Republic of The Philippines

Department Of Justice National Prosecution Service Office Of The City Prosecutor

Tuguegarao City
PEOPLE OF THE PHILIPPINES,
Plaintiff,
-versus-
JUAN SANTOS,
Accused.

IS NO.123456For:Rape

COUNTER-AFFIDAVIT
I, Bea Alfonso, Filipino, of legal age, and with residence Tuguegarao City, after having
been duly sworn in accordance with law, hereby depose and
statethat:(1) This complaint-
affidavit is being filed to charge PEDRO SANTOS, Filipino, of legalage, and with
residence at Tuguegarao City, of the crime of Rape under Article (Art.) 266 of the
Revised Penal Code (RPC), committed as follows:(a) On 27 October
2018, at around 10:00 in the morning, I was barely 6 years of age and playing outside
my house when JUAN DELA CRUZ came by and invited me to play computer games
with him at the house of
SANTOS.(b) On the way to their house, we passed by a narrow path where SANTOSsu
ddenly pushed me and JUAN DELA CRUZ inside a small, low building, which turned out
to be
SANTOS’
comfort room.(c) SANTOS then barred the door, whipped out a fan knife and poked it
against us and told us “Huwag kayo mag-iingay, kung hindi papatayin ko kayo!”
(d) SANTOS then asked me to step on the rim of the toilet bowl facing him and for
DELA CRUZ to hold me from behind. Out of fear for my life, I followed his orders.
While I was standing on the toilet bowl with my legs apart and DELACRUZ arms tightly
around my waist, SANTOS drew his short pants down to his knees, and after lowering
my underpants, he inserted his penis into my
vagina.(f) After satisfying his carnal desires, SANTOS once again pointed the knife at
DELA CRUZ
and told him “Gayahin mo ako! Ipasok mo ang ari mo sa ari niya!”
(g) DELA CRUZ pretended to insert his penis to my vagina while Mercado wasmasturba
ting.(h) Thereafter, he reiterated his threats to kill us. He gave me a five-pesocoin and
told me to buy candies with it, however I threw it
away.(2) It took me several months before I was able to overcome my fear and told my
mother, LINDA ALFONSO, what happened to
me.(3) Appalled by what happened, my mother and I went to the police station to report
the crime committed by SANTOS against my person. The police took my sworn
statement, a copy of which is hereto attached and made an integral part hereof as
Annex “A”.
Thereafter, I was examined by their medico-legal officer. A copy of the Medico-Legal
Report is likewise hereto attached and made an integral part hereof
as Annex “B”