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.

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.

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

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

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.

g. That you and accused Sandel were able to meet with Dr. Recina.
h. That after about thirty (30) minutes or around 12:15 PM, the meeting
ended with no untoward incident.

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.

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 as I
call her, 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 that 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 to go to the clinic of
accused Sandel and Rosca on Dr. Reciña.
November 17, 2020 at that time?
7. How did it happen that you were Cecil messaged me on November 15,
in that clinic at that date and time? 2020 and requested that I accompany
her to Dr. Recina.
8. What proof do you have? I have the screenshots of our
messages, here sir.
Atty. Santos: These screenshots
were manifested to be marked as
Exhs. “2” to “2-A”.
9. 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.
10. Where is the location of that It is in Shorthorn St. in Bgy. Bahay
clinic? Toro, Quezon City.
11. What time did you arrive at that Around 10:45 AM of November 17,
clinic? 2020, sir.
12. Was there any reason why Yes, sir.
accused Sandel requested you to
accompany her to Dr. Reciña?
13. What was the reason? Cecil told me she wanted me to
mediate between her and 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 any Yes, sir.
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 that consultation?
19. Upon arriving at the clinic, what Upon entering the clinic, 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 were Yes, I remember Cecil showed us a
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 date
recognize it? stamp is November 17, 2020 and the
time stamp is 11:09 AM.
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 at Yes, I was watching the program in
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 front
clinic? 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 less than four (4) meters wall
clinic? 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 that
and Cecil entered that room on the room and Cecil sat on a chair near
second floor? that table.
40. Was there anything you noticed Yes, there was a window type aircon
in that room? 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 clinic Yes, sir.
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. This is the picture of the
picture marked as Exh. 7, do you clinic of Dr. Recina from outside and
recognize this picture? clearly visible is the window with an
aircon unit.
42. After the two (2) of you sat, what After about two (2) minutes, Dr.
happened next? Recina entered the room and seated
herself at the chair behind that table.
43. What happened after Dra. Recina Cecil and Dr. Recina exchanged
entered the room and seated herself some pleasantries and right after,
at the chair behind that table? Cecil brought up the matter of the
unpaid loan she extended to Dr.
Recina.
44. How was that matter brought up? Cecil told Dr. Recina that she badly
needs her money for the medical
treatment of her daughter and in the
process, Cecil started to cry and Dra.
Recina cried also.
45. Was there any response from Dr. Yes.
Recina to Cecil?
46. What was that? Dr. Recina told Cecil that she 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.
47. What else were discussed after Cecil asked Dr. Recina if she can
that, if any? 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.
48. What was Cecil’s reply to that, if Cecil told Dr. Recina she will just
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.
49. 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.
50. Was there anyone telling her None sir, she wrote the promissory
what to write on the promissory note on her own.
note?
51. While Dr. Recina was writing the Yes, sir. Cecil took a picture of Dr.
promissory note, was there anything Recina while she was writing the
you noticed? promissory note and momentarily
showed me the snap.
52. 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, and you
picture marked as Exh. 10, what is can see the date stamp is November
this? 17, 2020 and the time stamp is 12:14
PM.
53. 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.
54. If that promissory note is shown Yes, sir.
to you, can you identify the same and
your signature therein?
55. I am showing you this document That is the same promissory note, sir,
marked as Exh. “B” for the and that is my signature in the
prosecution, what is this? witness portion.
Atty. Santos: We will be adopting
this Exh. “B” as our Exh. “25”.
56. 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.
57. What time did the meeting end, Around 12:20 PM, sir.
if you know?
58. 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.
59. During the entire time that you None at all, sir.
Cecil and Dr. Recina were meeting,
was there any incident involving
yelling, pushing, threatening or any
act of violence or intimidation
against Dr. Recina involving you or
accused Sandel?
60. 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.
61. How long did the entire meeting About thirty (30) minutes, sir.
with Dr. Recina last?
62. Now, in connection with this Yes, sir.
case, do you remember having
executed any affidavit?
63. If that is shown to you, can you Yes, sir.
identify the same?
64. I am showing to you an Affidavit This is the same affidavit I executed
executed by one Rosalea B. Reyes previously, sir.
on February 190, 2021, what is the
relation of this to the affidavit you
said you previously executed?
Atty. Santos: I manifested this
counter-affidavit to be marked as
Exhs. “4” and series for accused
Reyes, which to be exact is Exhs. “4”
to “4-U”.
65. 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?
66. In Sub-par. 9.6 of your Counter- I have two (2) businesses and Ms.
Affidavit, you mentioned about a Ritaga oversees the production
Ms. Aileen Ritaga who is your aspect of my products.
production supervisor. Why do you
have a production supervisor?
67. What are those businesses of I am an exporter of Capiz shell photo
yours?
68. Now, as an accused in this case, Yes, sir.
do you know the allegations against
you and Cecil by Dr. Recina?
69. What are her allegations?
70. What is your view about those Those allegations are malicious
allegations?
71. Why do you say that?
frames and supplies the same to SM
Kultura and I also have five (5)
branches of Roxsie’s Sinugba which
is a food business.
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

