Republic of the Philippines

Department of Justice
OFFICE OF THE CITY PROSECUTOR
Quezon City

JUANITA GIRL SAN JUAN,

Complainant

- versus - NPS DOCKET NO: V-08-INQ-15B-09999

For: Murder

PEDRO SAN PEDRO,

Respondent

x-----------------------------------------x

REPLY-AFFIDAVIT

I, JUANITA GIRL SAN JUAN, Filipino, of legal age, married, resident of

1901 Katipunan Avenue, Quezon City Philippines, respectfully submit hereunder,
my reply to the Counter-Affidavit of respondent PEDRO SAN PEDRO, to wit:

1. I am filing the instant Reply-Affidavit in order to accurately describe the

relevant events of April 3, 2017 and account for the actions of MR. PEDRO
SAN PEDRO that may establish his commission of the crime charged in the
instant case. The following are the unadulterated facts based on my personal
knowledge and observation.

2. My husband, JUAN SAN JUAN and I, were invited by Mr. PEDRO SAN
PEDRO, a family friend, to have a picnic at the Quezon City Memorial
Circle at 6:00 pm on April 3, 2017, to supposedly celebrate the 1st year
anniversary of their being business partners for the TRASH THAT JUNK
SHOP;

3. My husband and I arrived in Quezon City Memorial Circle at 6:15 pm,

bringing with us a picnic basket with Pan de Coco, Royal Tru Orange Soft
drinks, Chocnut luxury chocolates, and Fresh Taho, which was a favourite of
the respondent;

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4. Upon arriving at the Picnic Grove of the Quezon Memorial Circle,
Respondent was already waiting, with a picnic mat already laid and candles
and flowers set-up;

5. Respondent was wearing a white t-shit with a drawing of a fat man with a
caption that says: ANG TUNAY NA LALAKI WALANG ABS, and was
wearing red pants and black boots;

6. Respondent then asked my husband and I to take a walk around the garden
to which we agreed.

7. The respondent then, suddenly, out of nowhere took out a knife from his
front pocket, and stabbed my husband 3 times on the back, while shouting,
MANDURUGAS KA!;

8. My husband fell immediately, and I ran to him, and noticed that he was
already gasping for breath, and before expiring he said: I forgive him, thank
you, I love you, take care going home;

9. The respondent then started running, while some security guards chased
him;

10. The respondents alibi that he was in SM City North EDSA is false and
cannot overcome my positive identification of his person;

11. With the foregoing facts which prove treachery, I therefore most respectfully
pray that criminal information for murder case be now filed against PEDRO
SAN PEDRO as there is more than probable cause for his indictment. I am
executing this reply-affidavit to attest the truth of the foregoing and to
support my complaint for attempted murder case against the hearing
respondent.

12. I hereby expressly reserve my rights to file supplemental affidavit and

additional evidences in the course of the proceeding.

Affiant further sayeth naught

IN WITNESS WHEREOF, I hereunto affixed my signature below this

7th day of April 2017 in the City of Quezin, Philippines.

JUANITA GIRL SAN JUAN

Affiant

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SUBSCRIBED AND SWORN to BEFORE ME this 28th day of November 2015
in the City of Manila , Philippines. FURTHER CERTIFIES that I have
personally examined the herein affiant and was fully convinced that she freely
executed and understood the contents of this Reply-Affidavit

MINDA CANTON
City Prosecutor
Roll No. 22441-2009
IBP No. 904627-2/3/12
Quezon City MCLE Compliance III No. 0134501Issued on July 4, 2012

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