Republic of the Philippines

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
______________________

PM Real Estate Corp.

As represented by
Philip Mendoza,
Complainant,

-versus- NPS DOCKET NO. ___________

For: Falsification of Private Document
Robert Mang,
Respondents.
x --------------------------------------------x

COUNTER - AFFIDAVIT

I, Robert Mang, Filipino citizen, of legal age and resident of

________________, after having been duly sworn to in accordance with law hereby
depose and state that:

1. It came known to my knowledge that a certain case was filed before the Office
of Honorable Prosecutor when a subpoena is directed to me, and so, I as a
gesture of respect to the Office, I am executing this document as a form of
compliance;

2. With all due respect, the allegation/charge narrated in the complaint-affidavit

against the undersigned is vehemently denied for being farce and/or untrue.
Further, the same deserves scant of consideration for being a malicious
concocted. The truth of the matter will be set forth in the succeeding
paragraphs;

3. I vehemently deny the charge/s proffered against me as narrated in the

complaint-affidavit of the complainants, for being false and maliciously
concocted. The truth of the matter will be set forth in the succeeding
paragraphs;

4. The complaint arose out of an alleged incident-report dated July 20, 2020 by a
certain client of the Respondent PREC who claims that I went to his home and
represented myself as an employee of the PREC. More, presenting a false
documents and/or evidences unknowing to Respondent. In fact, it is only
through receiving such complaint that said documents came to my knowledge;

5. In addition, scant reading of the complaint would show that the incident was
reported at once to PREC. In conjunction thereto, if indeed a scam and/or person
plying to represent the company, wouldn’t it be prudent for the company to act
at once and curtail further damage to the name of company and/or loss
thereto?;

6. If indeed, such circumstance happened, it seems absurd that it was only after
more or less two (2) months a Complaint is filed. To note, time is essential for
everyone, moreover to a company who protects its interest in the eyes of public;
 7. Nevertheless, as the Respondent is charged by Falsification of Private documents
by, it must be stressed that Respondent has no prior knowledge of the falsified
ID and documents being presented. In fact, a copy of a government ID issued to
bearing my true signature is hereto attached for your consideration. Copy of said
ID is attached as Annex “A”;

8. The signature being presented is far different from my signature;

9. In addition, it should bear to note that the PREC’s client, alleging that
Respondent came to his house, represented as its employee and tried to collect a
sum of money is not known and had never been seen by the Respondent;

10. On the alleged date and time being stated in the incident by certain, Joseph
Morong. Respondent, on the day of July 20, 2020 was reporting on his duty as
Security Guard at ABC Marketing with an address of ___________. A copy of
Respondent’s Daily Time Record which is captured thru a Biometrics Machine is
hereto attached as Annex “B”;

11. More, this can be attest by my workmates that I have reported on said date and
time. Thus, the malicious intent to taint my name;

12.The elements of the crime of Falsification to wit:_____________

13.I did not do any of the acts enumerated in Article 171 of the RPC. To reiterate I
know nothing out of the baseless accusation against me and the reason to strip
Respondent on such act, more by a reputable Company to which I believe it is.

14.Applying these elements in this case:

a. That the offender knew that a document was falsified by another person.

b. Secondly, that the false document is embraced in Article 171. Certainly, I

am not aware that the subject document was falsified.

c. I have no interest whatsoever in making use of the subject document,

and it will not in any way benefit me.

d. I never had the intention to cause prejudice to anyone and if ever

anyone was prejudice by the person who allegedly falsified the subject
document, certainly it was not my act which caused to prejudice to the
other person.

15.I hereby attest to the veracity and truthfulness of the foregoing statements, and
humbly but most respectfully request the proper authorities to cause the
dismissal of the complaint against me.

WHEREFORE, premises considered, undersigned respondent most respectfully

pray that the Honorable Prosecutor dismiss the complaint for utter lack of merit.

Other relief/s just and equitable under the circumstances are likewise prayed for.

Lingayen, Pangasinan for San Carlos City, Pangasinan. August 24, 2018.
 ROBERT MANG
Affiant

SUBSCRIBED and SWORN to before me this __ day of September, 2020 at

__________, ____________, affiant exhibiting to me competent proof of his identity.

Authorized Official

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