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Tuguegarao City, Cagayan ) S.S.


I, JEFF TALATTAD, of legal age, single, and a resident

of Malibabag, Peablanca, Cagayan, after having been sworn
to in accordance with law, depose and say:

1. That on December 18, 2016 at around 9:00 in the

evening, while I was at home leisurely resting, I received
a text message from Antonio Paguirigan (hereinafter

2. That the content of the text message is that:

Pumunta ka dito sa Mango Suites may pag uusapan tayo.
which was then located at College Avenue, Caritan,
Tuguegarao City, Cagayan and I replied OK, magbibihis lang

3. That immediately, I drove my single motor vehicle

and proceeded to our agreed meeting place.

4. That when I was nearing the meeting place, I

slowed and I saw Antonio together with a handsome young man
standing at the other side of the road specifically at the
right side of the EastWest Bank College Avenue facing

5. That the area where they were standing was a

little bit dim but when I tried to watched with my naked
eyes, Antonios face was visible to me and I saw the
handsome young man wore a color red bull cap;

6. That I went straight ahead towards the parking of

the Mango Suites and parked my motor vehicle;

7. That thereafter, when I was about to alight from

my motor vehicle, I saw the handsome young man running
towards me and immediately pulled his gun and shot me (4)
four times;

8. That, immediately thereafter, Antonio and the

handsome young man escaped quickly from the crime scene
using a motor vehicle drove by Antonio;

9. That the plate number of the motor vehicle was

taken appearing that it was registered to a certain JAMES
MARIANO (hereinafter James) who was likewise identified by
one of the bystander witness. Copy of the Motor
Registration is attached as Exhibit A;

10. That when I fell off the ground unconsciously, a

bystander who saw the shooting incident took courage to
rescue me and rushed me to the nearest hospital for medical

11. That my gunshot wounds were operated by Dr.

Francisco Villaflor and I was confined at the Peoples
General Hospital Tuguegarao City, Cagayan from December 18,
2017 to December 27, 2017. Copy of the medical certificate
is attached as Exhibit B;

12. Based on the medical findings, the injuries I

sustained were fatal and without immediate medical
treatment it could have caused my death;

13. That I am executing this affidavit to attest to

the truth of the foregoing statements for the purpose of
charging the respondents with Frustrated Murder penalized
under Article 250 of the Revised Penal Code;

IN WITNESS WHEREOF, I have hereunto set my hand this

______day of _________________, 2016 at __________________.


SUBSCRIBED AND SWORN to before me this _______ day of

__________, 2017 at _________________.


I hereby certify that I have personally examined the

affiant and I certify further that he voluntarily executed
the foregoing complaint-affidavit and all the statements
and allegations made therein were understood by him.