Republic of the Philippines

National Capital Judicial Region

Metropolitan Trial Court
Branch 31, Quezon City
metc1qzn031@judiciary.gov.ph

People of the Philippines,

Plaintiff,

versus, Crim. Case No. M-QZN-21-05702-03-CR

Montaos-Sandel and Reyes,

Accused.
x----------------------------------------------------------------------------------------x

JUDICIAL-AFFIDAVIT

I, ROSALEA B. REYES, of legal age, Filipino, single and residing at

Blk. 36, Lot 12-A, Jot St., Goodwill Homes 1, San Bartolome, District V,
Quezon City, pursuant to the examination conducted by Atty. Roderick M.
Santos at his office, under oath and pain of prosecution for false testimony
or perjury, willfully and knowingly answered the following questions, as
follows:

PURPOSE OF TESTIMONY
Atty. Santos: Ms. Witness, the purposes for which your testimony is being
taken in the form of a Judicial-Affidavit is to prove the following:

a. That you are a friend of accused Sandel. YES

b. That accused Sandel on November 15, 2020 requested you to

accompany her to the clinic of private complainant Dr. Celerina Limon-
Reciña (Dr. Recina for brevity) on November 17, 2020 as Sandel wanted
to speak with Dr. Recina regarding the latter’s indebtedness to her and that
you agreed to the same. YES

d. That around 10:40 AM of November 17, 2020, you met accused Sandel
and her companion near Dr. Recina’s clinic. YES

e. That the three of you went inside Dr. Recina’s clinic around 10:45 AM
of November 17, 2020. YES

f. That about forty-five (45) minutes of waiting, one of the staff members
informed accused Sandel that she can now go up and meet with Dr.
Recina. YES

g. That you and accused Sandel were able to meet with Dr. Recina. YES

h. That after about thirty (30) minutes, the meeting ended and you came
down first and then followed by accused Sandel. YES

i. That the accusations made by Dr. Recina’s against you and Sandel that
formed the basis of the present cases are mere fabrications and utter
falsehoods. I STRONGLY SAY YES

j. You will testify on those documents as well as in other material and

relevant matters and identify pertinent documents and exhibits.

