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Complainant For: RAPE (Art. 266-A, RPC)





I, PEDRO MASAHOL, of legal age, a Filipino Citizen and a resident of Unit 101 MHLY
Bldg. Mandaluyong City after having sworn in accordance with the law hereby depose and state that:

1. I am the accused in the I.S no. 761243 for the crime of Rape under Article 266-A of the
Revised Penal Code;

2. I am employed as a bank officer at RCBC located at RCBC Plaza, Ayala Ave.,
Makati City since February 1994

3. I admit the allegation I am the owner of the Toyota Camry with Plate number XXX

4. I admit the allegation that Juana went inside my Toyota Camyry on August 14, 2014
at around 6 in the morning;

5. I vehemently deny that Juana and I are strangers to each other, the truth being that:

a. Juana and I are in a romantic relationship for about 2 months starting from
early June of this year 2014 (see Annex A);

b. Juana and I met at AAA restaurant where she works as a waitress sometime in
April of this year;

c. I frequent the restaurant to have dinner either with myself or with my
officemates because of the good food and great service;

d. The more I go and dine in the restaurant, I am starting to notice the Juana
because she was good-looking young woman with fair complexion and a long
shiny hair;

e. I took the courage to ask for her number and she fortunately obliged to relay
the information to me;

f. Soon thereafter, we would share text messages after her shift in the restaurant
(see Annexes B,C and D)

6. I strongly deny the allegations that I asked Juana about directions where to see the
nearest remittance center, the truth being that:

a. Juana texted me that she wanted to see me early morning of August 14, 2014
(see Annex E);

b. There is no logical reason why would I ask where is a remittance center
because it is early in the morning. Regular business hours start either 8 am or
9 am;

7. I fervently deny that I pointed a gun at hear during that morning, the truth being that I
am not an owner of a gun or any other firearm for that matter;

8. I vehemently deny that I tried to rape Juana that faithful morning, that truth being

a. When she entered the car, we kissed each other in the cheeks and lips like we
usually do when we already have a romantic relationship with each other;

b. After we kissed, she was crying because of a certain which she did not
disclose to me;

c. She kept saying Di ba sabi mo, gagawin mo lahat para sa akin dahil mahal
mo ako?;

d. I reluctantly said yes, and afterwards she said kailangan ko ng 200 thousand
ngayong araw kasi may problema ako dun sa restaurant;

e. I was shocked and ask her follow-up questions regarding her problems in the

f. To my surprise, she suddenly became angry and she shouted Matutulongan
mo ba ako o hindi?;

g. I said wala ako ganun kalaking halaga ngayong araw;

h. She became really mad and she kicked me in the groin;

i. She said that kung hindi mo kayang tulungan, irereklamo kita na ni-RAPE
mo ako;

j. I was surprised when she said those words and all I know was she was
suddenly taking her clothes-off piece by piece until she was completely naked
and used a sharp object from her purse which she used to self-inflict some
wounds in her private organs;

k. I tried to stop her but everytime I touch any part of her, she would cry and
shout Rapist ka, layuan mo ako, hayop ka ;

l. When I try to drive the car away from the lot because her cry for help is
getting louder and louder;

m. As I was trying to steer slowly the car away from the scene, Juana again
kicked my groin and without hesitation jumped off my moving car after
opening the car door.

9. I specifically deny that Juana was still a minor when we had a romantic relationship
because I relied on her text message that she was no longer a minor. She actually
texted me that she was already 18 years old (see annex B)

10. I am executing this Counter-Affidavit for the purpose of attesting to the truth of the
foregoing statement, to inform the proper authorities of the above facts, to support my
prayer for the dropping or dismissal of the instant case against me and for whatever
purpose this may serve best.

IN WITNESS WHEREOF, I have hereunto set my hand this 9
day of September, 2014
at Mandaluyong City, Philippines


SUBSCRIBED AND SWORN TO before me this 9
day of September, 2014 at
Mandalayong City, Philippines

Baby G. Shock
Prosecutor I


ANNEX A. The first text message exchanges between Juana Dela Cruz and Pedro Masahol

Various text messages showing how they started to get to know each other before they had a
romantic relationship

Text messages showing that Juana and Pedro are in a romantic relationship

An exchange of text message between Juana and Pedro during August 13, 2014.