REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL REGION
Manila, Philippines
Branch 44

PEOPLE OF THE PHILIPPINES

Complainant,

-versus- Criminal Case No. 587-V-96

FOR: Murder

JOHN LESTER A. TAN

Respondent.
x------------------------------------x

REPUBLIC OF THE PHILIPPINES)

CITY OF MANILA ) S.S.

COUNTER-AFFIDAVIT COMPLAINT

I, JOHN LESTER TAN, 27 years old, single, and resident of Block 40, San Sebastian
Street, Quiapo, Manila City, after having been duly sworn to in accordance with law hereby
deposes and says THAT:

1. I was charged by TRIXIE QUESTA TAGABALERA for the crime of MURDER

under Article 248 of the Revised Penal Code;

2. I vehemently denies all the allegations that she have stated on her Affidavit-Complaint;

3. On July 18, 2017, on or about 7:00pm, I was invited by Trixie Tagabalera to celebrate
th
her 25 birthday in her house.

4. It was 9:00pm when I left Trixie’s house since I need to attend another drinking session
with my friend Glenn Butardo.

5. Due to the above-mentioned circumstances, it was impossible for me to commit the

acts of kissing Trixie and starting a fist fight with his husband Rey Tagabalera.

6. Further, Rey and I were best friends for we worked together as Construction Workers
in Torre De Manila Condominium. I treated him as my brother. There came a time when he
needed money so badly and I insisted to lend him. Thus, I had no motive and intent to kill him.

7. On July 19, 2017, on or about 9:30pm, I saw Rey Tagabalera walking in an alley when
I saw two (2) persons who both were wearing black jackets and a mask, following him with a
knife on their hands. I followed Rey and the two persons. Alarmed, I shouted at Rey who saw the
two persons tried to stab him. Rey was able to escape from the first attempt. However, the other
person stab him in the stomach. I punched the one who stab Rey, but they outnumbered me and
they started to run. I quickly ran and followed the two persons hoping to catch them or at least
one of them.

8. However, I failed to catch the two persons. I quickly ran to the crime scene and tried to
help my best friend Rey but he was not there anymore. I went to my house to get a first aid due
to the injuries I sustained when one of the two persons punched me.
 9. At about 10:00pm, I went to Rey’s house and saw his wife, Trixie crying because Rey
was already dead. This was the time when Trixie accused me that I killed Rey and stated that a
certain witness saw me killed Rey.

10. In addition, the store vendor that told Trixie that I had intent to kill my best friend
Rey was inadmissible. The store vendor had a grudge on me since I was not able to pay my debt
to that vendor which amounted to P1,500.00. In that way, the store vendor could put also a
vengeance for me to get convict for killing Rey and for my unpaid debt.

IN WITNESS WHEREOF, I have hereunto set my hand this 20 th day of July 2017 at
Quiapo, Manila, Philippines.

JOHN LESTER TAN

Affiant

SUBSCRIBED AND SWORN to before me this 20th day of July 2017, at Quiapo, Manila,
Philippines with Driver’s License No. G03-03-000864 issued on March 15, 2010 at LTO-Manila
and I hereby certify that I have examined the herein affiant and I am fully convinced and
satisfied that he voluntarily executed the affidavit in his own free will and volition and that he
understood all the contents of the same.

Doc. No. 283;

Page No. 56;
Book No. XXXVII;
Series of 2017.

ATTY. AL MAYO PAGLINAWAN

Notary Public
Until December 31, 2017
PTR No. 856842
Issued on January 7, 2011/Manila City
Roll of Attorney No. 23789
IBP Receipt No. 2345
Issued on January 8, 2011/Manila City
MCLE Compliance No. 3428-1235824

CC: Atty. Tin Cayabyab

Counsel for the Complainant