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Republic of the Philippines

Municipal Trial Court in Cities

10th Judicial Region



- versus- For:

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I, , of legal age, single, Filipino and a resident of #120 Sto. Nino, Lapasan, Cagayan de
Oro City, Philippines, after having been sworn to an oath in accordance with law do hereby
state that:

1. I am the accused in the above titled case for the alleged commission of the crime of
Grave Threat;

2. I actually received a copy of the Order issued by the Honorable Court on April 12,

3. As I am directed by the Honorable Court to submit my Counter-Affidavit within ten

(10) days from receipt of the Order, the filing of this Counter-Affidavit is therefore
done within the reglamentary period;

4. I am the same accused in the same entitled case;

5. I and the private complainant are neighbors, and the house of the private complainant
stands across ours;

6. I deny all the allegations in the complaint for being false, sham, malicious, pure
fabrication, the truth of the matter being that:

a. On October 6, 2016 at around 10 o’clock in the morning, I was having my

breakfast when I noticed a bad smell;
b. I looked where the smell came from, and when I went outside, I noticed that
the road was very wet out of the water liberally coming from the residence of
the private complainant;
c. When I checked, the water came from the sewer of the private complainant;
d. I called the private complainant who was inside her house at that time, and
said, “Unsa man ni Te? Baho man kayo. Bantog ra wala koy customer sa akong
Pisonet” (What is this, Te. It smells so bad. That’s why I have no customer in my
e. Then the private complainant went out in an angry gesture, his right hand
tucked in her waist, and said in a very rude voice, “Ngano man di ay, dong? Ako
man ning katungod”.
f. I replied, “Imo bitaw ni katungod pero baho kayo, naghangyo na baya ko nga
gabei lang unta ka magpaagas kay naa ko mga kustomer sa pisonet, dili na sila
ganahan maggamit diri. Basa pa gyod kaayo, gakadala sa mga gasulod ang basa
sa among salog, wala baya mi helper, tiguwang na pa gyod na akong mama
luoy kaayo sigeg panglimpyo”.
g. Complainant was so adamant and murmured insulting words so I lost the
respect I initially showed her and so I said, “Unsa man di ay gusto ninyo Te?
Away gyod? Pamikil man gyod na imoha. Gapangita man jud kag gubot, bwisit,
putang ina!”
h. At the precise moment, his son shouted from the window, “Ayaw pagsinggit sa
akong inahan wala kay katungod!”;
i. I looked at her son and said, “Ngano mag apil apil ka? Ali diri sumbagay ta, laki
sa laki”;
j. It was then that my Uncle Rene Candelon came in and told me to get inside the

7. It is not true that I threatened the private complainant, and as a consequence, she was
damaged and prejudiced;

8. I can never do any act that amounts to threat against the private complainant. We
have been good neighbors since I was a kid and I accorded her respect and courtesy
as an aunt. Hence, the allegation that I was moved by personal resentment against her
is absolutely false, there being no reason to feel that way;

9. In view of the points cited in this affidavit, I respectfully pray that this criminal
complaint be dismissed for being false, groundless and simply unfounded;

10. Finally, I execute this counter-affidavit to establish the truth of the foregoing
statements and for whatever purposes it may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 29th day of April 2016, at
Cagayan de Oro City.


SUBSCRIBED AND SWORN to before me this 29th day of April 2016, at Cagayan de
Oro City. I hereby certify that I have personally examined the affiant and was satisfied that
he voluntarily executed the foregoing affidavit and fully understood the contents thereof.