REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
CITY OF SAGAY

JACQUELYN C. RECTO
Complainant,

- versus -

Complaint for: Violation of RA9262

Violence Against Women and their
Children

JOHN MICHAEL S. RECTO

Respondent.
x------------------------------------x

COUNTER-AFFIDAVIT

I, JOHN MICHAEL S RECTO, Filipino, 33 years old, male, married and a

resident of Barangay Poblacion, Balete, Aklan , Philippines after having been duly
sworn to an oath in accordance with law, do hereby depose and state: THAT

1. I am the respondent in NPS No. INV-24A-00010 for “Violation of RA

9262 Psychological Abuse filed by JACQUELYN RECTO y CHU at
the Sagay City Prosecutor’s Office;

2. The undersigned is executing this affidavit to vehemently deny all the

accusations of JACQUELYN y CHU in her complaint. Complainant is
deliberately misleading this Honorable Office as there was no direct
proof of said allegations;

3. I deny her allegations in paragraphs 2 and 3. The truth of the matter is

that we moved to the house of my mother in September 2015 at
Barangay Poblacion, Balete, Aklan and stayed therein as our conjugal
dwelling. Attached hereto is my PNP PDS as Annex “1” (see page 3).
Our relationship as husband and wife turned sour when I refused to
help her sister in the person of JEZREL C MANGUILIMOTAN to be
freed from criminal liability during the buy-bust operation conducted
against the latter on August 15, 2016 (Attached hereto is the Spot
Report of the said Buy-bust operation as Annex 2). My refusal made her
angry and she called me a useless husband. The said incident almost
linked me to Tokhang Drug List Protectors. Fortunately, my classmate

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 in the person of Dindo Ebag, the investigator on-case vouched for me to
his team leader that I was not involved. (Attached hereto is the Affidavit
of Dindo Ebag as Annex 3).

4. I likewise deny her allegations in paragraph 5, 6, 7 and 8. The fact is,

that I was not insulting her and stopping her from finding a job. In fact,
she kept saying that she didn’t need to work because she was a
“princess” and that I was obliged to give her money. I then proposed
that I pay for her tuition fees so she could finish a bachelor’s degree at
Aklan Catholic College, where I was at that time enrolled as a law
student, for her and her family’s sake. However, my proposal was
misinterpreted. As she mentioned in the year 2018, it was said by her
that she would go abroad since I proved to be a useless husband for the
second time because I could not help her brother who was also arrested
during a buy-bust operation on June 25, 2018 (Attached hereto is the
Spot Report of the said Buy-Bust Operation as Annex 4).

5. I deny her allegations in paragraph 9 that I was not fulfilling my

obligation as a father. The truth is after my 24-hour tour of duty, she
will be leaving the children to be taken care of by me. She will be
leaving for shopping or vacation without considering my fatigue from
work. Her allegation that she was taking care of the child without a
helping hand is also not true, in fact, we have a house helper that was
washing her clothes and underwear. The house helper in the person of
Lida C. Fuentes was also taking care of our children. Attached hereto is
the affidavit of Lida C. Fuentes as Annex 5.

6. I likewise deny her allegation in paragraph 10, that I was ashamed of

her as a wife. If that were the case, I would never introduce her to my
colleagues, friends, workmates, and even to my professors in law
school. The truth is, I was so proud of her beauty and kept saying to
everybody and even on Facebook that I was lucky to have a beautiful
wife. These posts and pictures were deleted by me in June 2019 when
we became separated in fact.

7. I likewise deny Paragraph 11 and 12, the truth is that sometime in June
2019 right after the death of my father, she left me and our conjugal
dwelling in Poblacion, Balete, Aklan while I was grieving and
mourning. She went to Sagay City with our children and said that she
wanted to separate from me and end our relationship. That if I really
love her and want to be a complete family, I have to follow her in
Sagay City and I should find a way for the release of her brother and be
assigned to their place as a drug protector since it generates a lot of
income. My response to her proposal was in negative, which made her
angry and once again she emphasized my uselessness to her. I begged
her to stay with our children because I was still grieving from my
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 father’s death and that I could not violate my oath and sworn duty to
the service just for her and her family’s convenience, but my plead fell
on deaf ears. From that moment, we’ve been separated in fact as she
laid down the premise that we will move on with our lives without each
other. Despite her leaving, I kept sending financial support to her in
hopes that she and the children would come back home. However, it
was only the children I was able to talk to. (Attached hereto are the
receipts of Palawan Express Padala as annex 6).

