Republic of the Philippines

COURT OF APPEALS
Visayas
Dr Pablo U. Abella St, Cebu City, 6000 Cebu

JUDICIAL AFFIDAVIT
OF CONCHITA BAHUGBAHUG

I, CONCHITA BAHUGBAHUG, Filipino, of legal age, widowed, and a

resident of Banogon Street, Barangay Apas, Cebu City, Cebu, Philippines, 6000
state under oath as follows:

PRELIMINARY STATEMENT

The person examining me is ATTY. LOU DELIANNE I. REBOJA with office

address at ABRR Law Firm, Room 414, Don Roman Aboitiz Street, Casa Rosario
Building, Cebu City. The examination was held at their office.

I am answering her questions fully conscious that I do so under oath and that I
may face criminal liability for false testimony and perjury.

I have prepared this Judicial Affidavit in English, a language of which I am

conversant, and pursuant to Supreme Court Administrative Matter No. 12-8-8-SC,
dated 04 September 2012, in place of, and to constitute, my direct testimony in this
case.

PURPOSE OF TESTIMONY

The testimony of the witness is offered for the following purposes:

 Witness would testify that she saw the black van, which allegedly took
Pedro, parked at the grounds of the military central command in Camp
Lapu-lapu, Lahug, Cebu City;
 Witness would testify regarding the surrounding circumstances as to how
and why she saw the black van in Camp Lapu-Lapu, Lahug, Cebu City;
  Witness would also establish the surrounding circumstances that the parked
black van in Camp Lapu-Lapu, Lahug, Cebu City, is the same black van
that took Pedro last November 6, 2019; and
 Witness would testify on other matters pertinent and related to the
foregoing purposes.

QUESTIONS AND ANSWERS

1. Q. Please state for the record your name and other personal
circumstances.
A. I am Conchita Bahugbahug, of legal age, a Filipino citizen,
widowed, and a resident of 123 Banogon Street, Barangay Apas,
Cebu City.

2. Q. Are you the same woman, who appears as witness in the Petition
for the Issuance of a Writ of Amparo and a Writ of Habeas Data
filed by Mrs. Juana Santos?
A. Yes. I am.

3. Q. Why are you here today?

A. I am here to have my testimony taken.

4. Q. How do you know the petitioner, Mrs. Juana Santos?

A. I just recently met her. I know her as the mother of the missing
Engineering Student, Pedro Santos.

5. Q. So, you two are not related?

A. No, ma’am.

6. Q. You said, you just recently met Mrs. Santos, can you tell me how
you two met and the surrounding circumstances of this meeting?
A. Yes. I first met her in person last November 15, 2019 in Camp
Lapu-Lapu when she went there to look and inquire about her
missing son, but prior to this meeting I already contacted her
through Messenger, on the night of November 14, 2019.

7. Q. What did you say when you contacted her through Messenger?
A. I told her that I saw the same black van which allegedly took her
 son, parked at the grounds of the military central command in
Camp Lapu-lapu, Lahug, Cebu City last November 14, 2019.

8. Q. What were you doing in Camp Lapu-Lapu?

A. I work there, as a cook.

9. Q. You said that you saw the same black van which allegedly took the
son of Mrs. Santos, how did you know that it was the same van?
A. It was because I saw the post of Mrs. Santos which contained the
photos of her missing son and the black van with its plate number. I
even shared her post because as a mother who also tried losing a
child, I understood her misery and pain.

10. Q. I am showing to you this printed copy of the screenshot of a post by

Mrs. Santos on November 7, 2019 which contains a photo of a
young man about the age of 20, and a photo of a black van with
plate number AEA 7998. Are you referring to this post?
A. Yes, Atty. It is that post I am referring to.

11. Q. Let this document be marked as Exhibit _.

A.

12. Q. What did you do when you saw the parked black van in Camp
Lapu-Lapu?
A. I looked for the post again and rechecked if the black van in the
post and the parked black van in Camp Lapu-Lapu had the same
plate number.

13. Q. And did they have the same plate number?

A. Yes. They had the same plate number, AEA 7998.

14. Q. When you had already verified that they have the same plate
number, what did you do?
A. I immediately contacted Mrs. Santos. I sent her a message through
Messenger and told her that I saw the black van in her post, parked
at the grounds of the military central command in Camp Lapu-lapu,
Lahug, Cebu City.

15. Q. When did see the black van parked at the grounds of the military
 central command in Camp Lapu-lapu, Lahug, Cebu City, again?
A. Last, November 14, 2019, ma’am.

16. Q. And when did you first meet Mrs. Santos personally?
A. I first met her personally last November 15, 2019, the day after I
contacted her through Messenger. She went to Camp Lapu-Lapu to
inquire about her missing son.

17. Q. Did you accompany her to the officer on duty when she inquired
about her missing son?
A. I just pointed where the office was because I am afraid that I might
lose my job.

18. Q. Why are you afraid that you might lose your job?
A. Because the officers might get mad at me for messaging Mrs.
Santos.

19. Q. Do you happen to receive any threats in relation to this case?

A. Yes. I received a text message from an unregistered number saying
that I should not get involved with this case and that my life and my
family’s safety would be compromised.

20. Q. Is there anything else you want to say?

A. None.

21. Q. Finally, will you affirm and confirm the truthfulness of your
answers herein?
A. Yes, I do.

IN WITNESS WHEREOF, I have hereunto affixed my signature this __ day of

July 2019 at ____________________.

CONCHITA BAHUGBAHUG
Affiant Witness
Republic of the Philippines }
City of Cebu }S.S.

SUBSCRIBED AND SWORN to before me, a Notary Public for and in the
City of Cebu this ________________. Affiant who is personally known to me
personally appeared and exhibited to me his/her ___________________________,
bearing his/her photograph and signature, as competent proof of his/her identity.

Witness my hand and notarial seal.

Doc. No. ____;

Page No. ____;
Book No. ____;
Series of 2019.

SWORN ATTESTATION

I, ATTY. LOU DELIANNE I. REBOJA, Filipino, of legal age and with

office address at Room 414, Don Roman Aboitiz Street, Casa Rosario Building,
Cebu City, under oath, hereby attest that I personally examined the witness at the
foregoing address, that the questions made and corresponding answers given by the
witness were faithfully recorded or caused to be recorded and that said witness was
not in any way coached by anybody in giving his/her answers.

ATTY. LOU DELIANNE I. REBOJA

Examining Lawyer