REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

11th Judicial Region
Branch 24
Hall of Justice
Koronadal City, South Cotabato

PEOPLE OF THE PHILIPPINES

CRIM. CASE NO. 8321-24

Plaintiff,
-

versus

-for-

ANTHONY REGONIEL DELOS SANTOS

VIOLATION OF SECTION 5

And LETECIA DEQUILLO KONG

of ARTICLE 2 of RA 9165

Accused.
x---------------------------------------------x
JUDICIAL AFFIDAVIT
(Rule on Judicial Affidavit,
A.M. No. 12-8-8-12, September 4, 2012)

I.

PRELIMINARY INFORMATION.
A.

NAME AND OTHER PERSONAL CIRCUMSTANCES OF THE

Name
:
Age
:
Address
:
Occupation :
Language
:

PO2 Jerome G. Serrano

40 years old
Brgy. San Isidro, General Santos City
Police Officer
English, Tagalog and Bisaya

WITNESS.

B.

LAWYER WHO CONDUCTED OR SUPERVISED THE EXAMINATION OF

THE WITNESS.

II.

Name

Prosecutor KAY AVILES

Address

OFFICE OF THE PROVINCIAL PROSECUTOR

Koronadal City

Place of Examination:

OFFICE OF THE PROVINCIAL PROSECUTOR

Koronadal City

OFFER.
The witness will testify on the arrest made to accused Anthony Regoniel Delos Santos and
Leticia Dequillo Kong for having possessed and traded illegal drugs. The testimony of

PO2

Serrano is being offered to prove the folllowing:

1. That he is a member of the Philippine National Police by profession;
2. That he will testify as one of the witnesses of the Prosecution;
3. That he is presently assigned at Regional Special Investigation and Detection Team,
Regional Investigation and Detective Management Division, PRO12, Tambler,
General Santos City;
4. That he is a member of the team who effected the arrest of the accused;
5. That he is the Poseur Buyer in the operation;
6. And to prove such relevant matters.

III.

JUDICIAL AFFIDAVIT PROPER.

I, PO2 Jerome G. Serrano, 40 years old, married, Filipino, and residing at Brgy. San Isidro,
General Santos City, under oath, depose:
2

1.

Q Please state your name, age, residence, and occupation.

A I am PO2 Jerome G. Serrano, 40 years old, single, Filipino, and residing at
Brgy. San Isidro, General Santos City and a Police Officer.

2.

Q- Why are you here now?

A To give a sworn statement in the above-captioned criminal case.
3.

Q-

For the record, please state the name and address of the Prosecutor who is

now conducting

or supervising your examination

and

the

place

where

the

examination is being held now?

A Prosecutor Kay Aviles is conducting or supervising my examination now at
her office at the Office of the Provincial Prosecutor, Koronadal City.
4.

Q In what language do you want your examination to be conducted?

A This judicial affidavit is prepared in English. But I prefer that my cross
examination be conducted in Tagalog for my convenience and for clarity.
5.

Q Do you undertake to answer the questions to be asked of you, fully conscious

that you will do so under oath, and that you may face criminal liability for false testimony
or perjury?
A -Yes.
6.

Let us now proceed. Mr. Witness, what is your profession?

A - I am a bona fide member of the Philippine National Police.

7.

Q
A -

8.

What is your rank as member of the PNP?

PO2, Maam.

Q How long have you been in the service as police officer?

A - I have been in service for almost 16 years, Maam.

9.

Where are you designated, Mr. Witness?

A - I am currently designated at the Regional Special Investigation and Detection

Team, Regional Investigation and Detective Management Division, PRO12.
10.
and

Since when have you been a member of the Regional Special Investigation

Detection Team, Regional Investigation and Detective Management Division,

PRO12?
A 11.

Since 2000, Maam.

Q What were you doing on the 16th day of October 2012?

A I was on duty, Maam.

12.

13.

What task were you assigned on that day?

I was tasked to be the Poseur Buyer on the planned buy-bust operation.

Q How did you plan your buy-bust operation?

A - SPO1 Lanaza received an information from our Confidential Informant (CI)
from Koronadal City that he had closed a transaction on the delivery of illegal
drugs particularly, shabu.
4

14.

