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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


REGIONAL TRIAL COURT
BRANCH 263, MARIKINA CITY

PEOPLE OF THE PHILIPPINES Crim. Case No. 2016 – 17771-MK


Plaintiff,
For: Carnapping
-versus-

ANALIZA S. UY
Accused.
x--------------------------------------------x

JUDICIAL AFFIDAVIT OF CHARLES K. HALEY

I, Charles K. Haley, of legal age, single, American Citizen, with


residential address at 312 Barcelona Building, Marquinton
Residences Condominium, Sumulong Highway, Marikina City, after
being duly sworn to in accordance with law hereby depose and state
that:

The taking and preparation of this Judicial Affidavit was


conducted by Atty. SHERWIN C. FERRER at his law office located at
CU01-A Alicante Tower, Marquinton Residences, Sumulong Hi-way,
corner Toyota Avenue, Brgy. Sto. Nino, Marikina City on October 2,
2017.

Likewise, as witness, Mr. Charles K. Haley in answering the


questions asked of him is fully conscious that he does so voluntarily
under oath and that he may face criminal liability for false testimony
or perjury.

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OFFER OF TESTIMONY:

The Testimony of the witness is being formally offered to prove


the following:

a) To prove the material allegations contained in the Information,


particularly the commission of the essential elements of
Carnapping under Republic Act No. 6539 otherwise known as
the Anti-Carnapping Act of 1972.

b) To identify certain documents in his Judicial Affidavit and to


attest to the truth and veracity of the same; and

c) To prove such other matters relevant to his case.

QUESTION AND ANSWERS

Q1: Do you swear to tell the truth and nothing but the truth?
A1: Yes Attorney.

Q2: Please state your name and other personal circumstances.


A2: I am Charles K. Haley, of legal age and with residential address
at Barcelona Building, Marquinton Residences Condominium,
Sumulong Highway, Marikina City

Q3: Are you the same Charles K. Haley who is the Private
Complainant in this instant case?
A3: Yes Sir.

Q4: Being the private complainant, what kind of motor vehicle is


the subject matter of this case?
A4: It’s a Mitsubishi Montero with Plate No. PAI 575 Sir.

Q5: Do you know the details of the said vehicle?


Q5: Yes, as the owner of said vehicle, it is a Mitsubishi Montero GLS
2010 Model with Plate Number PAI 575.

Q6: How are you related to the Accused, Analiza S. Uy, if any?
A6: She is one of the employees of Eurasiamquest Inc., a manpower
agency that I manage.

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Q7: How did you acquire ownership of the aforementioned
vehicle?
A7: I purchased the aforementioned vehicle from the accused,
Analiza S. Uy. I have a copy of the Deed of Absolute Sale dated
December 10, 2011 executed between me and the accused.

(Request to have the Deed of Absolute Sale dated 10 December


2011 marked as Exhibit “A” for the prosecution.)

Q8: There appears to be signatures over the names of Charles K


Haley and Analiza S. Uy in this Deed of Absolute Sale, do
you know whose signatures are these?
A8: Those are my signature and that of the Accused.

Q9: Why do you know that it was the signature of the Accused?
A9: Because I am well familiar with her signature since I have seen
her sign her name on several documents.

(Request that the signatures of the contracting parties in the Deed


of Absolute Sale be marked as Exhibits “A-1” for Private
Complainant and “A-2” for the Accused.)

Q10: Under whose name the aforesaid motor vehicle is registered,


if you know?
Q:10: It was still registered under the name of Analiza S. Uy. I have a
photocopy of the Official Receipt and Certificate of Registration
of the aforementioned vehicle.

(Request to have the Official Receipt and Certificate of Registration


of the Mitsubishi Montero GLS 2010 Model with plate number PAI
575 marked as Exhibits “B and B-1” for the prosecution.)

Q11: How come that the registration of the said vehicle was still
under the name of the accused and not in your name?
A11: I was not able to cause the transfer of registration of the said
vehicle by reason that the Accused told me that the Land
Transportation Office would not allow me to do that because I
am a foreigner so I believe her. She also assured me that after
paying her the amount and upon execution of the Deed of sale
that I would be the legal owner of the said vehicle and she will
not take it because I have already paid for the same.
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Q12: Do you have proof that you indeed paid for the
aforementioned vehicle, if any?
Q12: Yes, I have here a certification from Union Bank Intramuros
Branch stating that I paid for the downpayment, chattel
mortgage fee one month advance and monthly amortizations of
said vehicle using my personal checks

(Request to have the Certification from Union Bank Intramuros


branch marked as Exhibit “C)

Q13: Sir, where were you on October 31, 2015 at around 12:30 in the
afternoon?
Q13: I was on my way back here in the Philippines from Illinois,
United States for my annual check up.

Q14: What time did you arrive here in the Philippines, if you
know?
Q14: I arrived at NAIA Terminal at around 4:30 in the afternoon.
From there I travelled to Marquinton Condominium Residences
for about two (2) hours. Then I went straight to my
Condominium unit 312 after a while

Q15 Upon arriving at in my residence in Marquinton Residences,


What happened next, if any?
Q15: When I returned in my residence in Marquinton Residences, I
went to my parking slot designated as Parking Slot No. 30 and I
was shocked that my vehicle was already missing.

Q16: Who owns the parking slot denominated as Parking No, 30, if
you know?
Q16: I own the Parking Slot No, 30. I have here the Condominium
Certificate Title No. 009-201000051 for the said Condominium
Parking Slot.

(Request to have the Condominium Certificate Title No. 009-


201000051 be marked as Exhibit “D” for the Prosecution.)

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Q17: What happened next if any?
Q17: I immediately reported the fact of the loss of my vehicle to the
security guard on duty Mr. Antonio Fungo of the
Condominium Building, who informed me that he saw that the
accused, Analiza S. Uy took the my vehicle at around 12:30 in
the afternoon.

Q18: Do you have a proof of the report that you made, if any?
A18: Yes. I have a copy of the Sworn Statement of Antonio Fungo
dated December 9, 2015 and the attached copy of the Logbook
of Marquinton Residences

(Request to have the Sworn Statement of Antonio Fungo and the


copy of the logbook be marked as Exhibits “E and E-1” for the
Prosecution.)

Q19: What happened next, if any?


A19: I tried to call the Accused through her cellphone but she was not
answering her cellphone.

Q20: After calling the accused, what happened next, if any?


A20: I found out that for two days (Saturday and Sunday) the
accused did not exert any effort to return my vehicle. On
Monday, the third day, I went to FEMII Building, Intramuros,
Manila where Eurasiamquest Inc. is holding its office. I was also
shocked that the accused went there during when there on
Saturday and Sunday. One of my staff, Romeo S. Galang Jr.
informed me that the accused together with Rey Gorgod,
Adones Carmona have ransacked my private office. They got
the Official Receipt and Certificate of Registration of my vehicle
(Exhibits B and B-1), cash in the amount of Twenty Five
Thousand Dollars ($ 25,000.00) and other important documents.
That is why they have the accused and her aforementioned
cohorts have a pending criminal case before the Metropolitan
Trial Court Branch 24 of City of Manila for Robbery in an
uninhabited place. Romeo S. Galang Jr. also told me that he saw
the accused with her lady friend and two men ride the motor
vehicle parked at the left side of FEMII building; I have a copy
of the sworn statement of Romeo S. Galang Jr. dated December
7, 2015.

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(Request to have the Sworn Statement of Romeo S, Galang Jr. be
marked as Exhibit “F” for the Prosecution.)

Q21: What happened next, if any?


A21: On November 4, 2015, I went to the Eastern Police District of
Marikina City and report the said incident. I have a copy of the
Police Report dated November 4, 2015.

(Request to have the Police Report of Eastern Police District be


marked as Exhibit “G” for the Prosecution.)

Q22: What happened next, if any?


Q22: On November 26, 2015, my legal counsel sent a demand letter to
the accused, Analiza S. Uy for the immediate return of the
motor vehicle. I have a copy the said letter with its Official
Receipt and Registry Receipt.

(Request to have the Demand Letter dated November 25, 2015 be


marked as Exhibit “H” for the Prosecution.)

Q23: What happened next, if any?


A23: As the accused still refuses to return the subject vehicle, I
already filed this case for Carnapping.

AFFIANT FURTHER SAYETH NAUGHT

City of Marikina 2 October 2017.

_______________________
CHARLES K. HALEY
Affiant

SUBSCRIBED AND SWORN TO before me, a Notary Public


at the above jurisdiction, this day of ___________________, affiant
exhibited to me competent evidence of his identity, particularly his
__________________ with No._________________.

Doc. No. ______;


Page No. ______;
Book No. ______;
Series of 2017.
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REPUBLIC OF THE PHILIPPINES)
CITY OF MARIKINA ) S.S.

ATTESTATION

I, Atty. SHERWIN C. FERRER, of legal age, Filipino and with


office address at CU01A Alicante Tower, Marquinton Residences,
Sumulong Hi-Way corner Toyota Avenue, Brgy. Sto. Niño, Marikina
City, attest under oath as follows:

1. I personally conducted the interrogation of Charles K. Haley at


CU01A Alicante Tower, Marquinton Residences, Sumulong Hi-
Way corner Toyota Avenue, Brgy. Sto. Niño, Marikina City.

2. I faithfully recorded the questions I asked Mr. Haley and the


corresponding answers he gave me; and

3. Neither I nor any person then present coached Mr. Haley


regarding his answers.

______________________
_
SHERWIN C. FERRER

SUBSCRIBED AND SWORN TO before me, a Notary Public


at the above jurisdiction, this day of ___________________, affiant
exhibited to me his IBP I.D. with No. 59320 as competent proof of his
identity

Doc. No. __________;


Page No. __________;
Book No. __________;
Series of 2017.

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