REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE PRESCUTOR
MAKATI CITY

SHARON DACERA
Complainant,

-versus- I.S No. XV-09-INV-18B-01870

FOR: Murder under Article 248,
par. 1 of the Revised Penal Code

R O M M E L D. G A L I D O
and
J O H N P A U L R. H A L I L I
Respondents,
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JOINT COUNTER-AFFIDAVIT OF
ROMMEL GALIDO AND JOHN PAUL HALILI

We, ROMMEL D. GALIDO and JOHN PAUL R. HALILI,

both of legal ages, Filipinos, with the address of 8139 Dr. A. Santos
Avenue, San Dionisio 1700, Parañaque City, of 102 Liezel Park Plaza,
EDSA, Pasay City respectively, after having been sworn in accordance
with law, depose and state that:
1. We are the respondents in the above-captioned case filed against us by
the mother of the deceased Christine Dacera, herein complainant Sharon
Dacera, before this Honorable Office for Murder under Article 248, par. (1)
of the Revised Penal Code (“RPC”).

2. As a preliminary matter, we would like to point the error in the

Complaint-Affidavit of the complainant. That the correct address of
residence of one of the respondents, John Paul Halili is “of 102 Liezel Park
Plaza, EDSA, Pasay City” as stated in the Police Blotter Report
submitted by the complainant and not the incorrect address which
was reflected in the Complaint Affidavit dated 1 February 2021.

3. We would also like to point out the inconsistencies and errors

of the Complaint-Affidavit and the submitted annexes by the
complainant as to the named accused in this case. In the Affidavit-
Complaint, only us, herein respondents are charged with the crime of
murder. However, Annex C named John Paul Dela Serna, Gigo De
Guzman, Rommel Galido, Valentinie Rosales, and excluding John
Paul Halili as persons charged with murder. Annex G and Annex H
named Rommel Galido and Valentine Rosales, and excluding John
Paul Halili as persons charged with murder. Annex I named John
Paul Dela Serna, Rommel Galido, Gigo De Guzman, Valentine
Rosales, and excluding John Paul Halili.
3. Annex E submitted by the complainant lacks the signature of
Atty. Saul Goodman, the one who examined Abigaile Coronado, the
hotel manager. The failure to comply with this requirement makes
the said judicial affidavit inadmissible, as provided for in the in Sec.
10, par. c of the Judicial Affidavit Rule.

4. As to the Annex D, the two minutes and twenty-nine seconds

(2:29) cctv footage submitted by the complainant is clearly not the full
footage, contrary to the sworn statement of Abegaile Coronado in
Annex E that the said footage is unaltered.

5. We would also like to point out that the police blotter

submitted by the complainant contains no signature of the said
officer-in-charge, Police Inspector Christine Flores. Hence,
inadmissible as evidence.

6. In view thereof, we vehemently deny accusations hurled

against us by complainant. It cannot be overemphasized that there is
no truth to the allegation that we committed the crim of murder.
Hence, there is no reason to justify the filling of the instant complaint
against us.
 SPECIFIC DENIALS AND
COUNTER STATEMENT OF FACTS

7. At the onset, the allegations that we committed the crime of

murder by injecting heroine to the body of Christine Dacera is clearly
denied. As will be discussed below, evidence submitted by the
complainant is insufficient to charge Rommel D. Galido and John
Paul R. Halili with the murder.

8. We specifically deny the use of in City Garden Hotel in

Poblacion, Makati City to welcome the New Year, nor the existence of
such in the said party. The complainant failed to adduce evidence to
prove the existence of such drugs in the hotel. This was affirmed by
the sworn statement of Raymer Englis, one of the persons who
attended the said party with Chrisitine Dacera and the herein
respondents, attached here as Annex “A”, to wit:

“There are insinuations that there were party drugs during the

evening of December 31, 2020 but I vehemently deny these

allegations. While I admit drinking with my friends that night, I

likewise did not see or hear of anyone using drugs that

evening.”
9. The copy of medico-legal shows that the underlying cause of
death of Christine Dacera is ruptured aortic aneurysm. The latter is
considered a medical condition. Assuming arguendo that there
existed heroine in the party and was introduced to the body of the
deceased still, drug overdose will not result to the development of
aneurysm, according to the medico-legal. Hence, we clearly deny any
involvement as to the death of Christine Dacera. Attached hereto are
the findings in medico-legal as Annex “B”, to wit:

“IMMEDIATE CAUSE OF DEATH: CARDIO-PULMONARY

ARREST
ANTECEDENT CAUSE OF DEATH: HYPOVOLEMIC SHOCK
UNDERLYING CAUSE OF DEATH: RUPTURED AORTIC
ANEURYSM
MANNER OF DEATH: NATURAL