8. To lay down all the surrounding circumstances that she was not able to
mention after the year of 2018, it was from June 2019 to October 2019,
that I kept begging her to come back to me and make our family whole
again. I also promised her that I would make sure to pass the bar so that
I could help her brother and sister out of prison through the proper and
lawful means. However, she was always saying that she didn’t love me
anymore and that she already had a new businessman boyfriend who
could give her the life that she wanted. Every time I contacted her, she
would always emphasize my lowly status in the PNP and my salary
which could not sustain her lifestyle.

9. On the last week of October 2019, I flew to Manila and stayed at Park
Royal Condotel, Laong Laan, Sampaloc, Manila with Kris Zaldivar to
take the Bar Examination, wishing that after passing the bar she might
return to our home.

10. During the Bar Examination season, every time I contacted her, she
would always say that I should stop hoping that she would return to me
and love me again.

11. On November 9, 2019, she called me at around at around 11:00

o’clock in the evening, I received a call from her saying discouraging
words that I could not pass the bar exam and all of the students at Aklan
Catholic College were stupid. Our call lasted for three hours revolving
around my stupidity and her claimed businessman boyfriend. At around
2:00 o’clock in the morning of November 10, 2019, while I was kept
telling her that I would still accept her even though she had an affair.
She responded that their relationship started since 2014 and the father
of our children is not me but her claimed businessman boyfriend. Upon
hearing her declaration, I was devastated and did not stop crying until I
proceeded to the Bar Site located at University of Sto. Thomas, España
Blvd, Sampaloc, Manila, 1008 Metro Manila to take the exam. During
the examination, I couldn’t stop thinking about the fact of not being the
father of my beloved children and made myself to disbelieve it. Being
preoccupied and lacking rest, I fell asleep while answering the exams
and was not able to answer all the questions and submitted the test

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 booklets with blank answers. Attached hereto is the affidavit of
Khristianie R Refendor as Annex 7.

12.On November 15, 2019, I called her to clarify and withdraw her
declaration that I am not the father of their children. She then asked me
to send money to her sister for her plane ticket. I then asked Kris
Zaldivar if he could send the money in which he agreed to. Attached
hereto is the affidavit of Kris Zaldivar and photo of the receipt as
Annex 8.

13.During the entire Bar Weeks, she never showed herself and on
November 22, 2019, she called that she would no longer show herself
and that I was stupid to believe her again. She emphasized that she
would never come back to me and that she was already happy since a
lot of men are going crazy to her beauty.

14.On January 10, 2020, in hopes that I can convince her to make our
family whole again, I went to Sagay City. Upon arrival thereat, she was
not in their house. I asked her parents and sisters where is her
whereabouts, but they responded that even them do not know where she
was. Hopeless that I could not fix our marriage, I decided to bring the
children and take care of them in Balete, Aklan. While in transit, she
contacted me and informed me that she was with another man in Cebu.
Attached hereto are the screenshots of my stories on Facebook during
our travel going to Balete, Aklan as Annex 9.

15.The above-stated narration of facts are the incidents that transpired that
the complainant was not able to mention, hence, I deny her allegation in
paragraph 12. The truth of the matter is that, on January 23, 2020, she
went to our house to recover the custody of the children in which I
refused to. I begged again to fix our marriage and that I can still accept
her even if she had her declared paramour provided that she remains in
our conjugal dwelling and fulfill her obligation as mother and a wife.
She responded that if I really wanted to make her stay, I should give her
an iPhone 11 Pro Max and Php 150,000.00 cash. I immediately rushed
to AFPSLAI and Smart Center to produce her request. On January 27,
2022, I was able to give her requests. Attached hereto are the receipt of
the iPhone from Smart Center and the payslips showing the effectivity
of the loan as Annex 10.

16.That sometime in the first week of February 2020, while I was on duty,
my mother called me that my wife was not home and brought with her
our son in the person of Raphael Ceazar C Recto. She was not able to
bring our eldest son in the person of Levi Matthew C Recto since the
latter wouldn’t come with her. Hearing the news, I rushed home to

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 search for her and later called me that she was already on a Ceres Bus
going to Dumanggas, Iloilo. I asked her the reason of her leaving and
she responded that it was not about me but about her. I also emphasized
to her that she told me that she would not be leaving me when I gave
her the iPhone and the cash but responded that she could not love me
back the way I love her.

