Republic of the Philippines

Office of the City Prosecutor

Zamboanga City

JULIA SANTOS, I. S. No.

Complainant,

-versus- -for-

CARLO SANTOS and CONCUBINAGE

GIGI NAKO,
Respondents.
X-----------------------------------------X

JUDICIAL AFFIDAVIT

I, MATTHEW KANG of legal age, Filipino, married and a resident of Sta.

Maria, Zamboanga City, Philippines, employed as a co partner/ co-contractor of
Carlos Santos , after having sworn to in accordance with law, do hereby and
states:

PRELIMINARY STATEMENT

That That in accordance with A.M. No. 12-8-8-SC, which prescribes the
use of judicial affidavits to serve as the direct examination testimony of the
witness, on the basis of which the adverse party may conduct their cross-
examination on such a witness, I hereby execute this judicial affidavit in a
question and answer format;

That conformably also with section 3 (c) thereof, I hereby state under the
pain of perjury that in answering the questions asked of me, as appearing herein
below, I am fully conscious that I did so under oath, and that I may face criminal
liabilities for false testimony or perjury;

AND UNDER OATH, AVERS THE FOLLOWING:

Q1: Do you know the complainant and respondent-husband in this case?

A1: Yes

Q2: How did you come to know them?

A2: I established the business together with Carlos Santos since we graduated
college and one of their closest friend.

Q3: how long have you been partners?

A3: We already planned our partnership since we graduated college.

Q4: As a partner in business, what are the things you usually do?
A4: I am actually assigned in operational system and as well as planning of the
business, usually I mandate our foremen, masons and carpenters.

Q5: What is the respondent’s task in your business?

A5: he is assigned in hiring laborers, financial budgeting of the business, giving
out salaries to our employees.

Q6: do you also know the co-respondent in the case?

A6: Yes.

Q7: how come did you know the respondent?

A7: I came across with the respondent when we started hiring employees
especially secretaries for the new project.

Q8: Did the respondent immediately hired her?

A8: No. because her capability didn’t fit the standards that we are looking for a
new secretary.

Q9: how did co-respondent become an employee of the respondent?

A9: instead of being hired as a secretary, respondent hired her being the maid
since she wanted to have a work due to financial circumstances

Q10: Did you close to the co-respondent?

A11: Yes. Since the respondent hired her, she regular joins us especially on our
wee hours (like drinking, bar hoping and road trips).

Q11: did you ever wonder that the respondent and the co-respondent become
close?
A11: At first no, because I know that the respondent has a wife and I know that
he has a good relationship with her. But eventually when the co-respondent is
always joining us, I wondered because they are very close with each other, they
whispering in front of me which makes me uncomfortable, sometimes co-
respondent wipes his lips with her handkerchief but I ignored it maybe because
it was her role to take care of his employer.

Q12: what else did you notice between the closeness of the respondent and the
co-respondent?
A12: it was end of April when we were scheduled to go to Batangas with my team
I saw the co-respondent crying in front of the respondent and it seems that he
was comforting her and I wasn’t able to hear the conversation since I was in a
hurry to get all my things so that we can catch up our client in Batangas. When
we left, I noticed that the blue print that we are supposed to present was not on
hand and it was in the table of the respondent. We hurriedly went back to the
office to get the blue print, when I was entering the office I notice that the comfort
room was a little bit open and when I peep I saw the respondent and co-
respondent kissing, then they notice that I was there the respondent immediately
went out of the comfort room and asked me why I was still there and I answered
that I was able to left the blue print and I hurriedly went out and drove to
Batangas.

Q13: in that case, did you ever called the wife of the respondent husband?
A13: No

Q14: what is your reason for not telling the wife the respondent husband?
A14: I don’t want to hurt the feelings of the wife and I don’t want to be involved
in their relationship matters.

Q15: did you ever talked to the respondent husband or even discussed about
what you have seen?
A15: No. I just let it passed by as if nothing happens.
Q16: Do you have any additional statements in this judicial affidavit?
A16: none

Q17: Are you willing to sign this affidavit to certify that all statements you made
herein are true and correct?
A17: Yes.

IN WITNESS WHEREOF, I hereby set my hands this day of

, in the City of Zamboanga, Philippines.

MATTHEW KANG
Affiant

SUBSCRIBED AND SWORN TO before me this day of

in Zamboanga City, Philippines. The affiant is personally known to the
undersigned notary as the very person executing this judicial affidavit.

Doc No: ;
Page No: ;
Book No: ;
Series of 2018.

SWORN ATTESTATION

I, , Filipino, of legal age, single, with office

address Zamboanga City, after being sworn to in accordance with law, hereby
depose and state that: I conducted the examination of the witness, BEN
BAKENG, in the preparation of his judicial affidavit; that I faithfully recorded or
caused to be recorded the questions I asked and the corresponding answers that
the witness gave in a language known and understood by him; and that I nor
any other person then present or assisting, coached the witness regarding his
responses to the questions propounded.

SUBSCRIBED AND SWORN to before me this _____ day of

____________________ 2018 in the City of Zamboanga City, Philippines.