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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE PROSECUTOR
MAKATI CITY

JUAN D. CRUZ
Complainant,
NPS No. MKT-123-456
-versus- For: Robbery with Homicide

PEDRO C. RODRIGUEZ
Respondent.
x-----------------------------x
COUNTER-AFFIDAVIT OF PEDRO RODRIGUEZ
I, PEDRO C. RODRIGUEZ, of legal age, Filipino and with residential address at 1234
Dreamhomes Village, San Mateo, Rizal, after having been duly sworn to in accordance with law,
do hereby depose and say:
1. That I am the same person who is charged with the crime of ROBBERY
WITH HOMICIDE pending before the Office of the Prosecutor of Makati
City, docketed as NPS No. MKT-123-456;

2. That in order to controvert the allegations of JUAN D. CRUZ (herein


referred to as “Private Complainant”) in his complaint-affidavit dated 17
May 2019, I am hereby recounting the truthful narration of facts that
transpired on 16 May 2019;

3. That I am a former employee of the 7/11 store across ABC Building along
Makati Avenue, and the said store is owned by the Private Complainant;

4. That on 2 November 2018, Private Complainant explained to us that he had


to terminate some employees due to business reverses, but he promised to
give separation pay in addition to the unpaid salary;

5. That on 15 November 2018, Private Complainant informed me that I am


one of the employees who will be terminated and my last day of work is on
30 November 2018;
6. That after one (1) month from the last day of my work, Private Complainant
failed to give my last salary and the separation pay he promised;

7. That I wrote several letters to him demanding my salary and separation pay,
but he did not respond to any of my demands;

8. That on 8 February 2019, I went to the 7/11 store to talk to the store manager
about my unpaid salary and separation pay, and I found out that even the
remaining employees of the store are still unpaid since December 2018
because of Private Complainant’s gambling losses;

9. That after sending numerous demand letters for my unpaid salary and
separation pay, I decided to meet Private Complainant in front of his
condominium building on 16 May 2019;

10. That upon seeing Private Complainant, I asked him if he could spare me
some of his time, but he denied my request and yelled at me saying, “Umalis
ka nga ditong hampas-lupa ka!” to which I replied “Bayaran mo muna
kaming mga empleyado mo bago ka mag sugal!”;

11. That Private Complainant hailed a taxi from across the road, and I pursued
him until inside the taxi so he could listen to my demands;

12. That upon entering the taxi, I asked Private Complainant to give me my
salary and separation pay immediately so I can buy medicine for my sick
child;

13. When Private Complainant reached for his bag, I closed my eyes and sighed
in relief because I thought he will finally pay me;

14. I opened my eyes immediately when I felt a cold metal pointed towards my
temple, and to my surprise, Private Complainant was already pointing his
gun towards my head;

15. I grabbed Private Complainant’s hands quickly to get rid of the gun and the
taxi driver turned to us from the front seat to help me steal the gun from
Private Complainant’s hands;

16. After a few seconds, two (2) gunshots came and the three of us loosened
our grip on the gun;

17. The taxi driver fell and I saw him bleeding;


18. Out of panic, I grabbed Private Complainant’s bag and left the taxi
immediately;

19. This Counter-Affidavit is being executed to attest to the truth of all the
foregoing facts and events, and to disclaim all the accusations against me.

IN WITNESS WHEREOF, I have hereunto set my hand this 28th day of May 2019 in the
City of Makati.

PEDRO C. RODRIGUEZ
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME this 28th day of May 2019 in the City of
Makati, affiant exhibiting to me his competent evidence of identity: Passport No. EC95095 issued
on 16 April 2018 at DFA Manila.

WITNESS MY HAND AND SEAL on the date and in the place above-written.

MATT U. LUNGIN
Notary Public for the City of Makati
Appointment No. 95959595
Commission Expires on 31 December 2019
Roll of Attorney No. 123456
PTR No. 949596
IBP No. 969798
MCLE Compliance No. 989997
Unit 143, Xavier Bldg., Makati City

Doc. No. 13
Page No. 3
Book No. 1
Series of 2019

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