Republic of the Philippines

OFFICE OF THE CITY PROCECUTOR

Muntinlupa City

MORA S. AUNOR,
Plaintiff,
CRIMINAL CASE NO. 171718
- versus - For:Homicide (Article 249 of the
Revised Penal Code)
HAGGARDO I. VERZOSA,
Defendant.
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COUNTER-AFFIDAVIT

I, HAGGARDO I. VERZOSA, after having been sworn in accordance with law, and
by way of counter-affidavit to the complaint-affidavit filed by MORA S. AUNOR, to this
Honorable Office, most respectfully depose and state that:

1. The instant case arose from the complaint-affidavit for murder I executed
against MORA AUNOR (complainant herein) on _____July 2000 docketed as C.C No.
171718. Complainant Mora charges me of Murder, to wit:

“Par. 4. On May 1, 2000, at around 2:00 p.m.,

Haggardo, on board a Ford Fiesta (with Plate Number ZZZ
1122), dropped by our house at B20 L10 Ph. 2 Casimiro
Townhomes, Pulanglupa I, Las Piñas City to pick up my son
Alex. They jointly asked for my permission a few days ahead that
they would go to Baguio City for an overnight get-together with
their high school friends and I granted the same.”

“Par. 6. As a result of the tremendous impact, Alex

suffered serious bodily injuries which caused his immediate
death while Haggardo suffered mild cerebral concussion and

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 multiple fractures necessitating a thirty-day hospital
confinement. Both were taken to Baguio General Hospital but
Alex was pronounced dead on his arrival. Dr. Tirso Magaling
attested that he died of massive cerebral and intra-abdominal
hemorrhage."

“Par. 10. Given the extraordinary circumstances of

Alex’s death, wilfully caused by defendant Haggardo I. Verzosa,
I intend to claim in the same criminal case any and all possible
civil liabilities arising from his criminal act, including, but not
limited to, actual, moral, and exemplary damages, the exact
amounts of which I will prove during trial. I also intend to claim
attorney’s fees.”

I vehemently and categorically deny said allegations.

2. The alleged falsehood I made in the complaint-affidavit follows—

“Forthwith, on 01 May 2000, at around 11:00 in the evening,

Alex and I went for an overnight get-together party with our high
school friends, during the party, Sarah Go and Alex announced
they were a couple and they wanted to get married soon and have
a family when I (Alex) suddenly, walked out and obviously, I felt
differently, and as his best friend, Alex tried to talked and
followed me and I told him, I wanted to go home alone, but he
insisted. While on the car, we were having an argument, and he
wanted me stop the car, because he wanted to go back and
suddenly, he grabbed the steering wheel and I have not noticed
we were on the cliff already.”

3. Complainant claims that I should be charged of Murder, as defined and

punished under Article 248 of the Revised Penal Code, for the death of his son because I was
the driver of the car.

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 4. The allegations in the complaint-affidavit MORA AUNOR showed that
Murder was committed. But the allegations are not true. A copy of my testimony is
attached as “Annex A” hereof.

5. I am executing this Counter-Affidavit to attest to the truth of the foregoing and

in support of my prayer for the appeal of the complaint. And due to the circumstances which
I can prove on trial.

IN WITNESS WHEREOF, I have hereunto affixed my signature this __day of JULY

2000 in Las Piñas City.

HAGGARDO I. VERZOSA
Affiant

SUBSCRIBED AND SWORN TO before me this ____ day of July 2000 in Las Piñas
City. I further certify that I have personally examined the affiant and that I am satisfied that
he has executed this Counter-Affidavit and has understood the contents hereof of his own
personal knowledge.

BEBANGIDA K. VOLOSA
Administering Prosecutor