What were the names of the supposed sellers from whom the Confidential

Informant is supposed to buy shabu?

A - Alias Tony and alias Letty, Maam.
15.

Q Where did you conduct the buy-bust operation?

A At Upper Balmores, Barangay General Paulino Santos, Koronadal City.

16.

Q How were you informed of your tasking?

A After SPO1 Lanaza informed PCI Maximo F. Sebastian Jr., PCI Sebastian
conducted a briefing and gave a task to each member of the team.

17.

Q What were the tasks given?

A I was tasked to be the Poseur Buy, and SPO1 Lanaza as the Arresting Officer.

18.

Q Can you tell us the specific tasks of a Poseur Buyer in a buy-bust

operation?

A In a buy-bust operation, a police officer is designated to pretend to be a

civilian buyer of dangerous drugs for purposes of effecting the arrest of the
offender.

19.

Q And then, what happened after the briefing and tasking?

A - PCI Sebastian gave me a P1,000.00 bill marked money bearing serial
number HM931309 for the buy-bust operation and I marked it away with my
signature. A photograph of the process of me signing the P1, 000 was also taken.
5

20.

Q I have here a photocopy of a P1000.00 marked bill, I am showing this to you

now. Is this the one?
A - Yes, maam. Thats the one.

21.

Q Alright, I will mark this document as Exhibit _ and attach it to your judicial
affidavit. Do you confirm my action?
A Yes, maam. I confirm your action.

22.

Q Moving on. What happened next?

A On the same date, at about 8:35AM, we coordinated with the office of
Philippine Drug Enforcement Agency, Regional Office-12.

23.

Q What time did you arrive in Koronadal City?

A We arrived at around 1:30 PM of that date, Maam.

24.

Q Who were you with?

A The rest of the team, Maam, and Police Senior Inspector Alex Joe Orcajada
was our team leader.

25.

Q Are there other personnel aside from your team?

A - PSI Orcajada immediately called up Koronadal City Police Station for
coordination, while we met with our Confidential Informant and planned for a
buy-bust operation.

26.

Q And then?
A The entire team with our Confidential Informant proceeded to Upper
Balmores, Barangay General Paulino Santos, Koronadal City.

27.

Q What did you do when you arrive at the place?

A - We waited for the arrival of alias Tony and alias Letty beside the road,
while the rest of the team were just nearby strategically positioned in order not to
be detected by the subject persons.

28.

Q What time did the subject persons arrive at the agreed meeting place?
A - At around 2:15 PM of that date, Maam. They were riding on a black STX
Yamaha motorcycle.

29.

Q How did you know that those persons were the ones you were expecting?
A - Our Confidential Informant positively identified them, Maam and the
people in the motorcycle, Maam, were a male and a female, and they
approached us. I was with our arresting officer, SPO1 Lanaza.

30.

Q And then what happened?

A - Our Confidential Informant introduced us to Alias Tony and alias Letty.

31.

Q Were you able to know the real names of these Alias Tony and Alias
Letty?
A Yes maam. Alias Tony was later identified as Anthony Regoniel Delos
Santos, while Alias Betty was later identified as Leticia Dequillo Kong.
7

32.

Q If you would be asked in the court to identify the accused, would you be able
to identify them?
A - Yes, Maam. Photographs of them were also taken after the arrest, Maam.

33.

Q I will show you two documents containing a photocopy of photos of a male

and a female. Are they the accused Anthony Regoniel De los Santos alias Tony
and Leticia Dequillo Kong alias Letty?
A Yes, they are Anthony Regioniel De los Santos and Leticia Dequillo Kong
maam.

34.

Q I will mark these documents as Exhibit __ and Exhibit __ and attached

these two documents to your judicial affidavit. Do you confirm my action?
A Yes, maam. I confirm your action.

35.

Q So after the introduction, what happened next?

A - Alias Tony asked me how much shabu I would buy. Then I replied that it
would be worth P1,000.00.

36.

Q And then?
A - It was Alias Letty who handed to Tony a small item, which Tony gave to
me.

37.

Q Would you please describe that small item that he gave to you ?

