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REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES


FOURTH JUDICIAL REGION
Branch 13, Lipa City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. 101112


Plaintiff,

-versus- For: Lascivious Conduct in


Relation to Sec. 5 (b)
of RA 7610
LOU D. LEE,
Accused.
x- - - - - - - - - - - - - - - - - - - - - - - - x

JUDICIAL AFFIDAVIT OF CEECY TYBI

I, Ceecy Tybi, of legal age, single, and living at 451 Malupit St., Brgy.
Maginhawa, Lipa City, Batangas, witness of the accused in this instant case,
state under oath as follows:

PRELIMINARY STATEMENT

The person examining me is Atty. Maria Valerie Z. Buenavista with address


at 143 Pag-Ibig Street, Brgy. Minahal, Lipa City. The examination is being held
at the same address today October 22, 2017. I am answering her questions
fully conscious that I do so under oath and may face criminal liability for false
testimony and perjury.

This affidavit/testimony is being offered to prove (1) that the accused went
to room 211 with Zen Yor and Jun Balandra; (2) that the plaintiff was not
alone in room 211 when the accused and the other nurses checked on her
and (3) all other related matters, facts and circumstances relevant and
material to this case.

Q1. Do you swear to tell the truth and nothing but the truth?
A1. I do.

Q2. Are you aware that you may face criminal liability for false testimony
or perjury if you will not tell the truth?
A2. I am.

Q3. Please state your name, age, address and occupation.


A3. I am Ceecy Tybi, 30 years old, residing 451 Malupit St., Brgy.
Maginhawa, Lipa City, Batangas, the Cctv operator in Granja Hospital
in Lipa City.

Q4. Are you aware why you are present here today?
A4. Yes

Q5. Why are you here today?


A5. To give testimony in relation to the complaint against one of our
junior nurses, Lou D. Lee

Q6. Do you know what was the complaint against Lou D. Lee?
A6. Yes

Q7. What was the complaint about?


A7. One of our in patients Amy Tee accused Lou D. Lee of touching her
in her private parts.

Q8. Do you know when did the alleged touching happened?


A8. Yes, I saw the copy of the complaint of the patient.

Q9. When and where did this alleged touching happen according to the
complaint?
A9. On September 30, 2017 at around 9:00 in the morning in room 211.

Q10. Where were you on the said stated date, time, and place?
A10. I was in the CCTV control room in Granja Hospital.

Q11. What is your duty as CCTV operator?


A11. As the CCTV operator, I monitor all systems within the control room
ensuring that all work is undertaken in compliance with security
operating procedure. Also, I assist in conducting investigations and
prepare accompanying investigation reports for cases which occur
within the Hospital.

Q12. What time is your shift on September 30, 2017?


A12. My shift is 6:00 am to 2:00 pm.

Q13. Have you had the chance to review the CCTV footage, recorded
during your shift, in relation to this case?
A13. Yes. I also made a report on it as part of my duty as CCTV operator.

Q14. In your report can you tell what happened at 6:00 am of September
30, 2017?
A14. The accused together with Zen Yor and Jun Balandra stationed at 2nd
floor did their rounds.
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Q15. At 8:00 am what happened?
A15. I saw a man in his forties or fifties leaving room 211.

Q16. After that what happened next?


A16. At 8:10 am I saw a man in his early twenties enter room 211.

Q17. At 8:30 am what happened?


A17. A woman in her forties or fifties left room 211.

Q18. After that what happened next?


A18. At 9:00 am, I saw the man in his early twenties leaving room 211 and
went to the nurses station.

Q19. After that what happened next?


A19. Then I saw him return in room 211 together with accused, Zen Yor
and Jun Balandra.

Affiant further sayeth naught.


Ceecy Tybi
Ceecy Tybi
Affiant

SUBSCRIBED AND SWORN to before me this 22nd day of October,


2017, in the City of Lipa, Philippines.

Atty. Maria Valerie Z. Buenavista

ATTESTATION

I, Atty. Maria Valerie Z. Buenavista, under oath, do hereby state that:

1. I supervised the examination of herein witness-affiant;


2. I faithfully caused the recording of the questions and their
corresponding answers;
3. Neither I nor anyone present at the time of the examination of the
witness-affiant had coached him in giving answers.

IN WITNESS WHEREOF, I have hereto affixed my signature this 22nd day


of October, 2017 in Lipa City, Batangas.

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Atty. Maria Valerie Z. Buenavista
Counsel for Defendant
143 Pag-Ibig Street, Brgy. Minahal, Lipa City
Roll of Attorney No. 081490
IBP No. 1015014
PTR No. 122500
MCLE Compliance No. 123456-1

SUBSCRIBED AND SWORN to before me this 22nd day of October 2017,


in the City of Lipa, Philippines.

Atty. Richelle Ann Zamora


Notary Public
st
Rm 123 1 Flr Very Tall Bldg, Lipa City
PTR No. 1234567 1.4.17 Lipa City
IBP NO. 1234567 1.4.17 Lipa City
Roll of Attorneys No. 12345
MCLE Compliance No. IV-12345
Issued on January 1, 2017

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