Republic of the Philippines

REGIONAL TRIAL COURT

6TH Judicial Region
Branch 1
Bacolod City, Negros Occidental

PEOPLE OF THE PHILIPPINES,

Plaintiff,

CRIM. CASE No.

-versus-

FOR: PHYSICAL ABUSE IN

RELATION TO R.A.9262

MAR PUNO,
Accused.
X- - - - - - - - - - - - - - - - - - - - - - - /

JUDICIAL AFFIDAVIT
OF ANGELIE DELON

I, ANGELIE DELON, 30 years old, single , residing at 143 Cutie

St., Bacolod City, after having been sworn to in accordance with the
law do hereby depose and state:
That Atty. Mark John Simondo is the counsel who conducted and
supervised my examination as a witness at his office located in
Simondo & Tan Law Office, O Residences, Mandalagan, Bacolod City;
That I am answering the questions herein fully conscious that I
do so under oath and that I may be criminally liable for false testimony
or perjury;

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The following are the Questions propounded by Atty. Mark

Simondo and my answers in English language:
Q1:

Do you swear to tell the truth and nothing but the truth?

A1:

Yes Sir.

Q2:

Do you know Gretchen, the complainant in this case?

A2:

Yes, Sir. She is my first cousin. Our mothers are sisters.

Q3:

Do you have a good relationship with her?

A3:

I consider her as my closest relative. She is like a sister to me

since I am an only child.

Q4:

Do you still talk or see Gretchen from time to time?

A4:

Since I moved out from our house I have seen her once during a
family occasion.

Q5:

So you and Gretchen lived together?

A5:

Yes,Sir. After I left my job as a teacher in Macau, I moved back

to the Philippines and Gretchen told me I could stay with her and
Carlos.

Q6:

So what happened next?

A6:

I moved in with Gretchen and Carlos in January 2014.

Q7:

How was it like living with Gretchen?

A7:

It was good. I mean, Gretch is like a sister to me. We were

always close ever since we were little.

Q8:

And what happened next?

A8:

A few weeks after I moved in Gretch told me she was dating

someone else. This came as a surprise to me since I knew she
and her ex girlfriend separated just about a month ago.

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Q9:

Were you able to meet this alleged person she was dating?

A9:

Yes, she introduced me to a guy name Totoy Mascuvado.

Q10: And what was your impression of Totoy?

A10: Well at first he seemed okay. Gretch told me she was in love and
to me thats all that mattered
Q11: What do you mean at first?
A11: Well I started hearing rumors around town that Totoy was
actually a drug pusher.
Q12: How did you react to this news?
A12: I never really bothered with it. To me, rumors are just that
rumors.
Q13: So you have never actually seen Totoy sell drugs?
A13: There was one time that I came home really late. When I got to
the house I saw four other men, none of whom I knew, inside
the living room. As soon as Totoy and Gretchen saw me one of
the guys handed Totoy money and Totoy in turn handed a small
plastic bag to him. They left right after.
Q14: How do you know that it was drugs?
A14: I was very suspicious so I confronted Gretchen the next day as
soon as Totoy left. To my surprise she didnt deny it.
Q15: What did she say?
A15: Gipit lang gid kami subong. Indi na maliwat. (We are very short
on cash now. It wont happen again.)
Q16: Then what happened?
A16: I got mad and told Gretchen that if I found out it happened again
I would report her and Totoy to the cops.

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Q17: What happened next?

A17: I was shocked because I did not know Gretchen told Totoy about
our confrontation.
Q18: What did Totoy do?
A18: He came barging to my room and was very hysterical. He was so
mad that I suggested to Gretchen that she should leave him. He
told me that if I meddled with them again he would kill me. He
put a knife to my throat
Q19: What were his exact words?
A19: Hoy Angelie! Mabal-an ko pa gani nga ga intra ka sa relasyon
namon ni Gretchen ipa patay ta gid ka. Basi abi mo ga lango
lango ko nga gaga ka ha! (Hey Angelie! If I ever find out that
you are trying to meddle with our relationship, I will have you
killed. I am not joking.)
Q20: Did you tell anyone about this?
A20: Are you kidding me? I feared for my life!
Q21: During your stay with them, did you ever witness Gretchen or
Totoy being violent with Carlos?
A21: Yes. Every time Carlos would do something they did not approve
of they would pinch Carlos or slap him so hard he would always
cry and scream in pain. One time I even saw Gretchen push
Carlos off the chair because he wouldnt finish his dinner.
Q22: Did you try stopping any of them from hurting Carlos?
A22: I did but Totoy would hold a knife and look at me as if to warn
me to back off.
Q23: How else would they be violent towards Carlos, if any?

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A23: They would always curse around him and would shout at him all
the time.
Q24: Did you ever try to talk to Gretchen alone about this?
A24: After that incident when I asked Gretchen to leave Totoy and he
threatened to kill me, Gretchen never spoke to me again. So
even if I wanted to do something she refused to listen to me.
Q25: Then what happened next?
A25: I could no longer take it anymore. I decided to leave the house.
Q26: Did you tell anybody about it?
A26: At first I really kept it to myself because I was still scared of
Totoy. But after a while I felt guilty and scared for Carlos. I tried
getting hold of Mar but according to his household helper he was
abroad for a meeting. I told his maid to inform him to contact
me as soon as he arrives.
Q27: And did Mar contact you?
A27: Yes he did. We saw each other morning of march 15,2015 and I
told him everything.
Q28: Do you hold any grudges or have ill feelings now towards
Gretchen?
A28: No, Sir. All I want is for Gretchen and Carlos to be safe.
Q29: Did you execute any statement regarding any of these?
A29: Yes, I executed an affidavit on __ April 2015.
Q33: If that affidavit is shown to you would you be able to identify it?
A33: Yes, sir.
Q34: Do you have anything else to say, Angelie?
A34: No more, sir.

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IN WITNESS WHEREOF, I have hereunto affixed my signature

this ___day of April 2015 at Bacolod City, Philippines.

ANGELIE DELON
Witness

SUBSCRIBED AND SWORN to before me this ___ day of April

2015 at Bacolod City, Philippines.

MARK JOHN SIMONDO

Counsel of the Accused
Simondo & Tan Law Office
O Residences, Bacolod City
Negros Occidental
MCLE Compliance No. IV 000000
Officer-in-Charge

ATTESTATION OF LEGAL COUNSEL

I, MARK JOHN SIMONDO, Counsel of the accused, with office

at Simondo & Tan Law Office, O Residences, Bacolod City, after having
been sworn to in accordance with the law do hereby depose and say:

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Judicial Affidavit
1. That I have faithfully recorded or caused to be recorded the
questions I asked and the corresponding answers that
witness, ANGELIE DELON, gave;
2. That I have not, nor any other person present or assisting
coached the witness regarding the witness answers; and
3. That I fully understand that any false attestation shall subject
me to disciplinary action, including disbarment.

IN WITNESS WHEREOF, I have hereunto affixed my signature

this ___ day of April 2015 at Bacolod City, Philippines.

MARK JOHN SIMONDO

Counsel for the Accused

SUBSCRIBED AND SWORN to before me this ___ day of April

2015 at Bacolod City, Philippines.

ATTY. ANNA BOON

Public Attorney IV
Public Attorneys Office
Bacolod City, Negros Occidental
MCLE Compliance No. IV 000000
Officer-in-Charge