Republic of the Philippines)

Province of Cagayan ) SS
Tuguegarao City )

AFFIDAVIT

I, MARIA COSOLACION BAQUIRAN, of legal age, Filipino,

married, and currently residing at Centro I, Tumauini, Isabela, after having
been duly sworn to in accordance with law, depose and state THAT:

1. I am the then President & CEO of HGBaquiran College, Inc in the 1 st

semester of the School Year 2005-2006 and I am the spouse of the
current President & CEO of the same college, Honorato G. Baquiran;

2. I personally know Gretchen V. Balangat, Jaycel Pamittan , and

Kristine Mea C. Sadang who are the former employees of
HGBaquiran College, Inc. particularly when I was still the President
& CEO of the same College;

3. I came to know of a pending labor case against the College filed by

Gretchen V. Balangat, Jaycel Pamittan, and Kristine Mea C. Sadang
for illegal dismissal and unpaid wages which is now pending before
the Regional Arbitration Branch No. 02 of the National Labor
Relations Commission, Tuguegarao City, Cagayan;

4. I came to know also that a criminal case was filed against the same
former employees of the College for Theft regarding the taking
without the consent of the concerned officials of the College
important documents needed for the accreditation by the CHED
which case is now pending for preliminary investigation before the
Provincial Prosecution Office, Ilagan, Isabela;

5. In their complaint before the Regional Arbitration Branch No. 02 of

the National Labor Relations Commission, Tuguegarao City,
Cagayan, the afore-named former employees are claiming and
alleging that when they were employed by the College, they were
enticed by the promise of the officials of the College, to include me as
the then President & CEO, the amount of “P20, 000.00 monthly salary
plus free board and lodging” which offer became, according to the
afore-named, a “silent internal arrangement”;

6. It was further claimed by these former employees that the College,

according to the afore-named former employees, “reneged on the
terms and conditions” of the “silent and internal arrangement”;

7. Allegedly, among the former employees offered with such “P20,

000.00 monthly salary with free board and lodging” were Jaycel
Pamittan, a certain Marcel B. Atianzar, a witness for the Jaycel
 Pamittan, et al, and the former dean of the College, Dr. Adelaida
Leano;

8. I have personal knowledge of the facts surrounding the employment

of the afore-named employees in the outset, Jaycel Pamittan, et al.
including their purported witness, Marcel B. Atianzar, I being then the
President & CEO of the College, and I vehemently deny the existence
of an offer made by the College regarding this “P20, 000.00 monthly
salary plus free board and lodging” to the afore-named and also the
existence of this purported not only “silent” but also “internal
arrangement”;

9. This Jaycel Pamittan and Marcel B. Atianzar are just making up their
stories regarding this imagined terms and conditions of their
employment when they are still employed by the College;

8.1 There is no iota of reason for the College to enter into a “silent”
much less “internal arrangement” with Jaycel Pamittan
regarding her salary. One thing for sure, it was Jaycel Pamittan
who made a silent and internal arrangement with herself since
according to her, the same is “silent” and at the same time
“internal”;

8.2 The fact that a written contract was drawn between Jaycel
Pamittan and the College, I representing the College in that
contract, that contract is the true intent and agreement of the
parties, and any and all “silent and internal arrangement”, in the
far possibility that there be any, are deemed abrogated by the
terms and conditions of the written contract which Jaycel
Pamittan signed freely and voluntarily;

8.3 More importantly, Jaycel Pamittan was not compelled much

less threatened by me or any person to enter into the written
contract with College but instead after reading the same, which
I can conclusively presume that she understood the terms and
conditions since she herself boasted that she holds a masteral
degree, she signed it and the same became the agreement of the
contracting parties;

8.4 What is more suspicious to this “silent and internal

arrangement” is that the written contract was consummated on
its letters for a period of time and Jaycel Pamittan, of wonders
of all wonders, did not protest but instead brought about its
consummation;

8.5 A contract that is “silent and internal arrangement” cannot be

asked to be complied with given the scenario that there is a
written contract entered into between the College and Jaycel
 Pamittan enumerating all the terms and condition of the
employment contract;

8.6 Adding to the inexistence of this purported “silent and internal

arrangement” is the refusal of Dr. Adelaida Leano to affirm its
existence because she does not want to be a party to this lying
expedition and wild imagination of Jaycel Pamittan;

9. Jaycel Pamittan is even attempting to give explanations why such

purported “silent and internal arrangement” existed when in fact what
she could tender are merely speculations and Cinderella bedtime
stories;

10.The College and I are not only standing on mere denial of the
existence of this “silent and internal arrangement” but by its blatant
factual and legal impossibility to exist under the circumstances as
explained and enumerated above. Borrowing the expressions used by
Jaycel Pamittan in her Affidavit of Merit, it would be a “sheer
stupidy” and “incredulity and absurdity” for such contract to exist
under the circumstances;

11.I will not go on silently on the contention of Jaycel Pamittan that her
name was used by the College with the feeling that she is the most
important homo sapient in the whole world when the College was
established creating the picture that no College would come to being
without her and also creating the impression that she was pirated from
other school. Such statement of her is not only a badge of her
arrogance but also her extremely wild imagination;

12.I take exemption to the insinuation of the Gretchen V. Balangat,

Jaycel Pamittan and Kristine Mae C. Sadang in the criminal case as
well as in the labor case that I allegedly made statements regarding the
stolen/missing documents. These people, with their Marxist ideas,
have instigated a certain Maryjane Lobres to concoct a story wherein I
allegedly said that “gumagawa na naman ng kwento itong si Honorato
at Dean Navarro”;

13.I vehemently deny that I made such statement and that necessary
criminal case of perjury against the instigators and Mary Lobres will
be filed in court since these people did not only invent stories but they
are likewise in a mission to destroy the harmony in my marriage by
putting words in my mouth against my husband;

14. Lastly, the picture given by the afore-named former employees that
the College has been remised with its obligations to its employees are
all but concoction with the intent of making it appear that they are the
abused when in fact they are the abuser. The afore-named tender
nothing but sublime and poetic words drained in evidence;
 15.I am executing this affidavit to attest to the truthfulness of the
foregoing facts and for the purpose of refuting the existence of
purported “silent arrangement” or sweetheart deal regarding the
employment of Marcel Atianzar and Jacel Pamittan.

MARIA COSOLACION BAQUIRAN

SUBSCRIBED AND SWORN to before me this __ day of June 2006

at Tuguegarao City, Cagayan.

CERTIFICATION

I CERTIFY that I have personally examined the affiant and I am

satisfied that the foregoing sworn statement is being executed freely and
voluntarily.