17. I deny all the allegations against me in paragraphs 13, 14, 15, 16, 17
and 18. The truth is that from the moment she abandoned our conjugal
dwelling in Balete, Aklan, in the first week of February, 2020, I lost all
hope and ceased to beg her to come back. I decided to try to move on
with my life without her, but I never stopped contacting my youngest
son and sending financial support through my mother. I sought comfort
in the company of my circle of friends in the persons of Wiline Relator,
Robe-an Delagdo, Bia Amor Ambrocio Nina Marie Macapaz, L’Jude
Mikkel Cortez, John Ariel Dormido and others. It was difficult to try to
forget the pain I felt because of the actions of my wife, hence I did
everything I could to try to get over her. I tried to drown my sorrows
through going out and drinking with my friends. Our drinking sessions
occurred in different venues, including each other’s houses, in bars, and
if our finances permitted, we would camp out on the beaches of Batan,
Aklan and drink and talk all night. In an effort to try and console me
and help me move on with my life without my wife, my friends, as
mentioned above, would spend the night at my house in Balete, Aklan
and we would drink, watch movies together, and at one point, one of
my friends, in the person of Robe-An Delgado, offered to give us all
facial pampering session, as she said that it usually helps her relax and
it might help me with my case. Hence, that night, I, together with my
abovementioned circle of friends, got a facial from our friend, Robe-An
Delgado. Attached hereto is the Affidavit of Robe-an Delgado as Annex
11.

18.That during the said period, our activities were uploaded to different
social media platforms. With no direct communication with my wife,
she got insecure about the fact that I moved on and accepted that our
marriage could not be fixed. I was not begging for her love anymore
and can live my life with the children without her. At that point, she
was then frequently contacting my mother about my whereabouts and
what I was doing. She also contacted Weng Relator and accused the
latter as my concubine by using a dummy account but she got nothing.
When Weng Relator was not buying her accusations, she then contacted
Robe-an Delgado and also accused her as my other concubine. That
Weng and I has no intimate relationship whatsoever, in fact, we were a
childhood friend. There was also nothing intimate between me and
Robe-an Delgado and I was aware that she was dating someone from
Iloilo City at that time.

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19.I likewise deny her accusations in paragraph 19, 20, 21, 22 and 23.
There is no proof of her allegations of my infidelity. Most of her
allegations are self-serving. Sometime in October 2020, she took my
eldest son without my consent while I was on duty. I then called her
begging her to bring both of my children. In November 2020, she came
to our conjugal dwelling and I tried to reconcile and work out our
relationship but it was futile due to the acts done by her from 2016 to
2019. That I can no longer be with someone who wants me to do illegal
and declare that she was cheating and reveal that I am not the father of
our children as mentioned above.

20.From the time she took the children and went to Sagay City, I started to
move on without her and focused on the review for the 2020/2021 bar
examinations. I never stopped sending financial support through my
mother.

21.On January 29, 2021, J-mar S Moises confronted me that he saw my

wife posting in her stories on Facebook with her new boyfriend. John
Reiuq Q Relimbo also sent me the screenshots of my wife’s stories
showing intimacy with another man. I was also able to search on
Facebook a profile with URL https://web.facebook.com/people/Jackie-
Chu/100073907252865/?paipv=0&eav=AfZ4NvdGKJows-
yn3jLwVAfik8J1y4QnR8c6fjZsBqa0Bmo-
sdcsDk01TV7doNYG5ao&_rdc=1&_rdr showing the picture of my
wife and her paramour. I conducted an investigation and was able to get
the identity of her paramour in the person of PSSg Louil Vailoces.
Attached hereto are the affidavits of J-mar S Moises and John Reiuq Q
Relimbo and Screenshot of stories of Jacquelyn C Recto with her
paramour as Annex 12.

22.Sometime in March 2021, Louil Vailoces contacted me and asked for

an apology and that he did not know that Jacquelyn was married to me.
That if he only knew, he would not commit himself nor get involved
with my wife. Attached hereto is the Affidavit of Louil Vailoces as
Annex 13.

23.To keep focused on the bar, I did not prioritize addressing the extra-
marital affair of my wife since I could not gather direct evidence or
pieces of evidence of her adulterous acts against me. That I keep
sending through my mother financial support for my children.

24.I have no idea of her claims in paragraph 24. We were separated in fact
from 2019.

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25.Sometime in May 2022, Levi Matthew, my eldest son contacted me
through a call using the phone of my mother-in-law asking to rescue
him because their mother left them.

26.I admit paragraph 25 with qualifications. It was on June 19, 2022, I

went to Sagay City to retrieve the custody of my children through the
aid of CSWD of Sagay City and Sagay MPS. Upon retrieval, I found
out that my wife was not staying in their residence and left the care of
our children to the latter’s parents.

27.I deny paragraph 26. The truth of the matter is I instructed my mother
to allow my wife to contact our children.

28.I deny paragraph 28. I did not have an illicit affair with any of her
allegations. The truth is that from August to November 2022, I was
frequently staying at Camp Crame, Quezon City for processing in the
Lateral Entry for Legal Service.

