February 1, 2017

THE HONORABLE CITY PROSECUTOR

Office of the Bacolod City Prosecutor
Bacolod City, Neg. Occ.

RE: COUNTER AFFIDAVIT FOR LIBEL I.S. NO. 1-2017

SIR:

The undersigned counsel respectfully submits the hereto attached

Counter-Affidavit of Respondents MANUEL BOY MEJORADA,
ROMMEL S. YNION and JUNEP OCAMPO pertaining to the criminal
complaint filed against them for LIBEL by the complainant JED
PATRICK E. MABILOG.

We respectfully request that aside from considering the counter-

affidavit of the respondent, your office shall also set a clarificatory
hearing by the parties in order to personally assess the credibility of
their statements and possibly determine whose version of the story is
the truth.

Thank you very much for your usual kind accommodation on the
matter!

Very Truly Yours,

ATTY. MARY ANNE CANETE

Counsel for the Respondents

6100 La Salle Avenue, Bacolod City

Telephone No. (034) 123-4567

COPY FURNISHED:

ATTY. JUAN DE LA CRUZ

Counsel for Private Complainant
Rm. 96 Habal Habal Bldg, Bacolod City.
Republic of the Philippines)
Bacolod City ) S.c.
x------------------------------------x

COUNTER-AFFIDAVIT

We, MANUEL BOY MEJORADA, ROMMEL S. YNION and

JUNEP OCAMPO, all of legal age, Filipino citizens and with business
office address at 2nd Floor, Baquillos Arcade, 24th Calamba Street,
Brgy. Banago, Bacolod City, Philippines, after having been sworn in
accordance with law do hereby depose and say:

1) That we are the respondents in I.S. Case No. 1-2017 filed

against us by the herein complainant Jed Patrick E. Mabilog on the
charge of Libel.

2) That we vehemently deny the material averments stated in

the Complaint-Affidavit dated 20 January 2017 as the same are
unwarranted conclusions of facts and pure machinations intended to
harass us;

3) That the truth of the matter is hereunder set forth to wit:

4) That I (Respondent Mejorada) based my article on facts and

written and published in consonance with my duty as a journalist to expose the truth, and
comment on it, no matter how harsh, about the character and behavior of public officials,
untainted by malice or intent to libel complainant herein.

5) That we did not maliciously impute any dishonor or discredit

to the person of complainant herein;

6) That we therefore deny to have published or caused to

publish any malicious imputation against complainants;

7) That the article was written in good faith and in pursuit of the
public good;

8) That the document allegedly containing the defamatory

imputations, in fact and in truth, does not contain defamatory matters
that can be considered libelous. Being so, the Complaint-Affidavit
failed miserably to ALLEGE, MUCH LESS ESTABLISH, that the
alleged defamatory imputations in The News Today, Opinion Section
page 5 (Vol. 12 No. 50) can be considered libelous;
 9) That we are executing this affidavit in order to attest to all the
foregoing facts and for whatever legal purpose it may best serve.

Given the above arguments, it is apparent the instant

complaint, as well as the evidences attached thereto, is not sufficient
to engender a well-founded belief that an offense has been
committed. There is no probable cause to hold us liable for LIBEL as
defined in the Revised Penal Code. Thus, the present complaint
SHOULD BE DISMISSED FOR UTTER LACK OF MERIT.

Affiants sayeth naught.

MANUEL MEJORADA ROMMEL S.YNION

Affiant Affiant

JUNEP OCAMPO
Affiant

SUBSCRIBED AND SWORN to before me this ____ day of

February 2017 at Bacolod City, Neg. Occ. I hereby certify that I have
personally examined the respondents and I am satisfied that they
understood and voluntarily executed their counter-affidavit.

ASST. CITY PROS. RE CHARLES P. TUPAS

Investigating Prosecutor
Doc. No. ______;
Page No. ______;
Book No. ______;
Series of 2017.