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Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecution Office
OFFICE OF THE CITY PROSECUTOR
Baguio City

ROMEO T. PADILLA,
Complainant, NPS DOCKET NO.16-3065

-versus- for:

QADEER ZAHOOR AHMAD THEFT/ROBBERY


AND YAMMY D. AHMAD,
Respondents.
x------------------------x

COUNTER-AFFIDAVIT

WE, QADEER ZAHOOR AHMAD and YAMMY D. AHMAD, of


legal ages, Pakistan, married to each other, and
residents of No. 56 Purok 1, Brgy. Dontogan, Baguio
City, state that:

1. We are the respondents in the above-


entitled case. In compliance with the subpoena
issued by the Honorable Office of the City
Prosecutor, we hereby submit this counter-affidavit
and other documents supporting documents in our
defense;

2. We vehemently deny certain allegations


contained in the affidavit-complaint filed by the
complainant ROMEO T. PADILLA for being
untruthful, baseless, and malicious. The truth of
the matter is that:

a. At the outset, Qadeer Zahoor Ahmad and


Yammy D. Ahmad had no participation at all of
the alleged carting away of the materials of
AHMAD BROTHERS CAF structure;

b. Upon the assurance of the complainant


Romeo T. Padilla that he had the necessary
permit to operate, respondents Qadeer Zahoor
Ahmad and Yammy D. Ahmad constructed what was
known as AHMAD BROTHERS CAFE;

c. So when a JUDGMENT in the Eviction Case


with No. 13921 was rendered in favour of the
complainant, they saw it fit to remove
improvements on the leased premises.

3. We are executing this joint counter-


affidavit to attest to the truthfulness of the
foregoing narration and to answer the accusations
of the complainant against us, and to support our
prayer for the dismissal of the case. This
affidavit is likewise executed for all other legal
intents and purposes it may serve.

IN WITNESS WHEREFORE, I hereby set my hand this


___ day of December 2016 at Baguio City.

Qadeer Zahoor Ahmad Yammy D. Ahmad


Affiant Affiant

SUBSCRIBED AND SWORN TO BEFORE ME this ____ day


of December 2016 in the City of Baguio. This is to
certify that I have examined the Affiants and that
he fully understood the contents of his affidavit
and I am satisfied that they executed the same
freely and voluntarily.

_________________________________
Administering officer

Copy furnished:

ROMEO T. PADILLA, R.R. no. _____;


Bactad Proper, Urdaneta City, ___
December 2016
Pangasinan Baguio
City

c/o Atty. ERIC G. SANTOS


Suite 14 2nd Floor BBCCC Building
Assumption Road., Baguio City