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DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
QUEZON CITY
COUNTER-AFFIDAVIT
4. The injuries as shown in the copies of medical certificate and photos attached
in her complaint were self-inflicted and/or the certificates attached therein
were fabricated and were not properly notarized.
6. But the instant complaint she filed was only part of many harassment suits
she filed against me that all were baseless complaint but were only motivated
by her extreme jealousy and resentment without concrete basis due to her
immaturity and insecurities.
7. In the other complaint, i.e., the alleged Falsification of Public Document,
where she alleges that I sold our conjugal real property without her consent,
this was already controverted and belied by our children in their pinag-
samang sinumpaang salaysay ng pagtestigo, as herein attached as Annex “1”
and “2” forms part hereof, which can only shows that complainant was not
telling the truth;
8. The fact that complainant still living with me in our conjugal dwelling as of this
date while even the instant complaint, as well as the other criminal complaint,
subject for preliminary investigation is still pending for resolution, spending
quality family time1, as if we are not opposing parties in the complaint she
have filed, all the imputed acts alleged in her affidavit cannot be relied on.
11. The allegation of the complainant that I have no steady job was not true, in
fact, our children, including the complainant herself, have been benefitting
from the 15 apartments that parents tasked me to manage and maintain its
operation and undertakings, to which I never failed in providing all their
financial needs.
12. Again, it is most respectfully prayed unto the Honorable Office of the City
Prosecutor that the complaint for violation of RA 9262 filed by the complainant
against me be dismissed for lack of basis as all the allegations made were
purely fabricated and made up thing by the complainant merely to harass my
person.
13. 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 me in
the Complaint and Reply. Other matters alleged by the complainant in her
complaint and reply that failed to deny or to controvert in this counter-affidavit
are respectfully deemed denied and controverted.
IN WITNESS WHEREOF, I have hereunto set my hand this 20th day of March
2019 at Quezon City.
1
See attached photo taken during Christmas rush hour and my birthday celebration dated 19 March 2019 as
Annex “3”, Annex “3-1” and Annex “3-2”.
JOSE ALDRIN S. BARROGA
affiant
CERTIFICATION
I hereby certify that I have personally examined the affiant and I am fully
convinced that he voluntarily and freely executed the foregoing Rejoinder-Affidavit and
he understood the contents thereof.
Copy furnished: