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REPUBLIC OF THE PHILIPPINES )

CITY OF SURIGAO )
S.S.

COUNTER AFFIDAVIT
I, VICTOR A. LODI, Filipino, 35 years old, with address at
SitioCayutan, Barangay Cagniog, Surigao City, after having sworn to in
accordance with the law, do hereby depose and state that:

1. That I am employed as Clerk I at the Office of the Governer in


Provincial Capitol Compound;
2. That I did not rape or molested the Complainant;
3. That the truth is that me and the Complainant are in an intimate
relationship as lovers;
4. That there is no truth to the charges being leveled at me. The
statements of the Complainant and her witnesses are full of lies
and half-truths obviously meant to prop up and strengthen the
fabricated charges;
5. That on the 3rd day of September 2017, at around 12:00 noon, I
had lunch with my common law wife MARIA J. LUNAhereinafter
as “MARIA”, and her daughter TANYA J. LUNA, hereinafter as
“TANYA”;
6. That after we had taken our lunch I noticedTanya went straight
up to her room to rest and sleep;
7. That at around 1:00 PM, Maria went back to her office located in
downtown area of the city;
8. That around the same time Maria left, Tanya transferred from her
room to the living room to watch TV;
9. That I heard Tanya calling my name while she was watching TV
in the living room and asked me to sit beside her;
10. That upon sitting beside her, she begun caressing my groin
and started to kiss my nape then my lips;
11. That I only responded to the initial act of Tanya on the
kissing and caressing;
12. That there was no rape or molestation that transpired on
the said incident but an act of consensual sexual intercourse
between a man and his lover;
13. That, I am therefore executing this affidavit freely and
voluntarily to counter the case for QUALIFIED RAPE filed by
Tanya against me.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that


the instant criminal complaint be DISMISSED for lack of merit and
other reliefs as may be deemed just and equitable in the premises.

Respectfully submitted.

IN WITNESS WHEREOF, I have hereunto set my hand on this


th
15 day of December 2017, in Surigao City, Philippines.

VICTOR A. LODI
Affiant
SUBSCRIBED AND SWORN TO before me this 15th day of December
2017 at Surigao City, Philippines; I hereby certify that I have
personally examined the affiant and that she fully understand the
contents of her Affidavit-Complaint.

ATTY. CALVIN TYRON M. CHAN


Counsel for the Accused
ROLL NO. 7723
PTR No. 3121, Jan. 06, 2017
IBP Life Member No. 0883, Oct. 18, 2004,
Surigao del Norte
MCLE COMPLIANCE NO. III-000455
12/12/13

ATTY. ALEXIES BRIEN D. GOLES


Counsel for the Accused
ROLL NO. 7722
PTR No. 3122, Jan. 06, 2017
IBP Life Member No. 0883, Oct. 18, 2004,
Surigao del Norte
MCLE COMPLIANCE NO. III-000456
12/12/13

ATTY. VANESSA JANE J. GO


Counsel for the Accused
ROLL NO. 7724
PTR No. 3123, Jan. 06, 2017
IBP Life Member No. 0883, Oct. 18, 2004,
Surigao del Norte
MCLE COMPLIANCE NO. III-000457
12/12/13

COPY FURNISHED:
PROSECUTOR CHIVAS DULGUIME
Asst. City Prosecutor
ROLL NO. 7777
PTR No. 3131, Jan. 03, 2017
IBP Life Member No. 0888, Oct. 18, 2004, SurigaodelNorte
MCLE COMPLIANCE NO. III-000555 12/12/12

ATTY. IZA MAE S. DOTILLOS


CITY PROSECUTOR
ROLL NO. 7777, PTR No. 3131, Jan. 03, 2017
IBP Life Member No. 0888, Oct. 18, 2004, SurigaodelNorte
MCLE COMPLIANCE NO. III-000555 11/11/11

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