REPUBLIC OF THE PHILIPPINES)

BATANGAS CITY ) S.S.

REPLY
(To the Counter-Affidavit)

I, JOCELYN ADOYO Y SALAS, of legal age, married, Filipino and

a resident of Potenciana Village Pallocan West, Batangas City, after
having been duly sworn to in accordance with law hereby depose and
state that:

In the Counter-Affidavit submitted by my husband, herein

respondent Aljune S. Adoyo, he alleged that the allegations in my
complaint-affidavit were half-truths, exaggerations , a weak attempt to
destroy his reputation as an officer of Philippine National Police and
does not constitute a violation of any law, I beg to disagree as the
evidence attached to my complaint-affidavit proved otherwise;

Respondent stated for the record that he truly loves me and our
daughter, Kristen Gabrielle S. Adoyo as being the most important people
in his life, this may be true in the beginning of our relationship but
recent development in our relationship belied it. In the year 2010, I
believed that he loves me and our daughter and although he was not with
us, he regularly sent me text messages showing his affection, a
photograph of his messages sent thru mobile no. 09082763526
addressed to me are hereto attached as Annex “A”;

Respondent likewise denied that he had an illicit relationship with

Madel Algire and that the pictures of the two them were placed inside
his wallet, but the messages I received from him thru his mobile no.
09082763526 proved contrary. He admitted the fact that the picture
of Madel and him was placed in his wallet and that he was guilty,
ashamed and has been a bad husband to me and bad father to our
daughter, a photograph of his message sent thru mobile no.
09082763526 addressed to me are hereto attached as Annex “B”;

In another text message, respondent claimed all the blame to

what happened in our relationship and even wished for my forgiveness
feigning remorse on his part but his true color was instantly revealed in
another text message stating that he can no longer live with me after
the scandal that I caused at Eldridge and RIAS, such message
shattered my well-being and caused me sleepless nights, a photograph of
the said messages sent thru mobile no. 09082763526 are hereto
attached as Annex “C”;

There is no truth that I opposed and/or objected to Respondent’s

plan of being a police officer, in fact, I was the one who supported him
and financed his trainings so that he can enter the police service. There
is likewise no truth that I demanded him to leave his work as police
officer and uttered the words “Mas gusto ko pang magkaroon ng asawang
tambay at walang trabaho kaysa magkaroon ng asawang pulis at lagi
namang wala”. The truth of the matter is that I requested him to apply
for a transfer at any station within the Province of Batangas due to
the condition of our daughter whom he declared that he truly loves so
that he can spend more time with us and to prevent the impending
breakdown of our marriage;

I hereby denied calling him names and nagging him as the same is
not true and out of my character being a public school teacher;

It is only in Respondent’s counter-affidavit that I learned that he

has been depositing a certain amount in my Landbank Savings Account
and I cannot believe it when he stated in his counter-affidavit the he
was giving me the amount of P3,000 to P4,000 from January 2012 to
April 2012 while the deposits slips only disclosed the amount of P1,500
and P1,800;

I still affirmed that I received an information about respondent

and Madel Algire from unknown number as it was the truth, the only
thing I know about the sender is that he/she is a co-police officer of
respondent who pities me and if necessary, I will disclose the cellphone
number of my source and the exact content of the said messages during
the trial of these cases;

The Medical Certificate of our daughter Kirsten is just a

confirmation of the abnormal behavior of our daughter as I was able to
observe the same being her mother and the one who always take cares
of her and for purpose of the determination of probable cause, such is
sufficient;

Although I filed these cases against Respondent, I still

encouraged him to visit our daughter but up to now, he has not shown
any effort to visit our daughter albeit his presence here at Batangas
City. He has not done anything to check on the condition of our
daughter and although he was giving a minimal amount for our daughter’s
support, such is not sufficient to absolve him of his other obligations as
father of our child;

I executed this Reply affidavit to attest to the truthfulness of all

the facts stated therein and to prove that there is probable cause to
indict respondent Aljune S. Adoyo of Violation of R.A. 7610 and
Violation of R.A. 9162 against my husband Aljune S. Adoyo;
 IN VIEW THEREOF, I have hereunto set my hands this ____ day
of May 2012 at Batangas City, Philippines.

JOCELYN S. ADOYO
Complainant

SUBSCRIBED AND SWORN to before me this ____ day of May

2012 at Batangas City, Philippines.

Administering Officer

CERTIFICATION

I hereby certify that I have personally examined the affiant and

I am personally satisfied that she voluntarily executed and understood
the contents of her complaint- affidavit.

Administering Officer