AFFIDAVIT

I, Mara Ancheta Bisaya, of legal age, Filipino, married, with address at Paco Mangkayan,
Benguet, under oath declare that:

The lawyer conducting the examination is Atty. Maria Generosa T. Mislang. The
examination was held at _______. I answered the questions fully conscious that I did so under
oath, and that I may face criminal liability for false testimony or perjury.

OFFER OF TESTIMONY: The testimony of the witness is being offered to establish the legal
and factual basis for the Petition, all annexes appended thereto as well as other related matters,
facts and circumstances relevant to this case.

1) Q: Ms. Witness, can you please tell this Honorable Court why you are here today?
A: I am here to testify before this Court in regard to the case ___________.

2) Q: Who filed the Petition xxx?

A: _____________________.

3) Q: Do you know the respondent Lepanto Mines in this case?

A: Yes.

4) Q: What are the acts by Lepanto Mines complained of?

A: Continuous bulldozing in the area by Lepanto Mines for road and dam
construction which has resulted to the submerging and destruction of trees, rice
fields, and vegetable gardens. The construction of the tailings dam by Lepanto
Mines has been causing pollution resulting to uninhabitable rivers and other
sources of water, affecting agricultural lots, livelihood, and animals in the area.

5) Q: Where do you live?

A: I live in Paco Mangkayan, Benguet.

6) Q: What is your livelihood?

A: Farming.

7) Q: Do you have properties affected by Lepanto Mines?

A: Yes.

8) Q: What are these properties if any?

A: Agricultural lands and improvements thereof such as trees and crops within the
bounds of Dam 1, 3, and 5 constructed by Lepanto Mines. A river is located
amidst both of my properties which are adjacent to each other.

9) Q: What is your proof of ownership of these properties?

A: Tax declaration and photo representations.

10) Q: Where are these properties located?

A: The properties are located in Mangkayan, particularly in Paco and Cabiten.

11) Q: How were the properties affected by Lepanto Mines?

A: The bulldozing and construction of roads and dams affected the trees and crops
planted on my properties submerging them in contaminated water.

12) Q: What was the effect on the agricultural nature of your lands, if any?
A: In the years 1960 to 1970, Lepanto Mines suspended its operations and did not
conduct any form of maintenance leading to the land being unsuitable for
agriculture. There has been fewer crop production due to the water contamination,
 affecting our livelihood. Silt and other sediments were deposited on our rice
fields.

13) Q: What other changes resulted to the properties?

A: The water level continues to rise due to stoplog placement making our customary
route unpassable. Similar routes going to other sources of water are likewise
difficult to pass through or are unpassable altogether.

14) Q: What are other effects resulting from the acts complained of, if any?
A: A relative of mine acquired the Stevens-Johnson syndrome, a skin disorder that
might have been a result of contaminants in the nearby river.

15) Q: Do you have any proof on the Lepanto Mining operations and effects of the same
on the properties?
A: Yes.

16) Q: What action did you take, if any, when your properties were affected by Lepanto
Mines?
A: We approached Lepanto through its liaisons regarding the destruction of our
garden and rice fields.

17) Q: What was the result of this action you took, if any?
A: They initially offered to purchase our land and agreed to compensate us for the
destruction of my crops and other improvements.

18) Q: How did the said offer take place?

A: The property was not purchased, and the agreement to compensate was for a
certain amount that to this day, only two thousand pesos (Php 2,000.00) has been
given to us as payment.

19) Q: What other actions did you take, if any?

A: In the year 2012, my sibling J-LL Ancheta, proceeded to the Mines and
Geosciences Bureau or MGB where one Atty. Marciano Insu was involved, to
complain about the destruction of our properties and the environmental damages
caused by the acts of Lepanto Mines.

20) Q: What is the result, if any, of the said action?

A: The complaint is still pending with the bureau. They expressed that stoplogs were
lessened. Also, a proposal was sought to be made but did not continue.

21) Q: What other actions did you take, if any?

A: We finally went to our respective barangay and municipal officials to seek for
assistance.

22) Q: What was the result of this action, if any?

A: It led to the filing of this case with the cooperation of the City Environment &
Natural Resources Office (CENRO) in 2017, and Tanggol Kalikasan.

23) Q: Do you have any proof on the said actions taken?

A: Yes.

24) Q: What are the effects, if any, of Lepanto Mining operations on the
rivers/creeks/inland waters in your area?
A: When the pipelines and tailings dam were being constructed, water levels began
to increase. The color of the creeks and rivers changed alternating from orange to
 gray. The water systems are no longer potable and are toxic due to contamination,
rendering them uninhabitable for aquatic animals and plants.

25) Q: What is the name of the river/creek/inland water?

A: Supid Creek.

26) Q: What actions, if any, did you take on the said situation on the creek?
A: We tried using detoxifiers and lime to help restore its condition, but to no avail.

27) Q: Do you have any proof on the effect of Lepanto Mining operations on the
river/creeks/inland waters?
A: Yes.

28) Q: What do you want this court to do regarding your petition?

A: I respectfully pray from the Court to grant this petition; that proper measures be
taken to stabilize the tailings dam; and that areas damaged by Lepanto Mines be
rehabilitated.

29) Q: Do you confirm the truthfulness of your statements as contained in this judicial
affidavit?
A: Yes.

30) Q: Are you aware that you have sworn to the truth if these statements under oath and
that you may face criminal liability for false testimony or perjury if your
statement are shown to be untruthful?
A: Yes.

NOTHING FURTHER.

______________
Affiant

SUBSCRIBED AND SWORN TO before me this __th day of ____ 2019 in ____,
Baguio City, with affiant exhibiting to me her ID No. ________ issued at _______ on ______,
bearing her photograph and signature, known to me as the same person who personally signed
the foregoing instrument before me and avowed under penalty of law to the whole truth of the
contents of the said instrument.

NOTARY PUBLIC

Page No. ____;

Book No. ____;
Series of 2019.

SWORN ATTESTATION OF COUNSEL

I hereby attest that I have assisted the affiant in the conduct of her testimony; that
I faithfully recorded the questions I have asked the corresponding answers that the witness had
given; and that further, I nor any other person had coached the witness regarding his answers.
_________________________, _____th day of April 2019.

MARIA GENROSA T. MISLANG

 SUBSCRIBED AND SWORN TO before me this ___th day of _____ 2019 in
______, Baguio City, with affiant exhibiting to me her ID No. ________, issued on _________
at ______, bearing her photograph and signature, known to me as the same person who
personally signed the foregoing instrument before me and avowed under penalty of law to the
whole truth of the contents of the said instrument.

NOTARY PUBLIC

Page No. ____;

Book No. ____;
Series of 2019.