29.I deny Paragraph 29. The truth is we haven’t communicated completely

since sometime in March 2021 until September 2023. It was sometime
in November 2020 the last time I saw her and that I started to live
without her.

30.I deny her allegations in paragraph 30 and 31. The truth of the matter is
that sometime in September 2023 she contacted me in a peaceful
manner and talked about our lives without each other and eventually
became in good terms. She was also posting pictures of our video calls
in her stories on Facebook and occasionally consulting me regarding
legal matters. Attached hereto are the screenshots of her stories on
Facebook and conversation in Messenger as Annex 14. We talked
about our separate lives and eventually had a better understanding of
each other. She would narrate her love life including her affair to Louil
Vailoces, after we became separated in fact. She sent me a photo of her
foreigner boyfriend causing me to feel hurt and jealous. That I
retaliated by sending her photos of random beautiful girls I found on
the internet that I do not know. Attached hereto is the photo sent by her
through telegram of her foreigner boyfriend as Annex 15. Her
allegation that I was saying a lot of sex workers were going to Camp
Crame is also not true. The fact is, I was assigned to Camp Crame on
January 5, 2024 after her allegations of such. Attached hereto is my
assignment order as annex 16.

31.I deny paragraph 32. I never threatened her to plant drugs as evidence
against her. Her allegation is self-serving.

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32.I also deny paragraph 33, 34 and 35. The truth of the matter is that
when she went to the house sometime in December of 20233, I was the
one who convinced the children to be with her since their mother was
not able to see them for almost 2 years. That we have an agreement that
she will return the children on January 2, 2024 which is before the start
of their classes. When the agreed date came, I contacted her that I will
be fetching the children but responded that she wouldn’t return our
children. I admit that I became angry for the reason that she breached
our agreement and exploited my trust and confidence in her given the
fact that we were on good terms and communication with respect to the
custody of the children. Attached hereto is the Police Report of the
Incident as Annexed 16. That I emphasized to her that Levi Matthew is
enrolled in Balete Elementary School as top performer and has to finish
the school year to maintain his standing. I also emphasized to her that
Raphael Ceazar has special needs with a diagnosis of Global
Developmental Delay from a developmental pediatrician. That Raphael
Ceazar must finish his therapy at Kids Care, Kalibo, Aklan. After
which, he must go a follow-up check up to his Developmental Delay.
After laying down all the premises mentioned, she responded that she
don’t believe the findings of the pediatrician and that she could cure by
herself the special needs of the Raphael Ceazar even without
undergoing treatment. Attached hereto are the Certificate of
Enrollment of our Children and the impression of the Developmental
Pediatrician to Raphael Ceazar Recto as Annex 17.

33.Paragraph 36 is denied. During the stint of our marriage, I was faithful

and loyal. It was her who became unfaithful and abandoned me and the
children as mentioned above. She also abandoned our conjugal
dwelling without just cause and intention of returning.

34.I also deny all the statements made by Levi Matthew against me. First
and foremost, my eldest son does not call me “PAPA”. That since he
was a baby I am loved by him and gave all I could to make him happy.
Levi Matthew would not say those statements unless coached or
instructed. I would not allow my child to see me with another woman
or introduced a new mother since I know for a fact that it is traumatic
on his part. I witnessed how he narrated and demonstrated the acts of
his mother and her paramour. That at that moment I would prevent him
from remembering such traumatic experiences. Even his teachers every
time they visited our house, were telling me that my son would always
narrate the obscenity of his mother. Attached hereto is the Joint
Affidavits of his Teacher in Balete Integrated School. That such a thing
would I never show to my children.

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 35.It should be noted by the Honorable Office that all the allegations in the
complaint by the complainant that she had been psychologically abused
started when we became separated in fact. She was trying to attribute
her emotional distress during the period in which we had no
communication and became separated in fact. That she was seeking
relief when in fact in 2019, she became unfaithful to me and now using
RA9262 as a tool to shroud and shield her person from my possible
legal causes of action.

36.By the reason stated above the complaint against herein respondent
should be dismissed. The undersigned thus prays that the instant case
be dismissed.

37.I execute this affidavit to attest to the truthfulness of the foregoing facts
and for whatever legal purpose it may serve;

IN TRUTH WHEREOF, I have hereunto set my signature this 5 th day of

February 2024 at Taguig City, Philippines.

John Michael S Recto

(Affiant)

SUBSCRIBED AND SWORN to before me this 5 th day of February 2024 at

Taguig City, Philippines. Affiant exhibited to me his ID with number _________
and I hereby certify that I have personally examined the Affiant and that I am
satisfied that he voluntarily executed and understood the contents of his Affidavit
because it was explained to him in the dialect and language known to them.

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