REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
Kagawaran ng Katarungan
OFFICE OF THE CITY PROSECUTOR
National Capital Region
Manila City

ANGELICA A. SIMEON,
Complainant,

- versus - IS. No. 123456

JAY U. TUAZON Violation: Rape

Accused.

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REJOINDER - AFFIDAVIT

I, JAY U. TUAZON, of legal age, Filipino, single, with residential address

of Islamic Center, San Miguel, Manila City, after having sworn to in accordance

with law depose and say, that:

(1) As respondents in the instant case, I have been in receipt of the Reply dated

_____________

(2) I deny the allegations under paragraph 2 and 3 of the Reply, the fact that

Divisoria mall is almost five (5) kilometers away from San Miguel Manila denies

their stipulation that “it is not too far”. I could have used a farther place to

putmyself into if my intention was to use alibi as my defense to make myself more

convincing. Furthermore, September 11, 2017 is a Monday, which means that I

had walk with two (2) sacks of scraps of rags to be made for the whole week which
were bought from Tabora Street, Divisoria and to be delivered to the warehouse in

San Miguel Manila. I could have perpetrated the alleged crime on a day which is

more comfortable and efficient for me to do the same. For more than a year

already, I usually see the complainant walking to her work at 7:50 AM from home

in Isetann, Carriedo and goes home from work at around 5:15PM everyday. The

crime was allegedly committed at 11:00 PM, which is very far from the time she

usually goes home. I had no inkling that she is going home at that time and that

late since, again, I usually see her going home at 5:15PM everyday.

(3) I further deny the allegations under paragraph 4, 5, and 6. I have always

been a gentleman to the complainant since we knew each other for years already

and also as a respect for the past relationship of the complainant and my twin

brother. Never was it pointed out in the complaint or at any instance that I touched

her in anyway until the alleged time of the crime that she has been accusing me.

The respondent admitted that I helped her dress up the moment I saw she was

laying naked and bleeding the next morning. I even insisted to bring her to the

nearest hospital but I she suddenly ran away. Helping the complainant was a

genuine initiative on my part as the same person is not a stranger to me.

(4) The complainant admitted that she is aware that I have a twin brother. I am

also aware that they had a two-year affair which is more than enough time to know

even the most unnoticeable difference between me and my twin brother’s physical

appearance, and more importantly, the difference of our personality. The crime

was allegedly committed at 11:00 PM where the accused also admitted that it was

very dark in the area. This diminishes her accuracy in determining the real
perpetrator of the alleged crime, having the fact that me and my twin brother looks

almost identical except that he has a large mole on his right cheek.

(5) I am executing this Affidavit to attest to the truth of our foregoing

statements, in support of my Counter Affidavit and to rebut the allegations against

us in the Complaint and Reply.

IN WITNESS WHEREOF, I have hereunto set my hand this ___ day of ___ 201_
in Manila City.

JAY U. TUAZON
Affiant

Assisted by:
_________________
ATTY. _____________

SUBSCRIBED AND SWORN to before me, in Manila City, this ____

day of _______

I HEREBY CERTIFY that I have personally examined the affiant and

satisfied that he voluntarily executed this Complaint-Affidavit and understood the
same.

INVESTIGATING PROSECUTOR