IN RE: PRE-CHARGE INVESTIGATION PCI REFERENCE NO.

:
RIAS4AHRIAS-NMP-PCI-0324-030

AGAINST: PSSg Ronnie Glenn C Bagsic For: Simple Misconduct

PCpl Arnold B Cadorna (RA 9262)

JOINT COUNTER-AFFIDAVIT

We, PSSg RONNIE GLENN C BAGSIC, of legal age, married, Filipino, and a
resident of Brgy. Bilaran, Nasugbu, Batangas, and PCpl ARNOLD B
CADORNA, of legal age, married, Filipino, and a resident of Brgy. Aga,
Nasugbu, Batangas, after being duly sworn in accordance with the law, hereby
depose and state that:

1. On March 1, 2024, we received a copy of the Notice/Order to File

Comment/Conter-Affidavit dated March 1, 2024 issued by this good office.

2. In the said Notice/Order, we were directed to file our

Comment/Counter-Affidavit thereto within five (5) days from receipt of the said
Notice/Order.

3. Pursuant thereto, we have five (5) days from March 1, 2024 or

until March 6, 2024 within which to file this Counter-Affidavit.

4. Hence, this Counter Affidavit is timely filed.

5. We respectfully vehemently deny all the allegations of Complainant

Norilyn C. Macapagal (“Complainant Norilyn”) and her witness Marilyn C.
Macapagal (“Marilyn”) against us, the fact of the matter being as follows:

6. We are bona fide members of the Philippine National Police. We are

currently assigned in Nasugbu Municipal Police Station, Nasugbu, Batangas as
Investigators.

7. On February 17, 2024, Dulce Maria Bendolo (“Dulce”), Camila

Coro (“Camila”), and Emmarie Malabanan (“Emmarie”) went to Nasugbu
Municipal Police Station to file a case against Complainant Norilyn. We
assisted them as we were the investigators on duty then. According to them,
Complainant Norilyn physically hurt Dulce and then also forcefully took
Camila’s phone. To support their complaint, they showed us the Certificate to
File Actions against Complainant Norilyn issued by the Office of the attached
as Annex “1” and Annex “1-A”. The statements of Dulce Maria Bendolo,
Camila Coro, and Emmarie Malabanan are also hereto attached as Annex “2”,
“2-A”, and “2-B”, respectively.

8. Based on the barangay minutes, Complainant Norilyn did not

attend the barangay conciliation. We then went to the area where the incident
allegedly occurred to investigate the facts refferedto us by Dulce, Camila, and
Emmarie.
 9. When we arrived at the area, we alighted by a store which was just
on Apacible Boulevard, the main road in the area. PCpl Cardona then saw and
greeted Jojie Katigbak Ramos (“Jojie”), a resident therein. The two knew each
other as PCpl Cardona used to live in the area, A copy of the sworn statement
of Jojie Katigbak Ramos is hereto attached as Annex “3”.

10. While we were standing by the store, we asked Jojie if he was

aware of any altercation involving Complainant Norilyn last February 13, 2024
wherein Complainant Norilyn allegedly hurt and took the cellphone of
someone. Jojie then answered that he heard that there was indeed an incident
like that.

11. Then Kenneth Bryan Delmundo (“Kenneth”), also a resident in the

area and who happened to hear our conversation, approached us and told us
that as far as he knew, there was already a complaint filed in the barangay
pertaining to the alleged altercation. A copy of the sworn statement of Kenneth
Bryan Delmundo is hereto attached as Annex “3-A”.

12. While we were still talking, Marilyn, sister of Complainant Norilyn,

passed by the store where we were standing. We knew her as she is a fruit
vendor in the public market. We then talked to her and asked her about the
complaint against her sister at the barangay.

13. According to Marilyn, it was not her sister who was being
complained of at the barangay since the spelling of the name of the person
being invited for barangay conciliation was different from the spelling of the
name of her sister.

14. We then left the area and went back to the station.

15. There is no truth to the allegations of Complainant Norilyn that we

harassed her or any child or that we embarrassed her when we went to their
area.

16. We never saw her or her child or her niece or nephew when we
went to their area. Thus, there was no way that we could have harassed any of
them. There was also no way that we could have threatened her with the filing
of a case as we did not even see her then. The statement of her sister, Marilyn,
also confirms the fact that we never got to her then. The statement of her
sister, Marilyn, also confirms that fact that we never got to talk to Complainant
Norilyn. As Marilyn stated, we talked to her and not to her sister.

17. Moreover, the undersigned respectfully submits that the fact that
we were merely investigating the matter should not be construed as
harassment. Otherwise, it could set a dangerous precedent where the
performance of our lawful duties could be adversely affected for fear that
thoroughly investigating cases could result in administrative cases against us.

18. The truth of the matter is that we merely talked to Jojie, Kenneth,
and Marilyn to investigate the facts of the complaint being filed with us by
Dulce, Camila, and Emmarie. The only reason we could think of as to why
Complainant Norilyn filed this complaint against us is so that we would think
twice about assisting Dulce in filing a case against her.

19. Based on the foregoing, it is most respectfully prayed that this

good office DISMISS the complaint against us for lack of merit.

PSSg RONNIE GLENN C BAGSIC PCpl ARNOLD B CADORNA

Affiant Affiant
National ID No. 6231-6512-6146-0479 PNP ID No. 23F2200228