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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


11th Judicial Region
Branch 24
Hall of Justice
Koronadal City, South Cotabato

PEOPLE OF THE PHILIPPINES

CRIM. CASE NO. 8321-24

Plaintiff,
-

versus

-for-

ANTHONY REGONIEL DELOS SANTOS

VIOLATION OF SECTION 5

And LETECIA DEQUILLO KONG

of ARTICLE 2 of RA 9165

Accused.
x---------------------------------------------x
JUDICIAL AFFIDAVIT
(Rule on Judicial Affidavit,
A.M. No. 12-8-8-12, September 4, 2012)

I.

PRELIMINARY INFORMATION.
A.

NAME AND OTHER PERSONAL CIRCUMSTANCES OF THE

Name

SPO1 Arden G. Lanaza

Age

35 years old

Address

Uhaw, General Santos City


1

WITNESS.

Occupation

Police Officer

Language

English, Tagalog and Bisaya

B.

LAWYER WHO CONDUCTED OR SUPERVISED THE EXAMINATION OF

THE WITNESS.
Name

Prosecutor SHIENA LOU B. AMODIA

Address

CITY PROSECUTION OFFICE


Hall of Justice, General Santos City

Place of Examination:

CITY PROSECUTION OFFICE ,


Hall of Justice, General Santos City

II.

OFFER.
The witness will testify on the arrest made to accused Anthony Regoniel Delos Santos and
Leticia Dequillo Kong for having possessed and traded illegal drugs. The testimony of

SPO1

Lanaza is being offered to prove the folllowing:


1. That he is a member of the Philippine National Police by profession;
2. That he will testify as one of the witnesses of the Prosecution;
3. That he is presently assigned at Regional Special Investigation and Detection Team,
Regional Investigation and Detective Management Division, PRO12, Tambler,
General Santos City;
4. That he is a member of the team who effected the arrest of the accused;
5. And to prove such relevant matters.

III.

JUDICIAL AFFIDAVIT PROPER.


I, SPO1 Arden G. Lanza, 35 years old, married, Filipino, and residing at Uhaw, General
Santos City, under oath, depose:
1.

Q Please state your name, age, residence, and occupation of the witness.
A I am SPO1 Arden G. Lanza, 35 years old, married, Filipino, and residing at
Uhaw, General Santos City, married, and a Police Officer.

2.

Q- Why are you here now?


A To give a sworn statement by way of a judicial affidavit, the same to
constitute as my direct testimony, in the above-captioned criminal case.

3.

Q-

For the record, please state the name and address of the Lawyer -Prosecutor who

is now conducting or supervising your examination and the place where the examination is
being held now?
A The Public Prosecutor for the plaintiff, Prosecutor Shiena Lou B. Amodia, is
conducting or supervising my examination now at his office at the City Prosecution
Office located at Hall of Justice, General Santos City.
4.

Q In what language do you want your examination to be conducted?


A This judicial affidavit is prepared in English. But I prefer that my cross
examination be conducted in Tagalog for my convenience and for clarity.

5.

Q Do you undertake to answer the questions to be asked of you, fully conscious

that you will do so under oath, and that you may face criminal liability for false testimony
or perjury?
A -Yes.
6.

Let us now proceed. Mr. Witness, what is your profession?

A - I am a bona fide member of the Philippine National Police.


7.

Q
A -

8.

What is your rank as member of the PNP?


PO2, Maam.

Q How long have you been in the service as police officer?


A - I have been in service for almost 13 years, Maam.

9.

Where are you designated, Mr. Witness?

A - I am currently designated at the Regional Special Investigation and Detection


Team, Regional Investigation and Detective Management Division, PRO12.
10.
and

Since when have you been a member of the Regional Special Investigation

Detection Team, Regional Investigation and Detective Management Division,

PRO12?
A 11.

Since 2008, Maam.

Q What were you doing on the 16th day of October 2012?

A 12.

Q
A -

13.

I was working, Maam.


What task were you assigned on that day?
I was tasked to be the arresting officer on the planned buy-bust operation.
How did you arrive to a plan of buy-bust operation?

A - We received an information from our Confidential Informant (CI) from


Koronadal City that he had closed a transaction on the delivery of illegal drugs
particularly selling of shabu.
14.

What were the names of the supposed sellers from whom the Confidential

Informant is supposed to buy shabu?


A - Alias Tony and alias Letty, Maam.
15.

Q Where did you conduct the buy-bust operation?


A - At Upper Balmores, Barangay General Paulino Santos, Koronadal City.

16.

Q What did you do after receiving such information?


A - I immediately informed PCI Maximo F. Sebastian Jr., our Chief Resident.

17.

