Republic of the Philippines.

)
Province of Zamboanga del Norte) S.S.
City of Dipolog )
x----------------------------x

This Joint Counter - Judicial Affidavit of PRINCESS LAILA

TRONO and MARK ANGELO OMALIN is executed and prepared
by Atty. Mark Jasper G. Cielo who conducted his examination at the
latter’s law office at Bagarinao Bldg., Barra, Dipolog City.

The witnesses are answering the questions asked of them, fully

conscious that they does so under oath and that they may face
criminal liability for false testimony or perjury.

Furthermore, the witness was asked the and consequently

answered the questions herein in a language known to them –
English.

JOINT JUDICIAL AFFIDAVIT

The UNDERSIGNED, PRINCESS LAILA TRONO and MARK
ANGELO OMALIN, who are both of legal age, single, and are
residents of the Mun. of Kabasalan, Zamboanga Sibugay after having
been duly sworn to in accordance with law, hereby depose and state:

1. Q: Why have both of you come to my office?

A (Both): We came to your office to ask for your assistance in
answering the allegations of a certain Gloria Trono which was
filed before the most esteemed 3rd MCTC of Kabasalan-Siay, for
Forcible Entry docketed as Civil Case No. 389-K.

2. Q: How do you know each other?

A (Princess): Mark Angelo Omalin (Mark, for brevity) and I are
a couple and are living together.

3. Q: How do you know the complainant and their witnesses?

A (Princess): I only know her by name. My father, Peter L.
Trono (who is currently residing in the State of Alaska in the
United Stated of America) actually informed me that this
woman used to be his paramour.

A (Both): As to the other witnesses, they are strangers to both of

us.
4. Q: In the Complaint of Gloria, she claims, among other things,
that you entered her property found in Brgy. F.L. Pena,
Kabasalan, Zamboanga Sibugay.

A (Both): When we entered possession of the property it was

based on the premise that Princess has ownership over the
property, being the daughter of owner Peter Trono.

Our father who actually owns the property informed us, his
descendants, that it was his property and not Gloria’s. Hence,
we had a well-founded belief that the property is in fact ours.

This is exactly why we even initiated barangay proceedings

before the alleged dates of entry, because we wanted to meet
this Gloria person face to face and avoid any mess and to
respect the apparent agency of Gloria.

5. Q: If you believed the property to be your fathers, why would

you go through the effort of meeting with Gloria before the
barangay?
A (both): It is because, as far as we are concerned, Gloria was
my father’s agent, and she might have pertinent information
about the property – we had no idea she would claim
ownership of the property since, everyone we knew, and even
the boarders therein believe that the property was Peter
Trono’s, and that Gloria was just his agent in collecting rentals.
No one believed Gloria was the owner.

But then, Gloria could not be contacted. In fact, when we tried

to mail the address that we had of hers, the courier was given
an “Return to Sender” notice – clearly, either Gloria could not
be found, or, she is avoiding me, either way, it proves my point
that Gloria, could not be contacted.

Hence, the most reasonable avenue we saw was compulsory

processes before the Baranggay.

6. Q: Were you successful in contacting her through the

Baranggay?
A: Not at all. She failed to meet with us before the barangay.

7. Q: With this failure of Gloria to meet with you, what course of

action(s) did you take?
A(both): It is clear that prior to the complaint filed by Gloria,
 we have, in good faith, made an effort to reach out to her to
settle the issue of ownership over the property.

Our father, having informed us the true circumstances of the

property, urged us, through my mother Joy Duga to file a case
to retrieve the property.

Manifestation: Your honor, we wish to attach as our Annex “1” (and

all its annexes numbered Annex 1-with submarkings). This
document is already part of our records as an attachment to
the Answer submitted by us defendants which is the Complaint
for Annulment of Title, Deed of Sale and other Documents, filed
before the Regional Trial Court in Mun. of Ipil, Zamboanga Sibugay,
on December 4, 2019 Because much later, we found out that somehow
Gloria fraudulently acquired title over the property.

8. Q: There is however this Ulysses Isidro Atilano and Edlio Luab

who executed affidavit stating that you actually were found
inside the room of Gloria.
A (Both): First, we never had this encounter. I have never seen
the Ulysses Atilano whose picture they attached to the
complaint. Edlio Luab, also we encountered only at the Police
Station.

9. Q: What would like to happen now?

A: I humbly pray that this complaint she filed against us, be
dismissed for utter lack of merit.

10.Q: What else would you like to add?

A (Princess): To prove my mother is married to my father, I am
attaching their marriage license as Annex “2” and to prove my
relationship with my father, I would like to attach as my Annex
“3” my birth certificate.

11.Q: How did you acquire the information you shared to me?
A (Both): We acquired these through and by our own senses,
hence these are based purely off our own personal knowledge.

12.Q: Were your consents vitiated in any way or manner to

execute this affidavit?
A (Both): Of course not. We are executing this affidavit our of
our own free will and volition; we were neither forced nor
bribed to execute this document.
 13.Q: Are you willing to affirm, through signing, the due
execution of this affidavit which is composed of four (4) pages?
A (Both): Yes. We are very willing to affirm the due execution of
this affidavit made of four (4) pages.

---------END OF STATEMENT----------

IN WITNESS WHEREOF, I hereunto set my hand below this ____

day of __________at Dipolog City, Philippines.

PRINCESS LAILA TRONO MARK ANGELO OMALIN

Affiant Affiant

SUBSCRIBED AND SWORN to before me this ____ day of

__________at Dipolog City, Philippines.
Doc. No. __
Page No. __
Book No. __
Series of 2019.

ATTESTATION

I, MARK JASPER G. CIELO, of legal age, Filipino, single and

with office address at Bagarinao Bldg., Barra, Dipolog City, do
hereby certify that:

I have faithfully recorded the questions asked of the witness

PRINCESS LAILA TRONO and MARK ANGELO OMALIN and
the corresponding answers given; and neither I nor any other person
then present and assisting him coached the complainant regarding
the latter’s answers.

IN WITNESS WHEREOF, I have affixed my signature this

_______________ at Dipolog City.

MARK JASPER G. CIELO

Roll of Attorneys No. 70852; 6-05-18
PTR Or No. 7740774; 1-06-20
IBP Or No. 096450; 12-04-19 (for 2020)

SUBSCRIBED AND SWORN to before me this ____ day of

___________, 2019 at ___________________________. Further, I certify
that I personally examined the herein affiant that he voluntarily
executed and fully understood his statements.
Doc. No. __
Page No. __
Book No. __
Series of 2019.