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Republic of the Philippines

Sixth Judicial Region


METROPOLITAN TRIAL COURT
Bacolod City
Branch 001
PEOPLE OF THE PHILIPPINES
-versus-

FOR: Other Light Threats


Article 285 of the Revised Penal Code

RUFINA L. CALIWAN
x-------------------------------------------------x
MOTION FOR BILL OF PARTICULARS
Defendant, through the undersigned counsel and unto this Honorable Court,
respectfully avers:
1. That the plaintiffs complaints in paragraph 3 of Ofelia Ocampo and Paragraph 4
Rhodora Pasilona alleges:
Ocampo:
However, on the evening of the same day, at around 10:30, I heard Rufina
Caliwan shouting, and I peeped through the window, I saw her standing just
outside her house with her friends, facing our house and loudly uttering
slanderous and threatening words in Tagalog Dialect, x x x.
Pasilona:
That at around 10:30 oclock in the evening of the same day, I was already
in my room when I heard someone is shouting outside, I suddenly went out of
my room saw Maam Ofelia peeping on the window, I in turn, did the same
and peeped on the window, I saw Rufina and 3 other people standing outside
her house, facing towards the direction of our house, while she was uttering
slanderous and threatening words in Tagalog Dialect x x x. (emphasis
supplied)
2. The said allegation is not averred with sufficient definiteness and particularity,
specifically it does not mention to whom are the words directed;
3. That a more definite statement on the matters as above-indicated is necessary in
order to enable the defendant to prepare its responsive pleading because from

the very onset of this controversy, the main dispute was to whom was actually
and exactly are the words directed;
4. That a bill of particulars or a more definite statement as to particulars of the said
act which was allegedly done by the defendant would definitely simplify the issue
in the case, and uncomplicated the matters for the defendant.

PRAYER
WHEREFORE, defendant most respectfully prays that an order be issued by this
Honorable Court requiring the plaintiffs to make more definite statement as to the
particulars of the act mentioned in paragraph 4 and 3 in their complaint, particularly to
whom are the words uttered directed.
Bacolod City, Philippines, March 10 2016.
By
Filimon Sy
IBP No. 827847, 6/8/15, BC
PTR No. 576784, 6/8/15, BC
Attorneys Roll No. 12345
MCLE Compliance No. 11-055555
MCLE Compliance No. 111-005555
Copy furnished:
Atty. Isla Tambasakan
Counsel for the Plaintiffs
Ofelia Ocampo
Rhodora Pasilona

Notice of Hearing
To Hon. Branch Clerk of Court
RTC Bacolod City, Branch 69
Atty. Isla Tambasakan
Counsel for the Plaintiff
Please take notice that the foregoing motion will be submitted, and is requested to be
submitted for the consideration and approval of the Honorable Court on 11 March 2016,
at 9:30 AM or soon thereafter as matter and counsel may be heard on notice.
Filimon Sy
Counsel for the Defendant

Republic of the Philippines


Sixth Judicial Region
METROPOLITAN TRIAL COURT
Bacolod City
Branch 001
PEOPLE OF THE PHILIPPINES
-versus-

FOR: Other Light Threats


Article 285 of the Revised Penal Code

RUFINA L. CALIWAN
x-------------------------------------------x
Counter-Affidavit
I, RUFINA L. CALIWAN, 32 years old, Filipino, single, and a resident of Hipos
St., Malinong Village, Barangay Malinong, Bacolod City, Negros Occidental, after having
been duly sworn to in accordance with law, do hereby depose and say:
1. I am the same RUFINA CALIWAN, respondent in the Criminal Case for Other
Light Threats under Article 285 of the Revised Penal Code;
2. I am executing this counter-affidavit to refute the allegations of OFELIA
OCAMPO, RHODORA PASILONA;
3. That Ofelia Ocampo, Rhodora Pasilona were conniving and lying under oath
because the complaints and their affidavits were in response to the complaint I
earlier filed before this Honorable Office, and that Ofelia Ocampo and Rhodora
Pasilona filed this complaint to harass and vex me and to even the grounds with
me in the relation to the complaint I earlier filed against them and Mario Ocampo;
4. That these allegations are groundless and blatant fabrications for (1) I was
actually the one that was slandered and (2) Mr. Mario Ocampo has for several
times, intimidated and threatened me with his gun;
5. On September 4, 2014, I celebrated my birthday with my friends in my house at
Barangay Malinong Village, Bacolod City;

6. In the evening of the same day, while I and my friends were having fun, I heard a
sound of an small impact on my roof, at first, I did not mind, however, I kept on
hearing it; as went outside I saw stones flying towards my roof coming from the
direction of the house of Spouses Mario Ocampo and Ofelia Ocampo;
7. Later in the evening, while my guest and I were singing on the Karaoke, Rhodora
Pasilona and Ofelia Ocampo were outside their house next to my house,
shouting slanderous words against me in Tagalog Dialect, quoted hereunder,
POK-POK, PUTA, BOBO, SIRA ULO, TARANTADA KA!, and if the same were
translated into English it means, you are a prostitute, whore, dull, insane, idiot,
these slanderous words were uttered by Ofelia Ocampo in the presence of my
guests;
8. I never in any manner threatened nor uttered slanderous words against Ofelia
Ocampo and Rhodora Pasilona, for I am aware and afraid of the position of
SPO4 Mario Ocampo being a policeman who has a service firearm. I am afraid of
him.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 10 th day of
March 2016, at Bacolod City, Philippines.

RCaliwan

RUFINA L. CALIWAN
Affiant

SUBSCRIBED AND SWORN to before me this 10th day of March 2016, at


Bacolod City, Philippines and I hereby certify that I have personally examined the affiant
and that I am satisfied that she voluntarily executed and understood the same.
Filimon Sy
IBP No. 827847, 6/8/15, BC
PTR No. 576784, 6/8/15, BC
Attorneys Roll No. 12345
MCLE Compliance No. 11-055555
MCLE Compliance No. 111-005555

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