OPINION
Mechanism of Death:
Aneurism is a defect in the arterial blood vessel wall causing
dilatation. This condition is common among elderly patients due to
atherosclerosis. However, this is also seen sometimes in younger age
group, not associated with atherosclerosis, but due to other factors. It
occurs when an artery’s wall weakens and causes an abnormal bulge.
(See Fig. 1) This bulge can rupture and cause internal bleeding.
There are many causes of aneurysm; increased blood pressure is one
of them. In the person of Dacera, this happened in the aorta that the
continuous increase in her blood pressure within it (aorta) further
weakened that defect, and eventually burst. The moment there was a
tear in the aorta, blood loss will occur and patient is expected to feel
various symptoms like weakness, nausea and diaphoresis this can
explain why she was feeling weird and unlike the feeling of hangover
from previous drinking sessions. The loss of blood due to the
ruptured aorta killed her within few hours. (See Fig.2, blood clots in
the right thoracic cavity). That dilatation or aneurysm started long
time ago or maybe years, prior to her death. No alcohol or
recreational drugs taken night prior to her death will cause that kind
of dilatation or defect on her aorta. That dilatation is chronic
condition and was present long before she died. If she did not die
that faithful night, she will still die in any scenario that presents an
activity that will increase he blood pressure strong enough to tear
that aneurysm.
Furthermore, Dacera’s heart weighed 500 gm (normal is 300 gm).
This is a finding that supports Dacera’s apparently undiagnosed
hypertension. Her heart is enlarged and most probably it is due to
her chronic hypertension. About her kidneys, microscopic
examination revealed glomerular hemorrhages highly suggestive that
there was really significant increase in her blood pressure prior to her
death. Another incidental finding is the presence of myocarditis, or
inflammation of her heart muscle but is not associated with her
sudden death.

Manner of Death:
Manner of death as homicide is ruled out in Dacera’s case because
the aortic aneurysm is considered as a medical condition. Rape
and/or drug overdose will not result to the development of
aneurysm. Even overdose and ruptured aneurysm are two different
conditions and cannot be both included as cause of death of a patient.
Granting, but not assuming, the presence of recreational drugs or
alcoholic substances in her body, that will now be moot and
academic. The ruptured aortic aneurysm will remain the cause of
death as shown in the autopsy findings. An increase blood pressure
is the triggering factor for the ruptured aneurysm. If ever there are
presence of drug or alcohol that will only be incidental finding
because even by their absence, rupture can occur if blood pressure
shoots up from different strenuous physical activities. Vomiting or
retching may also increase blood pressure and trigger the ruptured
aneurysm.
Based on the available information on hand, the manner of death is
classified as natural death.

EXAMINED BY:

PETER NG, MD
Police Lieutenant Colonel
Medico-Legal Officer”

12. We further deny the that we arranged the lifeless body of

the deceased Christine Dacera in the bathtub as stated in the

Affidavit-Complaint. It is only a mere accusation and there was no

submitted evidence to support these accusations. As a matter of fact,

the herein respondent Rommel Galido was even the one who asked

for help to revive the deceased, as stated in the sworn affidavit of

Clark Rapinan, attached here as Annex D, Alain Dayana Chen,

attached here as Annex E, and Gregorio Angelo Rafael De Guzman,

attached here as Annex “C”, to wit: .  

“I heard Galido, Dacera’s close friend asking for help

saying“Guys tulungan nyo ako, parang hindi humihinga si Tin.” I

immediately rushed to check Dacera’s pulse and breathing.

Dacera’s body still felt warm when it was moved out of the

bathtub so I thought I can still revive her. I gave her CPR and

mouth-to-mouth resuscitation but when nothing seemed to happen,

I decided to call the hotel reception to request for a medic and an

ambulance.”

COUNTER-ARGUMENTS

11. Complainant failed to establish the probable cause of the death

of Christine Dacera in their Complaint-Affidavit. Probable cause is
the existence of such facts and circumstances as would excite the
belief in a reasonable mind, acting on the facts within the knowledge
of the prosecutor, that the person charged was guilty of the crime for
which he was prosecuted. In the Complaint-Affidavit submitted by
the complainant, assuming arguendo that there exist a heroine and
the respondents introduced it to the body of Christine Dacera, there
was a sufficient lapse of time between the said injection of heroine to
the body and her death which only occurred the next day in the
afternoon to assume that the probable cause of death is the said
heroine.

11. Base on the foregoing discussions and pieces of evidenced

adduced by the herein respondents, we vehemently deny the crime
of murder charged against us due to the following: (1) That the
underlying cause of death is ruptured aortic aneurysm which is a
medical condition not caused by any kind of drugs; (2) That there
exist no heroine in the said party; (3) That the facts provided by the
complainant that we arranged the dead body of Chsristine Dacera is
a mere allegation with no evidence to support it; (4) That the Annexes
submitted by the complainants were all defective; (5) That the
Affidavit-Complaint contains a lot of inconsistencies with the
annexes submitted by them; and lastly (6) The failure to establish the
probable cause of death of Christine Dacera.

PRAYER

WHEREFORE, premises considered, it is most humbly prayed

that that this case be dismissed for the lack of probable cause in the
commission of the crime of murder as it may deem fit and proper in
the facts and circumstances of the case and thus render justice.

AFFIANT FURTHER SAYS NONE.

 IN WITNESS WHEREOF, I have hereunto place my hands this
24th day of February 2021.

ROMMEL D. GALIDO JOHN PAUL R. HALILI

Affiant Affiant

SUBSCRIBED AND SWORN to before me this 24th day of

February 2021 in Makati City.

AREEYA M. PARK
_______________________
Prosecutor