then present or assisting him coached
the witness regarding his answer;
IN WITNESS WHEREOF, I have hereunto set my hand this 3 rd
Day of September 2006 at Room 69, Living La Vida Loka Bldg.,
Bokawkaw Road, Baguio City.

ATTY. CHRISTIAN VAN A. TALAWEC


Notary Public
Until December 31, 2006
Commission Serial No. 85-NC-11

Office: Room 69, Living La Vida Loka Bldg., Bokawkaw Road,


Baguio City.
(076) 442-0986/ 09999663496
PTR No. 7890678; 8-22-90
IBP Lifetime Membership No. 08976564 Baguio-Benguet
MCLE No. IV-0006789, 7-21-05

Doc. No. _________.


Page No. _________.
Book No. _________.
Series of 2006

Copy Furnished:
Office of the City Public Prosecutor