REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
BAGUIO CITY
ANNA ROSE SANTOS,
Complainant,
-

versus 17B-03998

NPS Docket No.

FOR: MURDER

JUAN BATUMBAKAL and

OSKAR SULAYMAN,
Respondents.
x---------------------x

COUNTER

AFFIDAVIT

I, JUAN BATUMBAKAL, of legal age, single, and a resident of No.

34 Bonifacio Street, Baguio City, after being duly sworn in accordance
with the law, hereby depose and state that:
1. I am the same person who is charged with the crime of Murder
pending before the Office of the Prosecutor of Baguio City,
docketed under NPS No. 17B-03998;
2. I was a former police inspector stationed at Bonifacio Police
Station, Baguio City;
3. On 7 September 2016, I was at home the whole morning, waiting
for my two (2) children to finish preparing for school (10am-2pm),
as I was about to take them on an owner-type vehicle to St. Louis
Boys High Elementary Building;
4. It was a daily routine for me to take them to school in the
morning, eat lunch with my wife at home, and man our sari-sari
store at the nearby market thereafter;
5. I could not have been one of the respondents since the bank,
where the supposed altercation happened, was out of our way to
school, and thus impossible for me to drive my children using
that route;
6. Based on the records, I and OSKAR SULAYMAN were the ones who
previously handled the case of violation of R.A. 9165 or The
Dangerous Drugs Act against Frank, who was later found guilty,
four (4) years ago;
7. However, after resigning from work last February 23, 2014, my
connections with the other police inspectors already stopped and

I did not have the chance to monitor the status of the case as
well as the person or persons involved anymore;
8. I am voluntarily executing this affidavit to attest to the
truthfulness of the foregoing facts and to support the outright
dismissal of the complaint filed against me.
PRAYER
WHEREFORE, premises considered, it is respectfully prayed that
the instant criminal complaint be DISMISSED.
IN WITNESS WHEREOF, I have hereunto affixed my signature this
3 of October 2016 at Baguio City, Philippines.
rd

JUAN BATUMBAKAL
Affiant
SUBSCRIBED AND SWORN to before me, the undersigned
prosecutor, this 3rd day of October, 2016 at the City of Baguio,
Philippines, affiant, JUAN BATUMBAKAL, exhibiting to me his License
No. 039338 issued at LTO Baguio, Philippines on the 19th of April 1978.
JOHN DAVID MANALASTAS
Notary Public

SWORN

STATEMENT

I, JUANA BATUMBAKAL, of legal age, married, and a resident

of No. 34 Bonifacio Street, Baguio City, after being duly sworn in
accordance with the law, hereby depose and state that:
1.

I am the wife of JUAN BATUMBAKAL who is charged with the

crime of Murder pending before the Office of the
Prosecutor of Baguio City, docketed under NPS No. 17B03998;

2. On 7 September 2016, I was at home with him the whole

morning, waiting for our two (2) children to finish preparing
for school (10am-2pm), as he was about to take them on an
owner-type vehicle to St. Louis Boys High Elementary
Building;
3. He was always in charge of taking our children to school in
the morning, as I do the daily household chores, he also eats
lunch with me at home, and man our sari-sari store at the
nearby market thereafter;
4. He could not have been one of the respondents since the
bank, where the supposed altercation happened, was out of
their way to school, and thus impossible for me to drive my
children using that route;
5.

I am voluntarily executing this affidavit to attest to the

truthfulness of the foregoing facts and to support the
outright dismissal of the complaint filed against him.

IN WITNESS WHEREOF, I have hereunto affixed my signature

this 3rd of October 2016 at Baguio City, Philippines.
JUANA BATUMBAKAL
Affiant