QUESTION ANSWER
1. Ms. Witness, do you know the Yes, sir.
accused Sandel?
2. Why do you know her? I knew accused Sandel, or Cecil,
because she is my friend.
3. Do you know a person by the Yes, sir.
name of Maria Luz Rosca?
4. Why do you know Maria Luz I met her on November 17, 2020.
Rosca?
5. What was the reason you met this She was with Cecil when we met on
Ms. Rosca on November 17, 2020? November 17, 2020 around 10:40
AM near the clinic of Dr. Reciña.
6. What is the reason you met with We were then (THERE) to go to the
accused Sandel and Rosca on clinic of Dr. Reciña.
November 17, 2020 at that time?
7. Where is the location of that It is in Shorthorn St. in Bgy. Bahay
clinic? Toro, Quezon City.
8. Why were you going to that Because Cecil wanted me to
clinic? accompany her in talking to Dr.
Reciña regarding the latter’s
outstanding indebtedness to her
which was not being paid.
9. What time did you arrive in that Around 10:45 AM of November 17,
clinic? 2020, sir.
10. How did it happen that you were Cecil messaged me on November
in that clinic at that date (DAY) 15, 2020 and requested that I
and date? accompany her to Dr. Recina.
11. What proof do you have? I have the screenshots of our
messages, here sir.
Atty. Santos: These screenshots
were previously marked as Exhs.
“2” to “2-E”.
12. Where is the original message On my phone, here sir.
thread of these screenshots?
Atty. Santos: We will show this
thread to the prosecution at the
hearing for comparison.
13. What was the reason why you Cecil told me she wanted me to
were requested by accused Sandel mediate between her and Dr. Reciña
to accompany her to Dr. Reciña? regarding the latter’s outstanding
indebtedness to her which was not
being paid and that she will be
bringing a demand letter for Dr.
Recina.
14. What was your reply, if any? I told her Dr. Recina might not even
mind me and if I need to speak at all
since I do not know their
transaction.
15. Now, who went to the clinic? I, Cecil and Ms. Rosca went
together to the clinic.
16. Prior to that day, do you have Yes, sir.
any knowledge about Dr. Recina?
17. Why? I had a consultation with her last
February 1, 2019.
18. What prompted you to go to Dr. Cecil recommended her to me, sir.
Recina for a consultation?
19. Upon arriving at the clinic, what We entered the clinic and the staff
happened next thereat? members at the reception greeted
Cecil “Good morning!” and Cecil
spoke to them and I heard one staff-
member said that Angelika dela
Cruz, a movie personality, was
being treated at that time.
20. How many staff members were I remember there were three (3)
there at that time? female staff members.
21. What happened next after that? The three (3) of us sat in the waiting
area.
22. Do you have proof that you Yes, I remember Cecil showed us a
were there in the clinic at that time? picture of the reception area that she
took while we were waiting there
that caught parts of our body.
23. Why do you know that? She showed us the picture.
24. If that picture is shown to you, Yes.
can you identify the same?
25. I am showing you this picture Yes, sir, that is the picture I was
marked as Exh. “9”, do you referring to and you can see the
recognize it? time-stamp ______. (LUH, DI KO
ALAM WHAT TIME)
26. Where are you in this picture? The leg wearing denim pants with
Onitsuka shoes without lace belongs
 to me, sir.
27. Now, while seated and waiting Yes, I was watching the program in
at that time, was there anything that the TV, occasionally talking with
you did? Cecil and Ms. Rosca and I was also
observing the clinic.
28. What did you observe in that It was a small clinic, directly in
clinic? front where we were seated is the
reception area as shown in that
picture and there was a television
that was turned on at that time and
another television for the CCTV
cameras.
29. Can you estimate the size of the It was about maybe less than four
clinic? (4) meters wall to wall in the front.
30. You mentioned about the Because I can see the CCTV video
television for the CCTV cameras, feed squares in that TV.
why do you know that?
31. You said the three (3) of you sat We were waiting for Dr. Recina to
and waited. What were you waiting talk to Cecil.
for?
32. How long did you wait? We waited for about forty-five (45)
minutes from the time we sat.
33. What happened after that time? The patient, who was the actress
Angelika De La Cruz, eventually
came out and that was the time a
female staff told Cecil “Ma’am,
akyat na po kayo.”
34. What happened next after that? Cecil stood up and she told me “teh,
tara na”.
35. What happened next when Cecil I followed Cecil to the second floor
told you “teh, tara na”? and went with her inside a room.
36. Who were with you when you Cecil, sir.
went to that room?
37. How about Ms. Rosca? She remained in the reception area
as she was talking on her phone.
38. Was there anyone in that room There was no one yet.
when you and Cecil entered the
same?
39. What happened next after you I sat on a bench facing a table in
and Cecil entered that room on the that room and Cecil sat on a chair
second floor? near that table.
40. Was there anything you noticed Yes, there was a window type
in that room? aircon in the glass window behind
 where Cecil was seated and there
was a CCTV placed on top of that
aircon unit.
41. If a picture of Dr. Recina’s Yes, sir.
clinic is shown to you, can you
identify that window type aircon in
the glass window where Cecil was
seated at that time?
Atty. Santos: I am showing you this Yes, sir. Those are pictures of the
picture marked as Exhs. _____, do clinic of Dr. Recina from outside
you recognize these pictures? and clearly visible is the window
with an aircon unit.
42. After the two (2) of you sat, After about two (2) minutes, Dr.
what happened next? Recina entered the room and seated
herself at the chair behind that table.
43. What happened after Dra. Cecil and Dr. Recina exchanged
Recina entered the room and seated some pleasantries and right after,
herself at the chair behind that Cecil brought up the matter of the
table? unpaid loan she extended to Dr.
Recina.
44. How was that matter brought Cecil told Dra. Recina that she
up? badly needs her money for the
medical treatment of her daughter.
In the process, Cecil started to cry
and Dra. Recina cried also.
45. Was there any response from Yes, Dr. Recina told Cecil that she
Dr. Recina to Cecil? is embarrassed that she was unable
to pay and that her clinic is
suffering from low volume of
clients due to the pandemic which
made her think about closing the
clinic.
46. What else were discussed? Cecil asked Dr. Recina if she can
start paying her obligation by
January of 2021 and Dr. Recina
responded yes and that she will
make a schedule of payment that
she will send to Cecil via LBC.
47. What was Cecil’s reply to that, Cecil told Dr. Recina she will just
if any? pick up the schedule of payment
once ready as “sayang ang bayad
sa LBC”. Then Cecil requested Dr.
Recina if she can make a
promissory note to which the latter
 agreed.
48. How did Dr. Recina agree to She went out of that room and after
Cecil’s request? some time, she came back with
some bond papers, she sat on her
table again and begun writing the
promissory note.
49. Was there anyone telling her None sir, she wrote the promissory
what to write on the promissory note on her own.
note?
50. While Dr. Recina was writing Yes, sir. Cecil took a picture of Dr.
the promissory note, was there Recina while she (WAS) writing the
anything you noticed? promissory note and momentarily
showed me the snap.
51. If that picture is shown to you, Yes, sir.
can you identify the same?
Atty. Santos: I am showing you this That is the same picture, sir.
picture marked as Exh. ____, what
is this?
52. What happened next in relation After writing the promissory note, I
to that promissory note? saw Dr. Recina sign the same and
after which, she passed the same to
Cecil who signed it and then Cecil
passed it to me and I signed as
witness.
53. If that promissory note is shown Yes, sir.
to you, can you identify the same?
Atty. Santos: I am showing you this That is the same promissory note,
document marked as Exh. ____, sir.
what is this?
54. After you signed the promissory Dra. Recina stood up which made
note, what happened next? Cecil and I to also stand up and
when Dr. Recina looked at me, I
nodded to her and told her “Kaya
niyo yan Doctora, God bless po.”
and then I exited the room as the
meeting was over and slowly went
downstairs.
55. During the entire time that you, During the meeting, I only said
Cecil and Dr. Recina were in the “Kaya niyo yan Doctora, God bless
room, was there anything you said? po” which was at the end of the
meeting.
56. Who among the three of you It was me and I also went outside as
went to the ground floor first? I heard Cecil and Dra. Recina
 saying goodbyes to one another.
57. What happened next when you Cecil followed and we went to our
exited the clinic? respective cars and while going
there, Cecil said that Dr. Recina was
asking (NOT ASKING, TELLING -
CECIL about how her daughter was
doing and even offering them
coffee.
58. What happened next? Cecil invited me for lunch but I told
her that I have a business meeting
that afternoon and I need to go
ahead already.
59. How long did the entire meeting About thirty (30) minutes, sir.
with Dr. Recina last?
60. Now, in connection with this Yes, sir.
case, do you remember having
executed any affidavit?
61. If that is shown to you, can you Yes, sir.
identify the same?
62. I am showing to you an This is the same affidavit I executed
Affidavit executed by one Rosalea previously, sir.
B. Reyes on February 190, 2021,
what is the relation of this to the
affidavit you said you previously
executed?
Atty. Santos: This affidavit was
previously marked as Exh. “___”
for accused Reyes.
63. Please go over the same and tell Yes, I affirm my statements in this
the Honorable Court if you affirm affidavit.
the truthfulness of all your
statements therein?
64. In Sub-par. 9.6 of your Counter- (MRS. COSICO IS MY SISTER,
Affidavit, you mentioned about AILEEN RITAGA IS MY
Mrs. Rosalinda Costco who is your SUPERVISOR)
production supervisor. Why do you I HAVE A PRODUCTION
have a production supervisor? SUPERVISOR, BECAUSE I AM
AN EXPORTER OF
PHIL.HANDICRAFTS, I AM
ALSO A SUPPLIER OF PHOTO
FRAMES TO SM KULTURA,
(NATIONWIDE) MADE OF
CAPIZ SHELLS. I ALSO HAVE
FOOD BUSINESS, ROXSIE’S

