Republic of the Philippines )

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COUNTER-AFFIDAVIT
1. I am the Respondent for Acts of Lasciviousness in relation to R.A. 7610, now
pending before the City Prosecutor of

2. I deny all the imputations of wrongdoing against me in the complaint for

being groundless and unmeritorious. I never had any sexual nor lewd
intentions against the complainants. Thus, I hereby pray for the dismissal
of the present complaint maliciously filed against me;

3. As can be perused from the Affidavit Complaint, the first alleged time where
I allegedly molest of 8:00 in the evening, where I allegedly grabbed and
dragged her to a dark and obscure portion of the church and made lewd acts
against her are all untrue. During that time, I was not in the church as I was
already at home since it is a Holy Thursday that time. I always go home
early as I have also responsibilities in our house;

4. As indicated in the complaint, I again repeat the lewd acts that I allegedly
committed on 30 March 2018 at 7:30 in the evening. These are all fallacious
and wrong because I always go home early. My usual working time in the
church is 7am then I go home at 11am. Then my time to go back to church
in the afternoon will vary every time I had work to finish at home. Then I
go home in the afternoon at 5:00pm;

5. Further, one of the complainant who who said that I allegedly embrace her
tight and carried her, her legs place on the sides of my waist and perform a
push and pull motion of “KIYOD-KIYOD” are all false. I did not do any such
acts. In fact, I was in my home on the said date and time as I was fixing an
electric fan and repairing shoes in our small shop as I was requested by my
brother to attend such work;

6. Furthermore, one of the complainant also imputed me on the same acts of

lewdness on 02 April 2018, when I allegedly called to come in the church
and I allegedly carried her abd frontally embraced her tight and sweetly told
her .Then I positioned my private part closed to the complainant private part
and performed a push and pull motion in a fast movement are all untruthful.
I never do any of such acts as these are all maliciously imputed to me. In
fact, during that day I was in the church and there was a program happening
at that time wherein there are too many people participated in that day. I
also repair the wall of the church that day and went home at 7pm;

7. The two complainants who and wherein according to their statements I

allegedly touched their private parts are all spurious and untrue. These
imputations against me are all sham and lies since I know the reason why I
was charged this kind of crime;

8. The truth is all of the complainants are all siblings and the one who assisted
them, their mother, is mad at me because I reprimanded her at the time I
discovered that their family is connecting electricity in the church to where
I was working. I also reprimanded them not to get water in the church since
they also get water without any permission. I also told my brother who is
also a member of the Church to where I work of what I discovered and there
my brother caution her about it;
 9. Since I was the one who reprimanded them on their anomalous acts and
intention to connect electricity and get water in the church, she was mad at
me and used her children to get even with me;

10.I strongly believe that this case filed against me is purposely to hurt me and
my family. I never and will never had have any lustful intent to molest a
child. Though I am not educated person, I know what is right and wrong
and all the statement of the complainant against me are all tainted with
malicious intent to cause pain in me and my family. In fact, one of our
neighbor told me, that her child was recruited by the mother of the
complainant purposely to file a case against me but our neighbor decline
because she knew the truth and that all statements against me are false;

11.Hence, there can be no probable cause to believe that I committed crime

filed against me;

12.I am executing this counter-affidavit to refute all the imputations of

wrongdoings against me, to inform the concerned authorities and this
Honorable Court of the foregoing facts and to attest to the truth thereof.

IN WITNESS WHEREOF, I have hereunto set my hand this

SUSCRIBED AND SWORN to before me this this I hereby certify that I have
examined the affiant personally and that I am satisfied that he voluntarily executed
this affidavit and understood the same.

Copy furnished: