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REPUBLIC OF THE PHILIPPINES


DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
ILOILO CITY
PEVI MAE P. JALIPA
-VERSUSI.S. No. 1234
FOR:
Rape
DONI JUNE V. ALMIO
x------------------------------------------------------------------------------------------------x
I, Doni June V. Almio, of legal age, Filipino citizen and a
resident of Mandurriao, Iloilo City, after having been sworn to
in accordance with law hereby depose and state that:
1. I am the accused in Criminal Case No. 1234 for
the crime of RAPE under Article 266-A of the Revised
Penal Code;
2. I am employed as a janitor at the University of San
Agustin, since January 10, 2015;
3. I admit the allegations in Paragraph 7 of the Complaina
nts Affidavit-Complaint;
4. I deny the allegations in Paragraph 4
for lack of knowledge as to the truth of the said
allegations, the truth being that:
a. On the evening of July 11, 2015, I was at the
place of my work in University of San Agustin,
Iloilo City;
b. That at about 8:00 in the evening of July 11,
2015, I finished cleaning the CR of the
University of San Agustin Gym;

c. That after finishing the aforesaid cleaning job, I


went to the janitors quarters in the outer part
of the University of San Agustin Gym where I
and one of my co-workers, KEVIN ANGELO
BUYCO, had a drinking session;
d. That at about 8:45 in the evening of July 11,
2015, after drinking 1 bottle of Red Horse each,
I and my co-worker, Kevin Angelo Buyco,
decided to leave the janitors quarters and drink
in Andoks Manokan located in Molo, Iloilo City;
e. That at about 9:20 in the evening of July 11,
2015, we arrived at Andoks Manokan and
ordered 1 bucket of Red Horse beer and ordered
2 more buckets of Red Horse beer after the first
bucket was consumed;
f. That I and my co-worker continued to drink until
it was already 2:30 in the morning;
g. That I was very drunk during such drinking
session that I have to ask my co-worker, Kevin
Angelo Buyco, to bring me home because it was
quite impossible for me to go home on my own;
h. That I was able to arrive at my house in
Mandurriao, Iloilo City, accompanied by Kevin
Angelo Buyco, at about 3:15 in the morning;
i. That it is physically impossible for me to commit
the crime charged because I was in Andoks
Manokan in Molo, Iloilo City at about 9:20 in the
evening of July 11, 2015 up to 2:30 in the
morning of July 12, 2015;
5. The allegations stated in the Affidavit-Complaint are
mere fabrications by the complainant which may have
been spurred by her insanity;
6. I am executing this Counteraffidavit for the purpose of a
ttesting to the truth of the foregoing statements, to
inform the proper authorities of the above facts, to

support my prayer for the dropping or dismissal of the


instant case against me and for whatever purpose this
may serve best.

IN WITNESS WHEREOF, I have hereunto set my


hand this 5th day of September, 2015 at Iloilo City,
Philippines.
DONI JUNE V. ALMIO
Affiant
SUBSCRIBED AND SWORN TO before me this 8th
day of March, 2010 in Davao City, Philippines.
ELIZABETH DYHN A. CABUNAGAN
Asst. City
Prosecutor
CERTIFICATION
This is to certify that I have personally examined
the herein affiant and that I am satisfied that he
voluntarily executed and understood his statements in
this Counter Affidavit.
ELIZABETH DYHN A. CABUNAGAN
Asst. City
Prosecutor

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