REPUBLIC OF THE PHILIPPINES)

ZAMBOANGA CITY . . . . . . . . . )S.S.

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COUNTER AFFIDAVIT
Re: Criminal Case No. 56377-3115
For: Slight Physical Injuries
I, WILLIAM A. USMAN JR., of legal age, Filipino, single, and a resident
of Zone 2, Zamboanga City, after having been sworn, hereby depose and
state that:
1. I am the respondent in the Case filed before this Honorable Court
docketed under Criminal Case number 56377-3115 for Slight
Physical Injuries filed by HERBERT D. ABRAHAM JR.;
2. I vehemently deny the allegations of aforementioned private
complainant in his Complaint-Affidavit as these are mere
fabrications and figments of his own imagination to destroy my
reputation because I refused to have a romantic relationship with
him;
3. The truth of the matter was that he was drunk and could hardly
walk when he came over to my house on or about 8:00 in the
morning of 04 February 2016 at Apartment #3-A, Zone 2,
Zamboanga City. He was also shouting at the top of his voice
looking for me. Hence, I approached and asked him to leave and
come back the following day instead but he refused to do so. Since
he could no longer be calmed I just ignored him and went inside our
house.
4. On the other day, 05 February 2016, I heard a news that he was
beaten into death by a group of men on his way to their family
home at Sta. Barbara, Zamboanga City. According to our friends, he
disturbed the neighborhood when he threw the garbage cans and
bags placed at the roadside while shouting my name;
5. I am executing this counter-affidavit to attest to the truthfulness of
the foregoing to refute the allegations of Herbert D. Abraham Jr.
and in compliance with the Order of this Honorable Court requiring
me to submit the same.
IN WITNESS WHEREOF, I have hereunto affixed my signature this
_____________ , at Zamboanga City, Philippines.
WILLIAM A. USMAN JR.
Affiant
TIN: 9912-31234-433521
SUBSCRIBED AND SWORN to before me this ______________ at
Zamboanga City, Philippines.

I hereby certify that I have examined herein affiant and I am satisfied

that he voluntarily executed his counter-affidavit and understood the
contents thereof.