I Rogelio Gomez, Filipino, 28 years of age, married, and residing at 1284 Laguna

Street Sta. Cruz Manila. I am writing this counter affidavit as my defense for the
crime of robbery that was charged against me by Raymond R. Rogacion in his
complaint dated February 20, 2015.
In the complaint of Raymond R. Rogacion, I was included as a co accused of Roberto
Garcia for the crime of robbery that allegedly took place on February 16, 2015.
It was stated in his complaint that on February 16, 2015 at about 9:15 in the
evening he was on his usual way home and while on the intersection of lerma and
recto two (2) men approached him and both armed with knives. Then he was
threatened that he would be harmed if he will not give his bag. That after complying
with the order of the two men, the two ran away and after few minutes a police
mobile arrived. He then asked the two police men who are: PO1 Morales and PO3
Nogales for help, thereafter the police went to the direction where the two robbers
went. After almost an hour the police mobile returned with two men who allegedly
robbed Raymond Rogacion.
I do not deny the fact that I was one of the two men that were apprehended and
were brought to the police station; however I deny the fact that I was one of the two
men that robbed Raymond Rogacion.
It was about 9:25 in the evening of February 16, 2015 that I was able to get out
from work as a janitor of UCPB , M.F. Tiaoqui Building, Plaza Sta. Cruz, Sta. Cruz, Manila branch.
Usually, I go out of work at around 5:30 pm, but on that day stated, I worked overtime as I was ordered by
our branch manager Mr. Luis Tan to help in the preparations for the renovation of the Bank.
While I was waiting on the corner of Recto and Sta. Cruz for a jeepney to ride on my way home, I saw two
men running towards my direction. I noticed that one of them was holding a bag. When they were already
near me, the other man who was not holding the bag went to Sta. Cruz Street, while the other man who
was holding the bag went straight towards me, suddenly a police mobile arrived, blocked the man holding
the bag and thereafter apprehended me.
I was then trying to ask the two policemen why they were apprehending me, but all my questions were to
no avail. They boarded me in the police mobile and then they drove to the intersection of Recto and
Lerma where Raymond Rogacion was waiting. Raymond Rogacion then boarded in the mobile and from
there we went to the police station.
Upon arriving at the police station, I immediately asked for permission to call my wife. I was then allowed
to call my wife.
It was only at the police station and only from the moment that we were brought to the police desk that I
knew the name of Raymond Rogacion and the other man that was apprehended with me. We were all
made to sign the log book, as they told as that it was for standard procedure. After about 5 minutes,
another police officer approached the desk and thereafter said that the other man apprehended with me is
Roberto Garcia who was previously convicted of the same crime.
I was then placed in a cell together with Roberto Garcia. I spent the night at the cell. The following day,
February 17, 2015 my wife together with Atty. Eduarte came to the police station. After an hour I was

released and told by a police officer that I am temporarily being released to prepare my defense for the
criminal complaint of robbery charged against me.
Hence, I execute this counter affidavit to refute the charge of robbery against me. to attest to the
truthfulness of my statements in this counter affidavit, I hereby affix my signature.

I Raymond R. Rogacion, 21 years of age, single, residing at 2180 Calamba Street,

Sta. Cruz Manila, and a student is writing this civil complaint for breach of contract
against Romualdez Rosal.
On March 5, 2015 I went to SM Manila to look for a computer repair shop to have my
Accer Laptop fixed. There I found the shop named Rosal Electronic Repairs which
was owned by Romualdez Rosal.
At the said shop, it was Romualdez himself who accommodated me. Thereafter,
Romualdez checked my laptop for initial assessment of what needs to be fixed.
Romualdez then said to me that my laptop needs some replacements of some
hardware parts for it to be fixed.
At the amount of 4,000 pesos I agreed to have my laptop fixed by Romualdez
himself. Upon paying the said amount, Romualdez issued me a receipt and also
made me sign a contract of service.
Under the contract, it was stipulated there that my laptop would be fixed by the
attending electrician which was Romualdez himself and within 10 days from receipt
of the laptop by the shop. The contract also contained a stipulation that upon repair,
it is guaranteed that the laptop would not experience any defect within 1 year,
provided that the defect was not caused by misusage or lack of care on my part.
On March 16, 2015 I returned to the shop to get my laptop. At the shop, Romualdez
handed me the laptop and affirmed that it has been fixed already. Romualdez then
showed me that the laptop was already fixed by turning it on and running some few
programs, thereafter, I left the shop and went home with the fixed laptop.
However, after just 1 week of using the said laptop and without any misusage on
my part, the laptop suddenly stopped working. As a consequence, I lost all of my
important files saved in my laptop. I wasnt able to complete all the assignments
and reports that I badly needed to finish.
On March 17, 2015 I decided to have my laptop checked again, but in a different
shop and by a different electrician. Upon examination by the electrician, it was
found that my laptop did not contain any new parts and even worse is that there
were also some parts that needed repair but was left unfixed.
On March 18, 2015 I again went to Romualdez in his shop and told him about what
occurred, I asked him if he could repair the laptop as it was not totally fixed, but
Romualdez without any good explanation refused to repair my laptop or even return
my money.
Hence, I execute this civil complaint for the breach of contract against Romualdez
Rosal.
Respectfully submitted:

Raymond R. Rogacion