Republic of the Philippines )

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COUNTER-AFFIDAVIT
I, , after having been sworn to in accordance with law, do hereby depose and
declare that:

1. I am the Respondent in for Acts of Lasciviousness in relation to R.A. 7610,

now pending before the City Prosecutor of Tagum City;

2. I deny all the imputations of wrongdoing against me in the complaint for

being groundless and unmeritorious. I never had any sexual nor lewd
intentions against the complainants. Thus, I hereby pray for the dismissal
of the present complaint maliciously filed against me;

3. As can be perused from the Affidavit Complaint, the first alleged time where
I allegedly molest sometime on 29 March 2018 of 8:00 in the evening, where
I allegedly grabbed and dragged her to a dark and obscure portion of the
church and made lewd acts against her are all untrue. During that time, I
was not in the church as I was already at home since it is a Holy Thursday
that time. I always go home early as I have also responsibilities in our
house;

4. As indicated in the complaint, I again repeat the lewd acts that I allegedly
committed against on 30 March 2018 at 7:30 in the evening. These are all
fallacious and wrong because I always go home early. My usual working time
in the church is 7am then I go home at 11am. Then my time to go back to
church in the afternoon will vary every time I had work to finish at home.
Then I go home in the afternoon at 5:00pm;

5. Further, one of the complainant who is who said that I allegedly embrace
her tight and carried her, her legs place on the sides of my waist and perform
a push and pull motion of “KIYOD-KIYOD” are all false. I did not do any such
acts. In fact, I was in my home on the said date and time as I was fixing an
electric fan and repairing shoes in our small shop as I was requested by my
brother to attend such work;

6. Furthermore, one of the complainant also imputed me on the same acts of

lewdness on 02 April 2018, when I allegedly called to come in the church
and I allegedly carried her frontally embraced her tight and sweetly told her
“UNSA MAN NI AKONG PALANGGA UI”. Then I positioned my private part
closed to the complainant private part and performed a push and pull motion
in a fast movement are all untruthful. I never do any of such acts as these
are all maliciously imputed to me. In fact, during that day I was in the church
and there was a program happening at that time wherein there are too many
people participated in that day. I also repair the wall of the church that day
and went home at 7pm;

7. The two complainants who are, 4 years old and, 3 years old wherein
according to their statements I allegedly touched their private parts are all
spurious and untrue. These imputations against me are all sham and lies
since I know the reason why I was charged this kind of crime;

8. The truth is all of the complainants are all siblings and the one who assisted
them, their mother, is mad at me because I reprimanded her at the time I
discovered that their family is connecting electricity in the church to where
 I was working. I also reprimanded them not to get water in the church since
they also get water without any permission. I also told my brother who is
also a member of the Church to where I work of what I discovered and there
my brother caution her about it;

9. Since I was the one who reprimanded them on their anomalous acts and
intention to connect electricity and get water in the church, she was mad at
me and used her children to get even with me;

10.I strongly believe that this case filed against me is purposely to hurt me and
my family. I never and will never had have any lustful intent to molest a
child. Though I am not educated person, I know what is right and wrong
and all the statement of the complainant against me are all tainted with
malicious intent to cause pain in me and my family. In fact, one of our
neighbor told me, that her child was recruited by the mother of the
complainant purposely to file a case against me but our neighbor decline
because she knew the truth and that all statements against me are false;

11.Hence, there can be no probable cause to believe that I committed crime

filed against me;

12.I am executing this counter-affidavit to refute all the imputations of

wrongdoings against me, to inform the concerned authorities and this
Honorable Court of the foregoing facts and to attest to the truth thereof.

IN WITNESS WHEREOF, I have hereunto set my hand this

SUSCRIBED AND SWORN to before me this this Philippines. I hereby certify

that I have examined the affiant personally and that I am satisfied that he voluntarily
executed this affidavit and understood the same.

Copy furnished: