Republic of the Philippines )

Province of Agusan del Sur ) S.s

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COUNTER-AFFIDAVIT

I, JOSE "TOTONG" OSOK, of legal age, Filipino, and resident of Poblacion, San Luis,
Agusan del Sur, after having been duly sworn to in accordance with law do hereby depose
and state:

1. That I am the same persons charged under NPS. No. 13-03-INV-16A-030 for
"GRAVE THREATS" filed by complainant JUNDRIL N. VERANO on January 20, 2016 at the
Provincial Prosecution Office, Patin-ay, Prosperisdad Agusan del Sur.

Background
2. That I am a Manobo native and lived in the subject area since birth, and known
the place very well. And the place have been part of ancestral domain of our ancestors since
time immemorial, where they hunt animals for food and cultivate for farming.

3. That the API rented from API-AGRARIAN REFORM BENEFICIARIES MULTI

COOPERATIVE, INC. (APIARBI COOP for brevity) around one thousand four hundred twenty
seven hectares (1427 ha.) with no specific address of coverage.

4. A cursory reading of the original Lease Agreement bet APIARBI COOP and API,
nothing in the said agreement which provided the details as to what lots or certificate of
title subject of lease.

5. That they themselves could not identify the exact locations of the metes and
bounds of the rented place, and for a long time they have been indiscriminately planting
areas in large breadth amounting two thousand hectares (2000 ha) more or less.

6. The complainant's attached Original Certificate of Title is addressed in Manat,

Trento, Agusan del Sur. However, the place of incident occured in Tudela, Trento, Agusan
del Sur. This supports our argument that they do not know the coverage of their lease
agreement.
Narration of Events

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Counter Affidavit of JOSE "TOTONG" OSOKNo. 13-03-INV-16A-030 for "GRAVE THREATS".
 7. That on December 8, 2015, I have seen from a distance MINDANIO "DANAO"
MIQUE, LINDEY "LOLOK" MIQUE ROLDAN "ABEL" BORANTES standing in the road with
Erpie Mancawan-Chief Security of API, complainant JUNDRIL N. VERANO, and 7 SCAA
bearing arms and more than thirty (30) weed-workers bearing Lagarao nearby.

8. When I sensed that they have discussion on serious matter, I approached the two
groups because I want to know what it is all about.

9. Complainant JUNDRIL N. VERANO requested me to submit proposal, which I have

no idea what he is referring to. Later, I can deduced from the statement that he means a
proposal about what we want to demand with the API. And I told him "paabot lang sir kay
amo pa ning plastaron" (Just wait sir, because we ha have to place this in order).

10. That after such date of events, I have received a summon from the barangay and
later on received subpoena.

11. I was surprised when my name is included among those who were charged with
"grave threats"

12. That I have no participation in such incident whatsoever.

Prayer
That I am executing this counter affidavit to attest to the truth of the foregoing
statement and to pray for the dismissal of the complaint filed against me.

I WITNESS WHEREOF, we herby affix our signatures this ____________________ in

____________Agusan del Sur, Philippines.

JOSE "TOTONG" OSOK

Affiant

SUBSCRIBED and sworn to before me on June____________, 2015 in

_____________________ Agusan del Sur.

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Counter Affidavit of JOSE "TOTONG" OSOKNo. 13-03-INV-16A-030 for "GRAVE THREATS".