Republic of the Philippines

REGIONAL TRIAL COURT

10TH Judicial Region
Branch 1
Tagum City, Davao del Norte

PEOPLE OF THE PHILIPPINES,

CRIM. CASE No. __________
-versusFOR: ROBBERY WITH
HOMICIDE
RAMON ANDRES,
ANA RELOS
Accused.
X- - - - - - - - - - - - - - - - - - - - - - - /

JUDICIAL AFFIDAVIT
OF MR. EDWARD RAGASA

I, EDWARD RAGASA, 45 years old, married, residing at

National Highway, Tagum City and at present I am the operations

Page 2 of 11

manager of the Pera Money Changer Tagum Branch, after having

been sworn to in accordance with the law do hereby depose and
state:

That Atty. MICHAEL PERT GONZAGA is the counsel who

conducted and supervised my examination as a witness at his office
at Gonzaga, Gonzaga and Gonzaga Law Office, DCT Building, Rizal
Street, Tagum City, Davao del Norte;

That I am answering the questions herein fully conscious that I

do so under oath and that I may be criminally liable for false
testimony or perjury;

The following are the Questions propounded by Atty. Michael

Pert Gonzaga and I answered it in English:

Q1: Are you willing to give a free and voluntary statement and do
you swear to tell the truth and nothing but the truth?
A1:

Yes Sir.

Q2: Then please

circumstances.

state

your

name

and

other

personal

A2: Sir, I am Edward Ragasa, 45 years old, married. I finished my

elementary at Pilot Elementary School, I was in honor section. I was
also in the honor section at Mangga National High school. I finished
a degree in Management at the University of Mindanao Tagum
Campus.

Page 3 of 11

Q3: Do you have any work at present?

A3:

Yes sir, I do have.

Q4: Where do you work if we may know?

A4: At present I am the operations manager of the Pera Money
Changer shop Tagum Branch.

Q5: Being the operation manager, what does your work entails?
A5:

Sir, my work basically involves supervising the day to day

operations of the Pera Money Changer Shop. Clearing the
transactions involved only up to the extent of Two Hundred
Thousand pesos (P200,000.00).

Q6: When you say transactions, what do you mean?

A6:

Sir, a transaction in our company lingo is any request for money

exchanged. My authority as manager only allows me to clear
any request for exchanged up to the value of Two Hundred
Thousand pesos (P200, 000.00) only sir. Above that I would
have to clear that with the owner sir Mr. Ferdinand Topacio.

Q7: Now, where were you last July 25, 2012?

A7:

I was at my office your honor.

Page 4 of 11

Q8: Was there any peculiar incident during that day, if there was
any?
A8:

Yes, there was sir.

Q9: What was it if we may know?

A9:

I cannot forget that day your honor because during that day at
eight oclock in the morning I received a request for exchanged
amounting to Four Hundred Twenty Thousand
pesos sir.
That was the biggest single request for transaction that I ever had.

Q10: Who made the request if we may know?

A10: Sir the request was made by Anna Relos whom at the
time of the request made me believed that she was our long
time client Madamme Maryann Calle.
(What made you think that she was Anna Relos?)
A: I just find it out later sir after the incident of killing when I have
known the occupants of Room 2 with the Hotel Front Desk Officer/
Hotel Clerk.
Q11: Who is this Madamme Maryann Calle?
A11: Madamme Maryanne Calle is one of our more frequent
customers. She usually calls us through our telephone line
every time she wanted to make a transaction.

Q12: Going back to the phone call what transpired? How the lady on
the phone did introduce herself to you?
A12: Sir, as I remember it I picked up the phone and before I could
say hello, and ask who this is, the lady on the phone hollered in

Page 5 of 11

a cheerful tone hello general this is your friend Madamme

Calle.

Q13: Who was this general she was referring to?

A13: I am that general sir. Only Madamme Calle calls me by that
nickname sir since I conferred to her in one of her visits here
several months ago that my tatay always wanted me to become
a soldier and to follow his footstep of being a soldier.

Q14: So that made you convince that it was Madamme Calle?

A14: Not just that sir but her accent and cheerful way of speaking is
very similar with that of the real Madamme Calle..
Possible cross examination question on this: Did it ever occur to you
to check with the Information Officer of the Hotel to verify the person
occupying the room? (or you can possibly include na lang this
question Pert and make a safe answer out of this para iwas sa cross)
A: At that time sir, I was convinced because when I asked about the
record account number file which she had with us sir, she was able to
give it. Because as you know your Honor, part of our system and
internal policies to have files of our avid clients who usually transact
business with us especially in huge amounts. It is usually part of the
business internal controls, monitoring systems and record keeping
your Honor.

