Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Talisay City, Cebu
Branch 1

PEOPLE OF THE PHILIPPINES

Plaintiff,

-versus- CRIM. CASE NO. 17208

For: LIGHT ORAL DEFAMATION

LETICIA CALLORA, ET. AL

Accused
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COUNTER-AFFIDAVIT

I, JASMIN BRIONES, Filipino, of legal age, and a resident of Brgy.

Jaclupan, Talisay City, Cebu, after having been sworn in accordance with
the law, hereby depose and state:

1) That I am one of the respondents who was WRONGFULLY,

MALICIOUSLY and CAPRICIOUSLY charge in the above
captioned case filed by complainant;

2) That I vehemently deny, belie and refute the false accusations

levelled against me in the affidavit-complaint executed by SUSAN
EBALLES, as the same is designed to pursue me in the false hope
that, for fear of litigation, I would succumb to HER iniquitous,
undeserved and dissolute demand;

3) That the allegations contained in the complaint affidavit of Susan

Eballes are all lies and are not substantiated by any documentary or
object evidence;

4) That there is no truth to the allegations on the complaint affidavit

as well as the allegations of the affidavit of witness;

5) The truth of the matter are the following:

a) She was replaced as our president in purok and she couldn’t

accept that fact that is why she was very angry;

b) She was so upset because our purok members petition to

replace her as our purok president because of her poor
leadership during the pandemic particularly in her failure to
rightly inform the members of purok pertaining to the
assistance from the government;

1
 c) I have witnessed her poor leadership and she could not accept
the fact that she was replaced that is why she filed this case
against us out of her desperation;

d) That the allegations of the witness are not true and it is just a
reiteration of the allegations of the complainant. The witness is
the live-in partner of the son of the complainant and they live
under the same roof;

6) That there is no truth of the matter that I uttered her “You are in
charge on listing the recipients of the assistance yet some of them
were not able to receive the same”. During that time March 15,
2020, it is not true that we the accused in this case were shouting,
the truth of the fact is that she was very upset that I told her that the
quarantine pass should be given house to house;

7) That at the very onset, this case is dismissible outright as the

allegations contained in the Affidavit-Complaint would not make
out a case, much less a criminal case for LIGHT ORAL
DEFAMATION;

8) In sum, the instant complaint was clearly filed for purposes of

exasperating me or for any other malicious reason;

9) That based on the foregoing glaring factual truths, the undersigned

respondent only begs that this case be treated for what it really is, a
criminal suit without basis in fact and in law;

10) I further reserved the further presentation of other evidence,

documentary or otherwise;

11) This affidavit is executed to attest the truth of the foregoing facts
and to support my plea for the outright dismissal of the instant case.

IN WITNESS WHEREOF, I have hereunto set my hand this __ day

of _____________________ 2020 at _____________, Philippines.

_________________________________
JASMIN BRIONES
AFFIANT

SUBSCRIBED AND SWORN to before me this __ day of ________2020

at____________________.

Doc. No. ___ Book No. ___

Page No. __ Series of 2020