Republic of the Philippines

Department of Justice
OFFICE OF THE PROVINCIAL PROSECUTOR
Batangas City, Batangas
JUANA MACAPALAD-KHOH,
Complainant
- Versus -
ALLAN SWERTE,
Respondent
X - - - - - - - - - - - - - - - - X
Republic of the Philippines)
City of ipa )!"!"
COUNTER AFFIDAVIT
#, ALLAN C. SWERTE, of legal age, married, $ilipino citi%en
and a resident of Brgy" Pinag&a'itan, ipa City, Batangas, after
being s'orn in accordance 'ith la', hereby depose and state(
)" *hat # am an employee of the CDD Company, a semi-
conductor manufacturing company, under Production
Department as Production !uper+isor,

-" *hat on January )., -/)0 at around 1(2/ in the morning #
log-out at the Production Department after finishing the
)/P3-143 shift as sho'n in the Computeri%ed Daily *ime
Record being monitored by the time &eeper as sho'n in
4nne5 647,

2" *hat on the same day, before e5iting the main gate of the
company, # 'ent to the ad8acent comfort room to urinate,
0" *hat # sa' and pic& up an ice-pic& near the cubicle 'here
am # supposed to use,
." *hat # sa' 3r" !9:; J<=: >?=? lying on the floor of the
ne5t cubicle,
1" *hat # 'as shoc&ed and that incident pro+o&ed me to ha+e
a panic attac& that led me to fall do'n and collapse as
sho'n in my medical records pro+ided by DR4" @434;9C?# in
4nne5 6B7,
A" *hat at the time 3r" @oung seen the incident, # 'as
unconscious,
NPS Docket No. : _________________
For
MURDER
B" *hat based on the P:P findings, they ha+e seen another
different fingerprint,
C" *hat as sho'n in the 4utopsy Report in 4nne5 6C7, that
3R" !9:; J<=: >?=? died at around 1Do cloc& in the
morning,
)/" *hat # +ehemently deny the accusation against me,
))" *hat # e5ecuted this Counter-4ffida+it to attest the
truth of the foregoing facts"
WHEREFORE, premises considered, it is most respectfully
prayed unto this ?onorable =ffice that the complaint against me
be dismissed for insufficiency of e+idence"
IN WITNESS WHEREOF, # ha+e hereunto affi5ed my signature
this 20
th
da of F!"#$a# 20%& in L'(a C't, )ata*+a,"
Allan C. Swerte
ALLAN C. SWERTE
4ffiant
SU)SCRI)ED AND SWORN to before me this -/
th
day of $ebruary
-/)0 in ipa City, Batangas" # hereby certify that # ha+e
personally e5amined the affiant and # am fully satisfied that he
has read and understood all of the allegations contained in his
Counter-4ffida+it"
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:otary Public
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FACTS-
=n January )., -/)0, a >orean and $ilipino :aturali%ed in the
name of 3r" !ung Jeon >hoh 'as found dead in the male comfort
room of the CDD Company located at Brgy" 4ntipolo, ipa City at
around ADo cloc& in the morning together 'ith 3r" 4llan C"
!'erte, employee and Production !uper+isor" 3r" >hoh is one of
the part o'ners and the head of the finance department" #t 'as
found out that the ob8ect used to murder 3r" >hoh 'as an ice-
pic&" Based on the initial in+estigation, the fingerprint result
sho'ed that 3r" !'erteDs fingerprint is presently at the said
e+idence used to &ill the +ictim" $urthermore, an autopsy of the
body 'as conducted by the Philippine :ational Police FP:P) G
Crime aboratory - ipa City to ensure the fairness and Huality
of e+idences" During the conduct of the inter+ie', 3r" !'erte
denied the accusations to him" P:P gathered 'itnesses but to no
one is amenable for 'hat had really happened on the said
incident, e5cept to 3r" @oung, 'ho called the attention of the
security guards"