REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
CITY OF ILOILO

MARIA A. OLA
Complainant,

- versus -

Complaint for: Violation of R.A 9262

Violence Against Women and their
Children

JON B. SNOW
Respondent.

x-------------------------------x

COUNTER – AFFIDAVIT

I, JON B. SNOW, single, of legal age, Filipino, with residence at 56

Arguelles St., Jaro, Iloilo City, after having been duly sworn in

accordance with law, hereby depose and state: THAT

1. I am the same person who is the respondent in the instant

case;

2. Paragraphs 2, 3, 4, and 5 of the affidavit of Maria A. Ola are

ADMITTED.
3. As regards paragraphs 6 and 7, the truth is: I became really

depressed after being terminated from my job but it is not true

that I get mad to her and our children easily. In fact, since I was

always at home, I had more time bonding with my children.

4. Paragraph 8 is DENIED. Although it is true that I became more

stressed because of unpaid billings, I never cursed in front of

my common-law wife and I never cursed her.

5. Paragraphs 9, 10 13, and 14 are DENIED. I never hurt the

complainant. During those though times, we were always

fighting but I never laid my hands on my wife.

6. As regards paragraph 13, the truth of the matter are as follows:

On November 2, 2015, it was complainant’s first day of work.

She previously informed me that her shift was from 8:00am to

5:00pm. It was already 6:00pm and she has not arrived home

yet. I tried calling her several times but she did not answer. I

was worried about her so I decided to call some college friends

over. The complainant arrived around 11:00pm. During that

time, I was having a few drinks with my college friends. I

noticed that she was driven home by a guy with a car. When we

entered our house, I asked her who that guy was. She shouted

at me and said, “Wala ka na do’n! Sawang-sawa na ako sa ‘yo!

 Ako pa ang kailangang magtrabaho para sa atin! Mabuti pa ang

ibang lalake dyan! Wala kang kwenta!” Enraged, I threw her

bag and some papers on the table in our living room. She also

started throwing her things to me. My friends and children

approached us and tried to stop us. As a result of the

commotion, our son, Alden, fell on the ground and was slightly

hurt.

7. Paragraph 14 is DENIED. I never had a confrontation with the

complainant’s mother.

8. Paragraph 15 is DENIED. The truth of the matter are as follows:

I was watching my son and our neighbor’s son play outside

when I heard my son said, “Gago ka! Madaya!” I apprehended

my son right at that very moment. I admonished him and told

him that he should not be saying bad words. However, I never

hit my son.

9. The filing of the complaint is the complainant’s way of leaving

me because she intends to be with his paramour already. I

have been noticing that since she started applying for a job,

there has been always someone who drops her off a few blocks

away from our house. Also, she always gets calls and text

messages late in the evening. And on the day the complainant

 left me, she told me that she deserves someone better than

me, like his co-worker.

IN WITNESS WHEREOF, I have hereunto affixed my signature

this 11th day of March 2020 in the City of Iloilo, Philippines

JON B. SNOW

Respondent/ Affiant

_______________________________________________________

SUBSCRIBED AND SWORN TO before me this March 11, 2020 in

the City of Iloilo, Philippines.

ATTY. GRACE Y. PHAR

Associate City Prosecutor