65. Now, as an accused in this case, Yes, sir.
do you know the allegations against
you and Cecil by Dr. Recina?
66. What are her allegations?
67. What can you say about those Those allegations are malicious
allegations?
68. Why do you say that?
SINUGBA, IT’S A “TO GO” OR
“TAKE OUT” STORE. NO DINE
IN. AILEEN IS ALSO MY
SUPERVISOR HERE, WE HAVE
5 BRANCHES AT THE
MOMENT.
Based on the Judicial Affidavit of
Dr. Recina, she alleged that I, Cecil
and one unidentified female around
lunch time of November 17, 2020
barged into her clinic, that Cecil
pushed Dr. Recina and yelled at her
“Putang Ina Mo Doctora, d ka
ba magbabayad!!!” and that I
uttered "magbayad ka na doctora
kumg hindi masasaktan ka!!!", that
Cecil repeatedly pushed her against
the wall, that Cecil and I both yelled
at her "Puta ka doctora,
magbayad ka kung hindi
papatayin naming kita!!!”, that
Cecil brandished a gun at Dr.
Recina, that I kept on uttering that
"Patayin mo na si doc, gago ayaw
magbayad!!", that Dr. Recina was
forced to write a promissory note
while Cecil was pointing a gun at
her and that we were threatening
and cursing her, that Dra. Recina
was crying and begging Cecil and
me to leave, that Cecil again pushed
Dr. Recina and yelled at her
"babalik kmi dito sa November 26,
pa hindi ka nagumpisa mag bayad,
papatayin ka naming doctora".
fabrications to prop up these
equally made up criminal cases
against me and Cecil.
First of all, the physical evidences
do not match with Dr. Recina’s
 fabrications. Secondly, I, Cecil and
Luz all entered the clinic normally
and we did not barge in. We were
greeted by a staff-member, made to
sit and wait for at least forty-five
minutes and we have a picture with
time-stamp of that as proof. Third,
there were CCTVs in the clinic
including one in the room where we
met Dr. Recina in the second floor.
Bakit hindi niya sinubmit yun
CCTV footages sa hukuman bilang
patunay sa tunay na pangyayari
noong araw na iyun sa kwarto na
yun? Fourth, Dr. Recina could have
easily shouted to her staff to call for
any assistance especially since the
clinic is located in a busy area but
they did not do anything, especially
since she had three staff members.
Fifth, when we came out and slowly
crossed the four-lane road, they
could have easily called for
assistance of anyone to stop us but
Dr. Recina and her staff-members
did not. Sixth, there was really no
gun. Seventh, Dr. Recina’s
narrations in the barangay blotter
and police blotter are very
unnatural and contrary to ordinary
human conduct.