72. Why do you say that the physical First of all, Exh. 9, the picture Cecil
evidences do not match with Dr. took of the clinic reception showing
Recina’s fabrications?
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 a
thriving 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.
parts of our body and with time stamp
11:09 AM, clearly shows that we were
seated in the waiting area of the clinic
and hence, we did not barge in. Then,
Exh. 10 which is the picture of Dr.
Recina writing the promissory note
with time stamp 12:14 PM 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,
that she was pushed to the wall several
times by Cecil, that she was crying and

73. You mentioned about the barangay
blotter, why do you know about that?
74. I am showing to you the barangay
blotter marked as Exh. “D” for the
prosecution, why do you say that Dr.
Recina’s narrations in this barangay
blotter are very unnatural and contrary
to ordinary human conduct?
shivering and begging us to leave.
These pictures also prove as untrue the
assertion of Dr. Recina that the entire
incident lasted only between five (5) to
fifteen (15) minutes because it is clearly
demonstrated by the time stamps in the
pictures that we were in the clinic for at
least 1 hour and five (5) minutes
although actually around for one (1)
hour and thirty-five (35) minutes. And
in the consultation room itself, I and
Cecil were there since about 11:40 AM
until we left around 12:14 PM or about
thirty (30) minutes.
Further, 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.
That is attached in her affidavit-
complaint.
Dr. Recina’s handwritten narration in
the barangay blotter made on
November 17, 2020 at 2:00 PM states:
“Ako po si Celerina Recina,
pinuwersang gumawa ng 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
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

Atty. Santos: We are adopting this as
our Exh. “26”.
75. You mentioned about the police
blotter, why do you know about that?
76. I am showing to you the police
blotter marked as Exh. “C”, why do
you say that Dr. Recina’s narrations
in this police blotter are very
unnatural and contrary to ordinary
human conduct?
Atty. Santos: We are adopting this as
our Exh. “27”.
77. What is the reason why you say
that the accusations against you are
mere fabrications and that these
cases are just manufactured?
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 earlier. 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 accusations against us
are mere fabrications.
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 did not include in
her narration the alleged yelling,
vulgarities and pushing that was
done against her. Hence, it only
means that the accusations against us
are mere fabrications.
Dr. Recina is desperate to avoid her
obligations to Cecil and simply is
using these cases as a tool to do that.
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.
78. And apart from that, do you have Yes, sir.
any other document tending to
support your statement?
79. What is that? I have this mail matter that we sent
to Dr. Recina.
Atty. Santos: We manifested this to
be marked as Exhs. “6” to “6-A”.
80. What is in it that tends to support We sent this mail matter at her
your statement that Dr. Recina is address at No. 2 Road 19, Bgy.
desperate to avoid her obligations to Bahay Toro, Project 8, Quezon City
Cecil and simply is using these cases but it was not received on the ground
as a tool to do that? “Moved out”. However, that address
exactly corresponds to her address
that she stated in her Judicial
Affidavit particularly Q&A No. 1.
Thus, this shows that she is indeed
deliberately misrepresenting that she
is not living in that address to avoid
mail matters which also supports the
observation of Ms. Luz Rosca when
she testified.
81. What was that testimony of Ms. She testified that “I even witnessed a
Rosca? messenger came and was serving a
“sulat” addressed to Dr. Recina but
the female staff who talked to him
told him Dr. Recina was not in the
clinic when she was actually inside
and I thought to myself “kautangan
na naman ito”.”
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