Republic of the Philippines] Marawi City ] REPLY-AFFIDAVIT I, ARMINA GUILING DIDA-AGUN, of legal age, married and a resident of 141

AM Raya Madaya I, Marawi City, after having been sworn to an oath in accordance with law, do hereby depose and say: 1. That I am the complainant in NPS Docket No. XIV-06-INV-10A-00013 against MACAPADO A. MUSLIM, SAID M. MAKIL, BULINGAN SAMPORNA HADJI SIRAD and TANTUA A. MUSUR, all of legal ages and with office address at MSU Administrative Building, MSU Campus, Marawi City for violation of RA 6713; 2. That I vehemently deny the allegation of respondent MACAPADO A. MUSLIMs Motion for Reconsideration and Motion to Admit Additional Evidence for being completely false and untrue and are mere misrepresentations on the part of the respondent; 3. That respondent MACAPADO A. MUSLIM intentionally did not furnish me a copy of their reply communications by changing my official address to Dagduban, Marawi City; 4. That respondent MACAPADO A. MUSLIM has direct personal knowledge on the following communications which were duly received by his office and were discussed verbally by him and the complainant but no action was made: Date June 24, 2009 July 24, 2009 Aug 28, 2009 Sep 30, 2009 Subject Inquiry on MSU LNCAT vacant AO IV deliberation MSU LNCAT Refusal to receive my letter of inquiry for holding my salary Harassment and Grave Abuse of Authority of OIC BULINGAN H. SIRAD Request for Authentication and Verification of CSC Eligibilities and Other School Records of Tantua Musur, Baylo Cabili, Rasul Cadalay, Casana Serad and Raisa Taulo Request for Immediate Resolution of the Case: Armina G. Didaagun versus MSU LNCAT Administration Follow-up Letter to the previous communications dated Sep 30, 2009 and Oct 1, 2009 Marked in the Affidavit Complaint as Annex J Attached to Annex L Annex K Annex I

Oct 1, 2009 Dec 8, 2009

Annex L Annex M

5. That in our verbal conversation re: Authentication of CSC Eligibilities dated September 30, 2009, respondent MACAPADO A. MUSLIM requested me not to continue the verification of eligibilities of the accused otherwise they will be removed from the service;
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6. That in the Motion to Admit Additional Evidence of the respondent, NASSER M. ANDAM, Director of the Presidential Management Staff said: The case of Armina Guiling Dida-agun is an example. She had sent a communication to the President which I failed to bring to the attention of the President. As far as I could remember, when the Office received the communication, the President was out for an official trip. So what I did, I indorsed it to the Office of the Director of the Legal Services Division of the University for review and recommendation; Which one of my several communications addressed to the respondent was allegedly received by NASSER M. ANDAM and was consequently indorsed by him to the Office of the Director for Legal Services Division? Please take note of his word the communication, which means singular. If that is the case, he admitted that only one of my communications was done so by NASSER M. ANDAM, otherwise, the president is always out for official trip every time I sent a communication, which is improbable. Second, NASSER M. ANDAM in his affidavit said: When the President arrived, Armina Guiling Dida-agun talked to him in the Office of the President. In fact, it was not just once but several times. And because of the supervening event, I found it unnecessary to call the attention of the President regarding the letter because I had reasonably believed, in good faith, that they had already discussed the matter; It is therefore clear in the above affidavit of NASSER M. ANDAM, that the respondent MACAPADO A. MUSLIM is well aware of the complainants communications considering that they have discussed the communications of the complainant, not only once but several times. Therefore, the claim of the respondent that he is not informed of the complainants communication, which he failed to answer, is clearly unfounded and untrue. 7. That in the Motion for reconsideration of the respondent, he said: Firstly, contrary to the finding of the Office of the City Prosecutor, there is no evidence showing that respondent Dr. Macapado Muslim actually received the alleged letters of the complainant. As ruled by the Honorable Office, the letters were received by the Office of the President. Clearly then, respondent Dr. Muslim did not receive the said letters. The vital issue now is: Is the receipt of the office tantamount to the receipt of the recipient of the letter for purposes of the application of the penal provisions of R.A. 6713? It is my humble position that the respondent MACAPADO A. MUSLIM had actually received my communications due to the following facts: a) b) Said communications showed that it was all duly received by the Office of the President of the Mindanao State University, Marawi City; Every time I was given the chance to discuss with the respondent, I showed to him first my communications duly received by his staff;

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c)

The respondent admitted in his signed affidavits that we have talked verbally and discussed my grievances which is a clear proof of having a personal knowledge of my communications but he failed to answer any of those communications and most importantly, he never gave actions to address my grievances such as appointing a persons whose academic records and eligibilities are spurious, holding of my salaries from July 2009 to the present and harassing the complainant from preventing her to sign the school logbook;

8. That the respondent said in item 7 of his counter-affidavit: She accused me of not replying all his communications, which I did not personally received, as violation of R.A. 6713, otherwise known as Code of Ethical Standards of Government Officials and Employees. In Truth she blatantly hid the fact that we had several verbal communications that is more than a reply; While it is true that we had several verbal communications with respondent MACAPADO A. MUSLIM but he never gave any concrete action to address my legitimate grievances. Could it be considered a reply to my written communication when I told him that my salary was withheld by MSU-LNCAT Administration but did not bother to intervene when he is the good president of the MSU System? 9. That I am executing this affidavit to attest to the veracity of the foregoing facts and to move for the dismissal of the Motion for Reconsideration filed by the respondent. IN WITNESS WHEREOF, I have hereunto affixed my signature this ___ day of September 2010 at Marawi City, Philippines.

ARMINA GUILING DIDA-AGUN Affiant

SUBSCRIBED AND SWORN to before me this ______ day of September 2010 in Marawi City, Philippines, affiant exhibited her Community Tax Certificate Number _______________________________ issued at ____________________________ on _____________________________.

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