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DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
Office of the City Prosecutor – Paranaque City
RICHELLE SIASON,
Complainant,
NPS Docket No. ____________
-versus- For: Violation of Article ___ of the Revised
Penal Code (Perjury)
EDWIN SIASON and JOSEPHINE
OLLERES-CAMPOS,
Respondents.
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COMPLAINT AFFIDAVIT
1. I am filing a formal complaint for violation of Article 183 of the Revised Penal
Code or otherwise known as “False Testimony in Other Cases and Perjury in Solemn
Affirmation” against Respondents EDWIN SIASON and JOSEPHINE OLLERES-
CAMPOS;
5. Unfortunately, as the time of the filing of the aforesaid complaint, I had yet to
secure a copy of the Philippine Statistics Authority Certificate of Live Birth of the said minor,
hence, I was not able to include the same as part of the annexes to the complaint that I filed
against the Respondents;
6. However, I was only able to secure a copy the Certificate of Live Birth of
PRECIOUS ELISHA SIASON at around 12 pm of November 26, 2019. Attached hereto
and made an integral part hereof is a copy of the Certificate of Live Birth of minor PRECIOUS
ELISHA SIASON as ANNEX “B” and the corresponding Affidavit of
Paternity/Acknowledgement as ANNEX “B-1”;
7. On November 26, 2019, Respondents EDWIN SIASON and JOSEPHINE
OLLERES-CAMPOS filed their respective Counter Affidavits to answer the allegations
against them. Their Counter Affidavits was subscribed and sworn to before Assistant City
Prosecutor ALAN MICHAEL MONDRAGON of the Paranaque City Prosecutor’s Office.
Attached hereto and made an integral part hereof is copy of Respondent EDWIN SIASON’s
Counter Affidavit as ANNEX “C” and the signature of Assistant City Prosecutor Alan
Michael Mondragon as the Administering Officer as ANNEX “C-1” and a copy of
Respondent JOSEPHINE OLLERES-CAMPOS’ Counter Affidavit as ANNEX “D” and the
signature of Assistance City Prosecutor Alan Michael Mondragon as the Administering Officer
as Annex “D-1”;
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“19. That with respect to the charge of concubinage, I had a brief relationship with Josephine Olleres-
Campos sometime in 2017 but it was as mentioned earlier, a very brief acquaintance and when
Josephine Olleres-Campos came to learn that I am a married man, she avoided me thereby terminating
whatever communication we had to each other;
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10. On the other hand, on page 2, paragraph 9 of the Counter Affidavit submitted
by Respondent JOSEPHINE OLLERES-CAMPOS, she issued a blanket denial of the
accusation I had made that she and Respondent EDWIN SIASON both had a child named
PRECIOUS ELISHA SIASON, who was born last September 14, 2018, to wit:
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“9. Thirdly, Complainant further hinges her accusation against me for the crime of concubinage by
mentioning the birth of a child. But Complainant’s self-serving statement on this matter was only
based on an information coming from a third person (see par. 14 of Complaint Affidavit). No other
documentary evidence such as birth certificate of the child was attached to prove Complainant’s claim
on this regard. Hence, the same cannot be given weight or any probative value in finding prima facie
case for concubinage;
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“10. Finally, I am working as an OFW, for which reason I have been out of the country on a regular
basis. Thus, the impossibility of cohabitation. By way of example, I have attached hereto copies of my
departures and arrivals in year 2017 as Annex “A” and “B” respectively;
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12. It is very clear that Respondent EDWIN SIASON committed the act of perjury
as can be gleamed on page 3, paragraph 9 of his Complaint Affidavit. His attestation that he
had terminated a “brief” relationship with Respondent JOSEPHINE OLLERES-CAMPOS
is belied by the fact that a child was born out of their affair last September 2018;
13. Given the preceding circumstance, it is a foregone conclusion that their affair
lasted for more than two (2) years, which, for all intents and purposes is not brief nor had
concluded back in 2017;
15. As may be gathered from the foregoing, it is very clear that Respondents
EDWIN SIASON and JOSEPHINE OLLERES-CAMPOS, committed acts contrary to law,
more specifically Article 183 of the Revised Penal Code, which is quoted hereunder:
Art. 183. False testimony in other cases and perjury in solemn affirmation. — The penalty of arresto
mayor in its maximum period to prision correccional in its minimum period shall be imposed upon any
person, who knowingly makes untruthful statements and not being included in the provisions of the
next preceding articles, shall testify under oath, or make an affidavit, upon any material matter before
a competent person authorized to administer an oath in cases in which the law so requires.
(a) That the accused made a statement under oath or executed an affidavit upon a material matter.
(b) That the statement or affidavit was made before a competent officer, authorized to receive and
administer oath.
(c) That in the statement or affidavit, the accused made a willful and deliberate assertion of a falsehood.
(d) That the sworn statement or affidavit containing the falsity is required by law or made for a legal
purpose.” – Union Bank of the Philippines versus People of the Philippines, G.R. No. 192565,
dated February 28, 2012
19. Respondent EDWIN SIASON can be served with summons and other
processes of this Honorable Office at his last known address at 356 Rajah Tupas Steet, Danng
Hari, Navotas City while Respondent JOSEPHINE OLLERES-CAMPOS may be served
with summons and other processes of this Honorable Office at 213 E. Tuazon St. San Jose,
Navotas City.
RICHELLE SIASON
Affiant
CERTIFICATION
I hereby certify that I have personally examined the affiant and I certify further that he
voluntarily executed the foregoing complaint affidavit and all the statements and allegations
made therein were understood by her.