Q And then?
A - PCI Sebastian conducted a briefing and gave tasking to each member of the
team.

18.

Q What was the tasking?


5

A -

I was tasked to be the arresting officer , PO2 Serrano as the Poseur Buyer

and PSI Alex Joe Orcajada as the team leader.


19.

Q And then?
A - PCI Sebastian gave PO2 Serrano a P1,000.00 bill marked money bearing
serial number HM931309 for the buy-bust operation.

20.

Q What did PO2 Serrano do with the money after?


A -

21.

He right-away marked the money with his signature, Maam.

Q What happened next?


A - It was already 8:35 in the morning of the same date, Maam, when we
coordinated with the office of Philippine Drug Enforcement Agency, Regional
Office-12, before proceeding with the buy-bust operation.

22.

Q What time did you arrive in Koronadal City?


A -

23.

We arrived at 1:30PM of that date, Maam.

Q Who were you with?


A -

The rest of the team, Maam, Police Senior Inspector Alex Joe Orcajada as

our team leader.


24.

Q What did you do upon arriving in Koronadal?

A - PSI Orcajada immediately called up Koronadal City Police Station for


coordination, while we met with our Confidential Informant and planned for a
buy-bust operation.
25.

Q And then?
A

- The entire team with our Confidential Informant proceeded to Upper

Balmores, Barangay General Paulino Santos, Koronadal City.


26.

Q What did you do when you arrive at the place?


A - We waited for the arrival of alias Tony and alias Letty beside the road,
while the rest of the team were just nearby strategically positioned in order not to
be detected by the subject persons.

27.

Q What time did the subject persons arrive at the agreed meeting place?
A - At around 2:15 PM of that date, Maam, riding in a black STX Yamaha
motorcycle. A photograph of the vehicle was also taken.
(Request for Marking of photographs of the vehicle as Exhibit A)

28.

Q How did you know that those persons were the ones you were expecting?
A - Because the people in the motorcycle, Maam, were male and female, and
they approached us. I was with our Confidential Informant and PO2 Serrano who
at that time acting as poseur buyer.

29.

Q And then what happened?

A - Our Confidential Informant introduced us to Alias Tony and alias Letty


who we later identified as Anthony Regoniel Delos Santos alias Tony, 30 years
old, single, and resident of barangay Caloocan, Koronadal City and Leticia
Dequillo Kong alias Letty, 43 years old, married, and resident of Klinan 5,
General Santos City.
29.

Q If you would be asked in the court to identify the accused, would you be
able to identify them?
A - Yes, Maam. Photographs of them were also taken after the arrest, Maam.
(Request for Marking of Photographs of the suspects as Exhibit B)

30.

Q So after confirming their identity, what happened next?


A - Alias Tony asked PO2 Serrano how much shabu would he buy. Then PO2
Serrano answered that hes buying worth P1,000.00.

31.

Q And then?
A - Alias Letty handed to Tony a small item which Tony gave to PO2 Serrano.

32.

Q Would you please describe that small item ?


A - It was a heat sealed transparent plastic sachet containing white crystalline
substance which I believed then as a shabu.

33.

Q Was it the same item that PO2 Serrano later marked as JS-1?
A - Yes, Maam.

34.

Q So, what happened next after Tony handed the shabu to PO2 Serrano?
A PO2 Serrano paid Tony with the P1,000.00 bill marked money.

35.

Q After payment, what happened?


A - We then introduced ourselves as police officers to Tony and Letty and
arrested them.

36.

Q May you tell us the procedure of the arrest?


A - Upon arrest, we appraise the accused of their constitutional rights under the
law in a dialect know and understood by them.

37.

Q Is there anything happened during the arrest?


A - We saw Letty surreptitiously drop a small item on the ground which I
immediately picked up and identified that it was another heat sealed transparent
plastic sachet containing white crystalline substance which I believed to be a
shabu,Maam.

38.

Q What did you do with the sachet you picked up?


A - I later marked it as AGL-1.

39.

Q And then?
A - PO2 Serrano also found another sachet in the possession of Tony upon
frisking, which we believed as another shabu.

40.

Q Moving on, what did you do after the apprehension?


9

A - In order to avoid leakage to our next operations, we immediately brought


the arrested suspects and the seized items to Koronadal Police Station stationed
at Koronadal City for the marking and inventory.
41.

Q Who were there during the inventory?


A The inventory and marking of the items seized from Anthony Regoniel
Delos Santos was made by PO2 Serrano in the presence of Jerwen Paglinawan of
Brigada News and Brgy. Kag. Albert Piato.

42.

