Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
Laoag City

Juana Cruz NPS Doc. No 123456-123

Complainant,
vs. For

Juan de la Cruz Violation of Article 267 of the Revised Penal

Respondent. Code (Kidnapping)

COUNTER AFFIDAVIT
I, Juan de la Cruz, of legal age, single, and a resident of Barangay 02, Laoag City, Ilocos
Norte, after having been sworn to in accordance with law, do hereby depose and state and that:

1. I was the person charged at Office of the Provincial Prosecutor, Laoag City, that has
the docket number 123456-123.

2. That the accusations against me is not true and baseless thus the real story was:

a. At around 11:30PM of Saturday, January 01, 2020, I was at our house at Brgy. 02,
Laoag City.

b. At around 11:45 in the evening I got out of our house and went to buy load for my
phone at the store beside our house. This was evidenced by the text message
Received confirming the load transfer. (Attached as Annex “A”)

c. That I do not own a white van or a gun, and I did not threaten anyone in order to have
a sexual favor.

d. I only came to know the complainant when we met at the prosecutor’s office. I have
no prior knowledge about her person.

e. That I believe that this is a set-up because I was a police asset for dangerous drugs.

f. That when I cannot provide any information useful about my knowledge about the
drug trade, the police officer that I know, threatened me that he will file a case
against me.

g. That this prosecution was motivated by ill-will, which I believe that due to my refusal
to give information, thus this case was filed against me.
 3. That this Counter Affidavit was made in order to prove the real events and to deny the
accusations against my person.

IN WITNESS WHEREOF, I have hereunto affixed my signature on this 10 th day of

January 2020 at Laoag City.

Juan de la Cruz
Affiant

Subscribed and Sworn to before me this 10th day of January 2020, Laoag City, Ilocos
Norte.

RUTH KATHERINE P. MAALA

Assistant City Prosecutor

CERTIFICATION

This is to certify that I have personally examined the herein affiant and that I am satisfied
that he voluntarily executed and understood the statements in this Counter-Affidavit.

RUTH KATHERINE P. MAALA

Assistant City Prosecutor