Also, I am a businesswoman with

an expanding business. I have no
desire at all to engage in acts that
Dr. Recina has alleged. Most of all,
I was there and I knew that none of
the events she alleged ever
happened. These are the reasons
why I say that these cases are
merely manufactured or gawa-gawa
lang.
69. Why do you say that the First of all, the picture Cecil took of
physical evidences do not match the reception showing parts of our
with Dr. Recina’s fabrications? body and with time stamp “_____”
clearly shows that we were seated in
the waiting area of the clinic and
hence, we did not barge in. Then,
the picture of Dr. Recina writing the
promissory note clearly shows she
was relaxed and her face shield and
clinic gown properly worn which is
thus contrary to her claim that Cecil
was pointing a gun at her while she
was writing the promissory note and
that she was pushed to the wall
several times by Cecil. Then the
promissory note itself showing that
the written contents of the same are
perfectly aligned and even the
signatures are perfectly slotted in
the spaces those were written thus
debunking her claim that she was
shivering in fear and crying while
she was writing the same. The
barangay and police blotters also do
not support her fabricated story.
70. You mentioned about the That is attached in her affidavit-
barangay blotter, why do you know complaint.
about that?
71. I am showing to you the Dr. Recina’s handwritten narration
barangay blotter, why do you say in the barangay blotter made on
that Dr. Recina’s narrations in this November 17, 2020 at 2:00 PM
barangay blotter are very unnatural states: “Ako po si Celerina Recina,
and contrary to ordinary human pinuwersang gumawa ng
conduct? Agreement to pay kay Cecilia
Montaos-Sandel. Ako po ay
pumayag kasi nakatutok at kinasa
ang baril niya. Ako po ay may
pagkakautang kay Cecilia Montaos-
Sandel na 3,000,000 pero may
interest po iyon na 5% per month,
nakabayad na po ako sa kanya ng
5,145,000 last Dec, 2019. Ngayon
sa hirap ng buhay wala na ako
mababayad kahit ano gawin ko.
Pinuwersa ako magsulat ng
Agreement na simulan ko daw

72. You mentioned about the police
blotter?
73. I am showing to you the police
blotter, why do you say that Dr.
Recina’s narrations in this police
blotter are very unnatural and
contrary to ordinary human
conduct?
74. What is the reason why you say
that the accusations against you are
mere fabrication and that these
cases are just manufactured?
magbayad ng principal sa Jan 2021.
Natakot ako kaya nagreklamo ako.”
What is starkly missing here is me
and the lack of accusation as to the
alleged yelling, vulgarities and
pushing. If the incident is indeed
true, it is very unnatural that Dr.
Recina would forget to include me
in the barangay blotter that was
executed in her own handwriting,
considering the gravity of my
alleged actions, and the fact that my
name is in the promissory note she
just wrote. It is also very unnatural
that she forgot to include the alleged
yelling, vulgarities and pushing that
was done against her. Hence, it
only means that the accusation
against us is a mere fabrication.
That is also attached in her
affidavit-complaint.
Dr. Recina’s narration in the police
blotter in QCPD Talipapa Station 3
made on November 17, 2020 at
2:30 PM states or just 30 minutes
after the barangay blotter
essentially states the same narration
as in the barangay blotter except
that I was reported as Cecil’s
companion but still, Dr. Recina still
(REDANDUNT?) did not include in
her narration the alleged yelling,
vulgarities and pushing that was
done against her. Hence, it only
means that the accusation against us
is a mere fabrication.
Dr. Recina simply is using these
cases in order not to pay Cecil. I
remember vividly in the first
hearing, unang hearing pa lang ng
kaso na ito, yun abogado ni Dr.
Recina na si Atty. Millora nag-offer
na agad i-atras ang kaso kung
 papayag si Cecil na hindi na
sisingilin yun Php 3 million kay Dr.
Recina. Siyempre, yun ang balak at
plano talaga nitong doktora na ito.
So yun, halatang-halata na nag-
imbento ng kaso itong si Dr. Recina
kasi ayaw lang magbayad at
idinamay pa ako sa
kasinungalingan niya, doktora pa
naman pero sinungaling at
ginagamit ang hukuman, pulis at
barangay sa panloloko niya.
Atty. Santos: I have no more
questions to you as of now. Thank
you.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

____ May 2023 in _______________________.

ROSALEA B. REYES
Govt ID
Expiry

SUBSCRIBED AND SWORN to before me ____ May 2023 in

_______________________.

Doc. No. _____

Page No. _____
Book No. _____
Series of 2023

ATTESTATION

I, ATTY. RODERICK M. SANTOS, hereby attest that I have

examined ROSALEA B. REYES and that I have faithfully recorded the
questions I asked and the corresponding answers of the witness and that I or
any other person present or assisting me coached the witness regarding his
answers to my questions.
 ATTY. RODERICK M. SANTOS

SUBSCRIBED AND SWORN to before me this ____ May 2023 in

_______________________.

Doc. No. _____

Page No. _____
Book No. _____
Series of 2023