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Republic of the Philippines

Department of Interior and Local Government

NATIONAL POLICE COMMISSION XII


OFFICE OF THE SUMMARY HEARING OFFICER

Cotabato City

PHILIPPINE NATIONAL POLICE,


Complainant,

-versus- Administrative Case No. xxxx

FOR: Conduct
Unbecoming of a Police Officer

PO2 CARDO M. DALISAY,


Respondent.

xx——————————————xx

ANSWER

COMES NOW, respondent, through the undersigned counsel,


unto this Honorable Office, most respectfully submit the instant
Answer, and in support thereof, state that:

1. He recently learned that he has been made a respondent in


Administrative Case No. xxxx for Conduct Unbecoming of a
Public Officer filed by IVANA Y. MAYLAWIT on 16 March 2020
before the Office of the Summary Hearing Officer of the
National Police Commission XII in Cotabato City;

2. On 20 March 2020, he received a Summons from the said


Office requiring him to submit a Couter-Affidavit within five (5)
days from such receipt;

3. He admits the allegations found in paragraphs 1 and 2 of the


Complaint regarding his personal circumstances;

4. He specifically denies the material allegations in paragraph 3


of the Complaint, since such allegations are maliciously false.
The truth is respondent did not loan any amount from the
complainant and the Seventy thousand pesos (P70,000.00)
deposited to respondent’s bank account was in payment of
the roundtrip plane tickets procured by respondent for the
complainant, her parents and two siblings. (The receipt of the
said transaction are hereto attached as Annex “1”;

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5. He admits the allegations in paragraph 4 of the Complaint.
The complainant and respondent were in a relationship during
the said period. Respondent decided to end their relationship
after discovering that complainant is actually a trans woman
(A certified true copy of complainant’s certificate of live birth is
hereto attached as Annex “2”;

6. He specifically denies the allegations in paragraphs 5 and 6 of


the Complaint. The truth is respondent has no loan obligation
with the complainant and that her allegations are mere
fabrication meant to coerce respondent to get back in a
relationship with her;

7. He specifically denies the allegations in paragraphs 7, 8, 9 and


10, since such allegations are maliciously false. Contrary to
the allegations of the complainant, she and the respondent
would often take a video recording of their sexual activity and
the seeming voyeuristic feature of the subject video was
purely an act to gratify both of their sexual fantasy.
Respondent also has no intention of spreading the said video
since it would adversely affect his career as a police officer. (A
DVD containing a compilation of the video recording of the
sexual encounters of complainant and respondent is herewith
submitted as Annex “3”;

8. He is without knowledge or information sufficient to form a


belief as to the truth of the allegations in paragraphs 11, 12,
13 and 14 of the Complaint;

PRAYER

WHEREFORE, it is most respectfully prayed before this


Honorable Office that the instant Complaint be dismissed for lack of
merit.

Just and equitable relief, under the premises, are likewise


prayed for.

23 March 2020, Cotabato City, Philippines.

CASSEY Y. YULO
Roll No. 63810

PTR No. 0654321 04/13/2020

IBP No. 234890 11/09/2020

MCLE Compliance IV-0212456-05/28/2019

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Tel. No. (064) 421-7327

Cell Phone No. 0920-9786081

E-mail Address: cass.yulo@gmail.com

Alnor Complex, Highlands, Sinsuat Ave., Cotabato City

SUBSCRIBED and SWORN TO BEFORE ME, this 23rd day of


March 2020, respondent exhibiting to me his Residence Certificate
No. XX009945XX20 issued at Cotabato City on 11 February 2020.

MEHRAB U. BAHRI
Roll No. 43210

PTR No. 0654321 07/15/2020

IBP No. 234890 07/09/2020

MCLE Compliance IV-0002456-07/27/2019

Tel. No. (064) 421-1324

Cell Phone No. 0921-9386289

E-mail Address: rav.bahri@gmail.com

MC Squared, Einstein Suites, E. Guttierrez Ave., Cotabato City

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