Republic of the Philippines }

In the City of Naga }S.S

COMPLAINT-AFFIDAVIT

I, STEPHEN C. MENDOZA, Filipino, of legal age, married, and

a resident of B5 L13, R. Felipe St., Concepcion Grande, Naga City,
under oath, states that:

1. I was accused of the felony of Grave Threats as defined and

penalized by Art. 282 of the Revised Penal Code, in Criminal
Cases No. S-4582 and S-4583 before the 7th Municipal Circuit
Trial Court of Tigaon, Camarines Sur, both docketed as People of
the Philippines vs. Stephen C. Mendoza.

Copies of the Informations on the two cases are hereby attached to

this Complaint-Affidavit as Annexes "A" and "B", respectively, and
made integral part hereof.

2. In a Joint Judgment by the Honorable Court on the above criminal

cases, dated May 22, 2015, by the Honorable Jorge John S. Aganan,
I was acquitted of the said charges. The dispositive portion of said
judgment reads:

"CRIMINAL CASE NO. S-4582:

WHEREFORE, premises considered, accused

STEPHEN C. MENDOZA on ground of reasonable doubt, is
ACQUITTED of the crime charged in Crim. Case No. S-
4582.

SO ORDERED.

CRIMINAL CASE NO. S-4583:

WHEREFORE, accused STEPHEN C. MENDOZA is

also ACQUITTED on ground of reasonable doubt of the
crime charged in Crim. Case No. S-4583.

SO ORDERED."

Copy of said Judgment is hereby attached to this Complaint-

Affidavit as Annex "C" and made integral part hereof.

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3. During the prosecution's presentation of evidence, Prosecution
Witness SAMUEL BISCO Y DE LOS SANTOS, Filipino, married,
and a resident of Sitio Lubas, Sibaguan, Sagay, Camarines Sur,
knowingly and falsely testified against me committed in the
following manner:

a. On April 20, 2009, Mr. Bisco executed an Affidavit stating

facts and events which allegedly transpired on March 21,
2009. In summary, Mr. Bisco stated that when my cousin
Leopoldo Guillermo "Boyet" Mendoza III went to Sitio Lubas
on March 21, 2009, it was only my other cousins Hiram
Othelo M. Rogando, and Pethyas P. Mendoza who were
with him. My name was never mentioned in the Affidavit.

b. However, when he testified on October 17, 2014 during the

trial of my cases, he identified and adopted a Judicial-
Affidavit dated April 21, 2014 which already implicated me
as one of those who accompanied my cousin Boyet.

Thus, in his April 20, 2009 Affidavit, he stated:

4. Q: At the time you were harvesting, where was

Leopoldo Guillermo Mendoza III?

A: He was with Utilo and Pichas Mendoza talking

with Salome Buela.

But in his April 21, 2014 Judicial-Affidavit he stated:

5.H: Kan Marso 21, 2009, nagigirumduman mo kung

nahiling mo sindang apat?

S: Iyo po. Pakapangudto po kan Marso 21, 2009,

pinasuguan ako ni Boyet na dumanan daa ako sa may
harong ni Pelagio Dacillo.

6.H: Ano nagduman ka sa lugar susog sa paapod saimo?

S: Iyo po. Katunayan ngani kaiyan, naabutan ko duman sa

Boyet, Stephen, Pethyas, saka Utilo saka ibang
kalalakihan na napag-araman kong pina-apod man ni
Boyet.

Copies of both Affidavits are hereby attached to this

document as Annexes "D" and "E", respectively, and
made integral part hereof.

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d. On October 17, 2014, during the cross-examination of Mr.
Bisco by my counsel, Atty. Leo Caayao, he admitted in open
court that he testified against me because he was promised
by Bong Quillope (private complainant in the twin cases of
Grave Threats against me) that if he and one other prosecution
witness Rolando Condat would testify against me they will
not be included in a criminal complaint for qualified theft.

Thus, the transcript of stenographic notes during the

October 17, 2014 cross-examination reveals:

TSN
CRIM. CASE NO. S-4582/4583 and S-4588
Page 2
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x

CROSS EXAMINATION:

Q :Mr. Bisco, your tesstimony against Stephen Mendoza and

Guillermo "Boyet" Mendoza was on the alleged incident last
November 21, 2009, am I correct?

A :Yes, sir.

Q :And this incident that you are testifying on said date

involves the gathering of coconuts on orders of Guillermo
Mendoza, were you are one of the coconut pickers?

A :Yes, sir.

Q :And as one of the pickers you know for a fact your name was
included in the complaint made by Ulysses Bong Quillope in
the police authorities of Sagay, Camarines Sur?

A :Yes, sir.

Q :Your name was also included in the complaint of Vicente

Ulysses Quillope with the barangay authorities of Sibaguan,
Sagay, Camarines Sur, is that correct?

A :Yes, sir.

Q :But when a case for qualified theft was filed against the
coconut pickers your name and that of Rolando Condat were
no longer included, is that correct?

A :Yes, sir.

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 Q :You and Rolando Condat were no longer included
in the accusations because the two of you were
promised by Bong Vicente Ulysses Quillope, that if
the two of you will execute an affidavit against
Guillermo Mendoza and Stephen Mendoza you will
not be included in the complaint, is that correct?

A :Yes, sir. This is my affidavit and this is my

signature.

Copy of said transcript of stenographic notes is hereby attached

to this Complaint-Affidavit as Annex "F" and made integral
part hereof.

4. I am executing this Complaint-Affidavit to attest to the

truthfulness and veracity of the foregoing statements and for the
purpose of filing a criminal complaint against Mr. Samuel Bisco y
de los Santos for the felonies of FALSE TESTIMONY AGAINST A
DEFENDANT and PERJURY IN SOLEMN AFFIRMATION as
defined and penalized under Art. 180 par. 4 and Art. 183,
respectively, of the Revised Penal Code, should probable cause be
found by the Honorable Investigating Prosecutor.

IN WITNESS WHEREOF, I have hereunto set my hand this

______ day of June 2017 at Naga City, Philippines

STEPHEN C. MENDOZA
Affiant/Complainant
Govt issued ID: ___________
Valid Until:_______________

SUBSCRIBED AND SWORN to before me this _______ day of April

2017 at ____________________, Philippines, affiant having shown to me his
ID and further avowed that the foregoing statements are based on his own
personal knowledge and that the same is his free and voluntary act and
deed.

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