Q I have here a photograph evidencing the presence of Jerwen Paglinawan


of Brigada News and Brgy. Kag. Albert Piato during the inventory and marking.
Do you signify the authenticity of this photograph?
A Yes, Maam.
(Request for Marking of Inventory Receipt of Confiscated/ Recovered Items
as Exhibit C)

43.

Q And then?
A After PO2 Serrano finished his inventory and marking, I also complied with
the inventory and marking of the evidence I seized from Letecia Dequillo Kong
alias Letty.

44.

Q I have here a copy of the Inventory Receipt of Confiscated/ Recovered


Items you executed as the apprehending officer. Please go over this document
and please tell this Honorable Court that it is the same Inventory Receipt of
Confiscated/ Recovered Items you were referring to. Is that your signature
below?
10

A Yes, Maam.
(Request for Marking of Inventory Receipt of Confiscated/ Recovered
Items as Exhibit D)
(Request for Marking of a Photograph taken during the Inventory and
Marking as Exhibit E)
44.

Q What were those items?


A One heat-sealed transparent plastic sachet containing white crystalline
substance believed to be shabu, and one unit Cherry Mobile Cellphone.

45.

Q What did you do after the inventory and marking of pieces of evidence?
A We brought the arrested suspects to Camp Lira, Jr. General Santos City
for booking and further documentation and later they were subjected to medical
examination at the PNP Regional Crime Laboratory Office-12, General Santos
City.

46.

Q How about the seized items?


A The pieces of drug evidence were likewise forwarded to PNP Regional
Crime Laboratory Office-12 for analysis.

47.

Q I have here a copy of the Chain of Custody Form you filled up as the
seizing officer. Please go over this document and please tell this Honorable Court
that it is the same Chain of Custody Form you were referring to. Is that your
signature below?

11

A Yes, Maam.
(Request for Marking of Chain of Custody Form as Exhibit F)

48.

Q Have you executed a Joint Affidavit as Apprehending Officer with SPO2


Serrano for the purpose of filing this criminal case?
A Yes, Maam.

49.

Q I have here a copy of the Joint Affidavit you executed with SPO2 Serrano,
you, as the apprehending officer. Please go over this document and please tell
this Honorable Court that it is the same Joint Affidavit you executed with SPO2
Serrano that you were referring to. Is that your signature below?
A Yes, Maam. This is the joint affidavit I am referring to. And the signature
is mine.
(Request

for

Marking

of

Joint

Affidavit

of

Poseur

Buyer/Seizing/Apprehending Officer as Exhibit G).

Xxx NOTHING FOLLOWS xxx


IN WITNESS WHEREOF, I have hereunto set my hand this 21 st of October 2012, in
General Santos City, Philippines.

SPO1 ARDEN G. LANAZA


Affiant

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SUBSCRIBE AND SWORN to before me, this 21st day of October 2012, affiant
exhibited to me her competent evidence of identity with the details shown above. I hereby
certify that I personally know herein affiant being my client, and after having personally
examined him, I am fully convinced that he has personally read and understood the foregoing
judicial affidavit and the allegations herein.

SHIENA LOU B. AMODIA


Associate Prosecution Attorney
Doc. No. __
Page No. __
Book No. __
Series of 2012.

REPUBLIC OF THE PHILIPPINES )


CITY OF GENERAL SANTOS.. ) S.S.

AFFIDAVIT OF ATTESTATION

The undersigned PROSECUTOR SHIENA LOU B. AMODIA of legal age, single, and
with office address in City Prosecution Office, Hall of Justice, General Santos City, under oath,
deposes and states:
1.

She is the lawyer who conducted/supervised the Affiant SPO1 ARDEN G. LANAZA
in the execution of her judicial affidavit;

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2.

She faithfully recorded or caused to be recorded the questions she asked and the
corresponding answers that the above-named witness gave;

3.

Neither she nor any other person then present or assisting her coached the witness
regarding the latter's answers; and
4.

She conducted the examination of the witness at her office located at the City
Prosecution Office, Hall of Justice, General Santos City;

5.

She execute the foregoing affidavit to attest the to the veracity of the foregoing facts
and for whatever legal purpose this may serve.
IN WITNESS WHEREOF, I have hereunto set my hand this 21 st of October 2012, in

General Santos City, Philippines.


PROSECUTOR SHIENA LOU B. AMODIA
Affiant
SUBSCRIBE AND SWORN to before me on the date and place above mentioned,
affiant having exhibited to me her Integrated Bar of the Philippines ID No. 12345. I also hereby
certify that I personally know herein affiant being a member of the same IBP Chapter.
WITNESS MY HAND AND NOTARIAL SEAL.
Doc. No. __
Page No. __
Book No. __
Series of 2012.

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