Q15: After the introduction what happen next?

A15: The lady on the phone told me that she needs to have
her
Ten Thousand dollars $10,000 changed to pesos and have it
deliver at Room 2 Grand 7 Hotel, Tagum City. But I told her

Page 6 of 11

that considering the largeness of the amount I need to clear it

first with the owner Sir Ferdinand Topacio.

Q16: Afterwards what happened?

A16: I immediately called Sir Ferdie sir and upon his knowledge
that it was Maddame Calle who made the request, Sir Ferdie
(immediately) (delete the word immediately..kay matanga ang
owner paminawun) called up again Room 2 of Grand Hotel to
check and verify the veracity of my word. After that sir, he for
himself was quite convinced that it was indeed Madame Calle
and without hesitation approved the request on the condition
that it would be Mario Damiano, his trusted aide will be the one
to deliver the money and make the transaction.

Q17: I am showing to you a document could you please identify the

same?
A17: This is the receipt record for the transaction money purportedly
for Madamme Calle sir. I was the one who prepared the money
sir
worth Four Hundred Twenty
Thousand
Pesos
(P420,000) since the exchanged rate at that time sir is
P42.00 to $1.00.
(The witness at this point in time is requested by the counsel to
affix his signature and put the present date on the upper right
portion of the document. The receipt was marked as Exhibit A)
Q18: Then, what happen next?
A18: After preparing the money I called Mariano Damiano to
office.

my

Page 7 of 11

Q19: What were your instructions to Mariano Damiano if there are

any?
A19: I instructed him to deliver the money only to the
person of
Maddame Calle and to no one else at Room 2
Grand 7
Hotel, Tagum City. And in the unlikely event that it is not
Maddame Calle to immediately return to the office and
inform the security personnel of said hotel.

Q20: What was the reply of Mr. Damiano if there was any?
A20: Mariano asked me if the transaction turned out to be good
could he take his lunch at his house since his house is just
in the vicinity of the Hotel and he promised to return before 2
oclock in the afternoon.

Q21: What did you answered?

A21: I said yes Sir considering he had been a long acquaintance of
mine and he is a trusted aide of the owner Sir Ferdie.

Q22: What happened afterwards?

A22: We continue with the usual course of our business sir till I was
interrupted by a call from the police at 2:30
pm informing
me that Mr. Mariano Damiano our employee was
found dead at
Room 2 Grand 7 Hotel. So I inquired if the
money is still there.

Q23: What was the answer of the policeman?

A23: He answered me Sir that there is no money in the room. So I
immediately called Sir Ferdie and informed him of the incident
sir.

Page 8 of 11

Q: After knowing the culprits, did it ever occur to you their relation
with Madame Calle and how they happened to know the usual
way of calling you?
Possible answer: I have no idea your Honor. ( I think this question is
important Pert para musulod jud si Madame Calle as witness or
as conspirators of them.)

Q24: Do you have any more to add Mr. Witness?

A24: There is no more your honor.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

24th day of September 2013 at Tagum City, Philippines.

EDWARD RAGASA
State Witness

Page 9 of 11

SUBSCRIBED AND SWORN to before me this 24 th day of

September 2013 at Tagum City, Philippines.

MICHAEL PERT GONZAGA

Triple G Law Office
DCT Building Rizal Street,
Tagum City, Davao del Norte
MCLE Compliance Number 123456

ATTESTATION OF LEGAL COUNSEL

Page 10 of 11

I, MICHAEL PERT GONZAGA, public attorney, having office at

DCT Building, Rizal Street, Tagum City, Davao del Norte, after having
been sworn to in accordance with the law do hereby depose and say:

1. That I have faithfully recorded or caused to be recorded the

questions I asked and the corresponding answers that
witness, Edward Ragasa, gave;
2. That I have not, nor any other person present or assisting
coached the witness regarding the witness answers; and
3. That I fully understand that any false attestation shall subject
me to disciplinary action, including disbarment.

IN WITNESS WHEREOF, I have hereunto affixed my signature

this 24th day of September 2013 at Tagum City, Philippines.

MICHAEL PERT GONZAGA

Public Attorney / Notary public

Page 11 of 11

SUBSCRIBED AND SWORN to before me this 24 th day of

September 2013 at Tagum City, Philippines.

ATTY.ANGEL MAY P.YAMAS

Public Attorney IV
Public Attorneys Office
Tagum City, Davao del Norte
MCLE Compliance No. IV 000000
Officer-in-Charge