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Republic of the Philippines

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE PROVINCIAL PROSECUTOR
Cauayan City, Isabela

PNP-LUNA ISABELA,
Complainant, NPS Docket No. II-04-INQ-19A-00010
FOR: VIOLATION OF SEC 5 OF RA 9165
And OMNIBUS ELECTION CODE

-versus-

REYMOND FRANCISCO y LUYON


Respondent
X------------------------------------------X

SUPPLEMENTAL COUNTER-AFFIDAVIT

I, REYMUND L. FRANCISCO, of legal age, single, Filipino citizen, and


with residence address at Centro 2, Luna, Isabela, Philippines, under oath
hereby depose and state THAT, after having been sworn to in accordance
with law, hereby deposes and states that:

1. I am executing this Supplemental Complaint-Affidavit in order to submit


the following documents as additional annexes of my Counter-Affidavit.

2. I have hereto attached a copy of the Counter-Affidavit filed by a certain


Melvin Fernandez with a NPS Docket No. II-06-INQ-18H-00104 who was
charged of Violation of Section 5 and 12 of RA 9165(Annex ‘A’ of this
Supplemental Counter-Affidavit), dated August 31, 2018. This will prove
that Krisha Rumbaoa is one and the same person used by the PNP as an
asset to bait innocent victims who would be planted with drugs. That the
said Krisha Rumbaoa traps her victim by engaging with them through
'Facebook Messenger and requesting them to meet her. On the date of
the said meet-up, the lives of her unfortunate victims will be put in peril
because the said person named Krisha Rumbaoa finishes its main
objective by planting dangerous drugs to destroy the lives of these
innocent people.

3. I have hereto attached a copy of the Resolution resolved by Honorable


___________________ (Annex “B” of this Supplemental Counter-
Affidavit) dated ____________. That the Honorable Prosecutor dismissed

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the case filed against Melvin Fernandez y Naval whose case is very
identical in the case at bar. The accused Reymund L. Francisco through
her counsel, humbly prays that the same verdict given to Melvin
Fernandez y Naval will also be granted in our favor.

4. I desire to maintain and preserve all allegations and attachments


contained in my Complaint-Affidavit; and pray before this Honorable
Office to admit this Supplemental Complaint-Affidavit in as much as the
Certificate to File Action attached herein was unavailable at the time the
original Complaint-Affidavit was filed.

5. It is only because of the foregoing that I am filing this instant


Supplemental Complaint-Affidavit.

I STATE NOTHING FURTHER.

____________________
REYMUND L. FRANCISCO
Affiant

SUBSCRIBED AND SWORN to before me this ___ day of February 2019


in Cauayan City and I hereby certify that I have personally examined the
affiant and that I am satisfied that she voluntarily executed and understood
her Supplemental Complaint-Affidavit.

___________________________
Asst. State Prosecutor