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    Mando Rugas and Honey Rugas have been charged with robbery for allegedly taking a land title from Aiko Lugi's office. In their joint counter-affidavit, they deny the charge and request the criminal complaint be dismissed for lack of merit. They state that on October 16, they were named as respondents in a case for robbery by Aiko Lugi. On October 23, they received a subpoena requiring their counter-affidavit within 10 days. They deny conspiring to commit robbery by unlawfully taking the land title from Lugi's office, as alleged in the charge.

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    COUNTER DRAFT

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    Mando Rugas and Honey Rugas have been charged with robbery for allegedly taking a land title from Aiko Lugi's office. In their joint counter-affidavit, they deny the charge and request the criminal complaint be dismissed for lack of merit. They state that on October 16, they were named as respondents in a case for robbery by Aiko Lugi. On October 23, they received a subpoena requiring their counter-affidavit within 10 days. They deny conspiring to commit robbery by unlawfully taking the land title from Lugi's office, as alleged in the charge.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    22 views2 pages

    Counter Draft

    Uploaded by

    SS
    Mando Rugas and Honey Rugas have been charged with robbery for allegedly taking a land title from Aiko Lugi's office. In their joint counter-affidavit, they deny the charge and request the criminal complaint be dismissed for lack of merit. They state that on October 16, they were named as respondents in a case for robbery by Aiko Lugi. On October 23, they received a subpoena requiring their counter-affidavit within 10 days. They deny conspiring to commit robbery by unlawfully taking the land title from Lugi's office, as alleged in the charge.

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    © All Rights Reserved
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    of 2

    REPUBLIC OF THE PHILIPPINES

    DEPARTMENT OF JUSTICE
    OFFICE OF THE CITY PROSECUTOR
    QUEZON CITY
    Case No. ____________
    For: Robbery (with
    AIKO LUGI Force Upon Things)
    Complainant, in an Uninhabited
    Place
    -versus-

    MANDO RUGAS and HONEY RUGAS,


    Respondent.
    x---------------------------------------/

    JOINT COUNTER-AFFIDAVIT
    OF THE RESPONDENTS
    MANDO RUGAS and HONEY RUGAS

    THE UNDERSIGNED RESPODENTS respectfully state:

    We, MANDO RUGAS and HONEY RUGAS, both of legal age, Filipino, married,
    and residents of 666 P. Kamalasan St., Carmona, Makati City City, after being
    sworn to in accordance with law, do hereby depose and state that:

    1. We have been made respondents in Case No. _________, a charge


    for Robbery with Force Upon Things in an Uninhabited Place by the
    herein complainant on October 16, 2019 before the Office of the City
    Prosecutor of Quezon City;

    2. On October 23, 2019, we received a Subpoena from said Office


    requiring us to submit a Counter-Affidavit within ten (10) days from
    such receipt;

    3. The charge is based on the allegation that we conspired to commit


    Robbery with Force Upon Things under Article 302 of the Revised
    Penal Code by unlawfully taking the Transfer Certificate Title (TCT)
    No. T-99999 from the office of one Aiko Lugi, at Teacher’s Village,
    Quezon City;

    PRAYER
    WHEREFORE, premises considered, it is respectfully prayed that the
    instant criminal complaint be DISMISSED for lack of merit.
    Further, the respondents respectfully pray such and other reliefs as may be
    deemed just and equitable in the premises.

    Page 1 of 2
    TO THE TRUTH OF THE FOREGOING, we have signed this Counter-
    Affidavit on October 28, 2019.

    Affints:

    MANDO RUGAS HONEY RUGAS

    SUBSCRIBED and SWORN TO BEFORE ME, this 28th day of October 2019 at
    Quezon City.

    ATTY. PAPA POGI


    Counsel for Defendant
    Suite 26, 10th Floor, Maclane Center,
    Quezon Avenue, Quezon City;
    Until December 31, 2019
    Roll of Attorney No. 1026
    PTR No. 1234-00, January 3, 2014, Quezon City
    IBP No. 1906-01, January 3, 2014, Quezon City
    MCLE Compliance No. I-000894 – 12/21/18

    Page 2 of 2

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