Republic of the Philippines

Department of Justice
OFFICE OF THE PROVINCIAL PROSECUTOR
Hall of Justice-Carig, Tuguegarao City

JEFF TALATTAD, NPS-

Complainant, For

-versus- FRUSTRATED MURDER

ANTONIO PAGUIRIGAN and JAMES WILLIAM MARIANO

Respondents,

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

COUNTER AFFIDAVIT

I, Antonio Paguirigan Jr y Zalun, of legal age, Filipino citizen and a resident of #32 San
Roque Street, Pengue-Ruyu, Tuguegarao City, Cagayan, after having been duly sworn to in
accordance with law do hereby depose and state that:
1. I am one of the respondents in the criminal complaint for Frustrated Murder filed by Jeff
Talattad docket as ___.pending preliminary investigation before the provincial
prosecution office of Tuguegarao City, Cagayan;
2. In his sworn statement, the complainant alleged that while he was in Mango Suite to meet
with me, I conspiring with a certain John Doe ordered to shoot him several times with
intent of killing him using a pistol;
3. Specifically, I vehemently deny the imputation of Jeff Talattad that I ordered to shoot
him which caused his fatal injuries;
4. I vehemently deny the accusation of the private complainant as the same is false, baseless
and obviously a mere fabrication, designed to harass, inconvenience and discredit me, the
truth of the matter being that which is stated hereunder:
a. On December ___, at about 9:00 oclock in the evening, I texted the
complainant to meet me at Mango Suite with the intention to settle my
 remaining balance which is evidenced by a Contract of Sale hereto attached
and marked as Exhibit 4;
b. That when I proceeded to the Mango Suite, after alighting from my vehicle I
heard a gunshot fired which caused panic to me and to the public, prompting
at me to secure for safety and flee the area of incident;
c. That when the squabble subsided I returned to my vehicle and went home.
d. That I was informed, through the radio announcement of BOMBO RADYO
that the person shot was the Jeff Talattad, the person I was supposed to meet
regarding the sale of his vehicle.
5. I vehemently deny the accusations of the private complainant that I conspired with the
other accused in perpetrating the offense charged for I am not personally acquainted to
James William Mariano, however, Jeff Talattad was known to me personally because he
is the sales agent of second hand cars;
6. I have never owned nor have I fired a gun before;
7. Therefore, it would have been impossible for me to have committed the alleged wrongful
act imputed against me by the complainant; and
8. I am executing this counter-affidavit to attest to the veracity of the foregoing averments
and I am respectfully submitting the same in support of my prayer for the outright
dismissal of the instant case for lack of merit.

IN WITNESS WHEREOF, I have hereunto set my hand this___day of December 2017 at

Tuguegarao City.

ANTONIO Z. PAGUIRIGAN JR.

Affiant

SUBSCRIBED and SWORN to before me this____________day of December 2017 at

Tuguegarao City

MARIES M. ZALUN

Prosecutor

CERTIFICATION
 I hereby certify that I have personally examined the affiant and I certify further that he
voluntarily executed the foregoing counter-affidavit and all the statements and claims made
therein were understood by him.

MARIES M. ZALUN

Prosecutor