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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
ZAMBOANGA CITY

LORNA B. ALVAREZ
Complainant
vs. I.S. No. 12345ABC
For: Rape
PABLO LOPAB
Respondent.

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COUNTER-AFFIDAVIT
I, PABLO LOPAB, Filipino, of legal age, and a resident of Antartica Drive, Tulungatung,
Zamboanga City, after having been duly sworn in accordance with law, hereby depose and state
that:
1. I am the accused in Criminal Case No. 123456 for the crime of RAPE under Article
266-A of the Revised Penal Code;
2. I am currently employed in the logistics of the barrio, like a kargador;
3. I do not admit the allegations of the affidavit-complaint of Ms. Alvarez.
4. 4. I deny the allegations for lack of knowledge as to the truth of the said allegations,
the truth being that:
a) That on November 1, 2017, at around 10:00 pm in the evening, the complaint and
I walked away from the party as it was the time to go home. I asked to accompany
her because the road to her house if quite dark and dangerous.
b) While we were walking, we had small chit-chats and as soon as I knew it, she
locked her eyes unto mine. Perplexed, my body froze and I had to stop a few solid
seconds to fathom what’s going on.
c) The complainant kissed me and we made love on the grassy, solid, and quite
romantic ground.
d) After the incident, the complainant quickly dressed up and ran towards to her
house and left me a kiss on the cheeks. It was the last time I saw the complainant.
5. The allegations of the complainant are all false that I coerced and forced her to have
carnal knowledge with me. I confess that we are sweethearts and the incident was
mutual and born out of love.
6. I am executing this Counter-Affidavit for the purpose of attesting to the truth of the
foregoing statements, 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

AFFIANT FURTHER SAYETH NAUGHT.


IN WITNESS WHEREOF, I have hereunto set my hand this 7th day of March 2018, in
Zamboanga City.

Pablo Lopab
Affiant

SUBSCRIBED AND SWORN TO before me, this 7th day of March 2018, in Zamboanga City.

BENEDICT B. ALVAREZ
Prosecutor
This is to certify that I have personally examined the herein affiant and that I am satisfied that
she voluntarily executed and understood her statements herein.

BENEDICT B. ALVAREZ
Prosecutor

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