A - It was a heat-sealed transparent plastic sachet containing white crystalline

substance which I believed then as a shabu.
38.

Q Was it the same item that you later marked as JS-1?

A - Yes, Maam.

39.

Q So, what happened next after Tony handed the shabu to you?
A I paid Tony with the P1,000.00 bill marked money.

40.

Q Is that the same marked P1,000.00 bill a photocopy of which I showed to

you earlier?
A Yes, maam. It is the same bill and the same photocopy you showed earlier.

41.

Q Alright. So after payment, what happened?

A We then introduced ourselves as police officers to Tony and Letty and
arrested them.

42.

Q Kindly describe the procedure of the arrest.

A - Upon arrest, we appraised the accused of their constitutional rights under the
law in a dialect known and understood by them.

43.

Q What else did you do?

A- While frisking the possession and control of Tony, Maam, I was able to
seized another heat sealed transparent plastic sachet containing white
crystalline substance which I believed then as shabu.
9

44.

Q Were you able to mark the second heat-sealed transparent plastic sachet that
you seized?
A Yes, maam. I marked it as JS-2 upon arrival at Koronadal Police Station
in Koronadal City, maam.

45.

Q What happened next?

A During the arrest, Maam, we saw Letty surreptitiously drop a small item on
the ground which SPO1 Lanaza immediately picked up maam.

46.

Q Was it also marked?

A I believed SPO1 Lanaza was able to mark it at Koronadal Police Station.

47.

Q Moving on, what did you do after the apprehension?

A In order to avoid leakage to our next operations, we immediately brought the
arrested suspects and the seized items to Koronadal Police Station in Koronadal
City for the marking and inventory.

48.

Q Who were present during the inventory?

A The inventory and marking of the items seized from Anthony Regoniel Delos
Santos was made by me in the presence of Jerwen Paglinawan of Brigada News
and Brgy. Kag. Albert Piato.

49.

Q Where were the accused during the inventory?

A The two arrested suspects were also present during the inventory.
10

50.

Q How did you mark the seized items?

A I marked one piece of heat-sealed sachet containing white crystalline
substance as SJ-1 and the other heat-sealed sachet containing also white
crystalline substance as SJ-2.

51.

Q What else did you mark and include in the Inventory Receipt?
A I also included one unit of black Nokia cellular phone model N8860 which
is labeled as JS-3, the P1000.00 bill with serial number HM931309 with my
signature that I used during the buy-bust operation and marked as JS-3, a
motorcycle key and also one unit of STX motorcycle.

52.

Q Were you the one who wrote on the Inventory Receipt?

A Yes, I was the one.

53.

Q I am showing you a photograph of Jerwen Paglinawan of Brigada News and

Brgy. Kag. Albert Piato as well as the two arrested suspects. Is this the inventory
and marking process you mentioned?
A Yes maam. That is a photocopy of the photograph taken during the
inventory and marking process.

54.

Q Do you signify the authenticity of this photograph?

A Yes, Maam.

55.

Q I will mark this document as Exhibit __ and attach the same to your
affidavit. Do you confirm my action?

11

A Yes, maam. I confirm your action.

56.

Q So what happened after your inventory?

A After I finished my inventory and marking, SPO1 Lanaza also complied with
the inventory and marking of the evidence he seized from Letecia Dequillo Kong
alias Letty.

57.

Q I have here a copy of the Inventory Receipt of Confiscated/ Recovered Items

you executed as the Poseur Buyer. Please go over this document and please tell
me if it is the same Inventory Receipt of Confiscated/ Recovered Items you were
referring to.

58.

Q Yes, maam. This is the same Inventory Receipt of Confiscated/Recovered

Items that I filled up.

59.

Q Is that your signature below?

A Yes, Maam.

60.

Q Alright. I will mark this document as Exhibit __ and attach the same to
your judicial affidavit. Do you confirm my action?
A Yes, maam. I confirm your action.

61.

Q What were those items contained on the said Inventory Receipt?

A The items were two heat-sealed transparent plastic sachet containing white
crystalline substance believed to be shabu, which were later marked as JS-1
and JS-2, one unit black Nokia Cellphone model N8860, marked as JS-3;
one P1,000.00 bill marked money bearing serial number HM931309 with my

12

signature and one (1) unit black STX Yamaha motorcycle bearing plate number
XK 7194 with attached gray sidecar, and a motorcycle key.
62.

