PHILIPPINE NATIONAL POLICE,

Complainant,

Administrative case number

Versus PRO10-11292018-001 and
PRO10-11292018-002

PO3 Maulana M. Acoon

Respondent,

X-------------------------------------------X

ANSWER
(In Re: SUMMONS received on January 27, 2019)

Respondent, through the Undersigned Counsel hereof, comes unto the

honorable body and registers this answer to the complaint. Respondent
respectfully states;

ADMISSIONS AND DENIALS

1. That Respondents admits paragraphs 4 and 5 of the Complaint

with the additional averment that he may be served with all body
processes unto his present office assignment;

2. That defendant could not make an informed comment respecting

sub-par(1) of paragraph 6 as the respondent has not received any
of the purported notices and demand;

3. That paragraph 7 is denied for lack of basis to form a belief as to

its truth and veracity there being no proof shown to substantiate
that he held personal interest over the said firearms;
 DEFENSES

4. As affirmative defences , the respondent alleges that;

4.1 That he is currently assigned at Poona-Piagapo

Municipal Police Station and was assigned prior thereto
in Tagoloan Municipal Police Station as shown in
( Relieved and Re-Assignment Order marked as
Annex 1)

4.2 That he is bonafide resident of Barangay. Moncado,

Kadingilan, Marawi City, Lanao del Sur as shown in
(Certification of Residency as Annex 2)

4.3 That as averred in the complaint Sub. Par.(1) of

Paragraph 6, Demand letters through substituted service
was sent through registered mail and were delivered to
his last known address but none of those came to his
knowledge.

4.4 That the knowledge about the demand to return the

issued long firearms came to him only upon the receipt of
Notice on October 8, 2018(Notice of administrative
complaint is hereby attached as Annex 8)

4.5 That upon the receipt of notice of administrative

complaint on October 10, 2018, he immediately secured
a counter affidavit in compliance with the notice dated
October 10,2018(Counter Affidavit Annex 9 )

4.6 That in the counter affidavit , the respondent discloses

that he have no intention to ignore to said firearms upon
demand and that the failure to return said firearm is
based solely on fortuitous event without his fault as
shown in the counter affidavit with its corresponding
attachment such as the police blotter on the loss of the
firearms during marawi siege( Police Blotter Nr. 399 as
annex 7) investigation report: In Re loss of issued
firearms of PO3 Maulana M. Acoon of Barangay
Moncado Kadingilan, Marawi City( marked as Annex 6)
 Photographs of his Residence after the seige where the
said firearm was hidden( marked as Annex 4 & 5).

TIMELINESS

5. That this ANSWER is submitted seasonably;

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that

this Honourable body render judgment as follows:

1. A preliminary hearing as soon thereafter as may be convenient to

the Honourable body to consider favourably the merit of the
respondents’ submission.

2. After such hearing, the complaint BE DISMISSED.

Other forms of relief that are just and equitable under the premises
are also prayed for.

Iligan City, February 04, 2019

By:

CONSTANTINO O. SILVA
Roll No. 20936
PTR No. 6286523cy
IBP No. 1016190CY
MCLE Comp. No.1002886’08