Q- I have here the certification you executed that the P1,000.00 recovered from
Alias Tony was the same marked money with serial number HM931309 and
contains your signature. Please go over this document and please tell me if it is
the same Certification that you were referring to.
A Yes this is the same Certification I executed, maam.

63.

Q Is that your signature at the bottom?

B- Yes, Maam.

64.

Q I will mark this document as Exhibit __ and attach the same to your
judicial affidavit. Do you confirm my action?
A Yes, maam. I confirm your action.

65.

Q What did you do after the inventory and the marking of pieces of evidence?
A We traveled back to General Santos City with the arrested suspects and
brought them to Camp Lira, Jr. in General Santos City for booking and further
documentation. The two apprehended suspects, Alias Tony and Alias Letty were
also subjected to medical examination at the PNP Regional Crime Laboratory
Office-12, General Santos City.

66.

Q What happened to the seized, marked and inventoried items?

13

A The three heat-sealed sachets containing white crystalline substance were

forwarded to PNP Regional Crime Laboratory Office-12 at Camp Lira in General
Santos City for analysis, particularly, the ones marked as JS-1 and JS-2.
67.

Q Who forwarded those seized items marked as JS-1 and JS-2

A I did, maam.

68.

Q Would you tell me the process?

A I and SPO1 Lanaza went to the Crime Laboratory.

69.

Q And upon arrival at the Crime Laboratory, what did you do?
A I approached Mr. Roy Albert Pundogar.

70.

Q Who is Mr. Roy Albert Pundogar?

A He has the charge of the Crime Laboratory and he is the custodian of the
items I turned over, particularly JS-1 and JS-2.

71.

Q So, what did you do after you approach Mr. Pundogar?

A I told him I will turn over to him two heat-sealed sachets containing white
crystalline substance which I believed to be shabu and which I got from the
buy-bust operations conducted earlier on that day for laboratory examination.

72.

Q Around what time was it already when you reached the Crime Laboratory?
A Around 11:35 in the evening, maam of October 16, 2012.

14

73.

Q What happened after you told him that you will turn over some seized items
for laboratory examination?
A He gave me a Chain of Custody Report.

74.

Q What did you do with the form?

A Before I turned over the two sachets identified as JS-1 and JS-2, I filled
out a Chain of Custody Report.

75.

Q What is that?
A It is a document where we record the details of substances, which we turn
over to them for purposes of laboratory examination.

76.

Q Did you sign on this Chain of Custody Report?

A Yes, maam.

77.

Q Did Mr. Pundogar also sign?

A Yes, I saw him signed, too.

78.

Q I am showing you a document with a caption CHAIN OF CUSTODY,

kindly go over this document and tell me whether this is the same Chain of
Custody Report that you earlier described.
A Yes, maam. This is the same Chain of Custody Report that I filled out.

79.

Q Is that your signature below your name?

A Yes, maam. This is my signature.
15

80.

Q Alright, I will mark this document as Exhibit __ and attach the same to
your judicial affidavit to form an integral part thereof. Do you confirm my
action?
A Yes, I confirm your action, maam.

81.

Q Have you executed a Joint Affidavit as Apprehending Officer with SPO1

Lanaza for the purpose of filing this criminal case?
A Yes, Maam.

82.

Q I have here a copy of the Joint Affidavit you executed with SPO1 Lanaza,
you, as the poseur buyer. Please go over this document and please tell me
whether that it is the same Joint Affidavit you executed with SPO1 Lanaza.
A Yes maam. This is the same Joint Affidavit.

83.

Q Is that your signature below?

A Yes, Maam. This is my signature.mj jvum
P02 Jerome G. Serrano
AffianT

SUBSCRIBED AND SWORN to before me, this 21st day of October 2012, affiant
exhibited to me his competent evidence of identity with the details shown above. I hereby certify
that I personally examined him and I am fully convinced that he has personally read and
understood the foregoing judicial affidavit and the allegations therein.

16

KAY PELAYO AVILES

Prosecutor
.

17