REPUBLIC OF THE PHILIPPINES }

CITY OF ILOILO } s.s.

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

COUNTER-AFFIDAVIT

I, JOSE REX T. CORDERO, of legal age, Filipino, married and temporarily

residing at Brgy. Ingore, Lapaz, Iloilo City, Philippines, after having been duly sworn to
in accordance with law, do hereby depose and state:

1. That I am the respondent in the case for Violation of RA 9262, otherwise known
as Anti-Violence Against Women and their Children, pending before the Office
of the City Prosecutor docketed as NPS No. VI-10-INV-11A-00066;

2. That I deny the allegations contained in the complaint impugning me of having

sexual infidelity and harassing the complainant in violation of RA No. 9262. The
truth of the matter being as follows:

a.

3. That we are the Complainants in the case for Frustrated Murder with the Use
of an Unlicensed Firearm pending before the Office of the Provincial Prosecutor,
Province of Iloilo, with I.S. No.s. VI-11-INQ-00484 to 00484-A;

4. That on October 12, 2010, respondent Ronnie Castaños filed his Counter-
Affidavit interposing in his defense a pure alibi by alleging that on the night of
September 24, 2010, he was at his house, about 300 meters away from the
scene of the incident, having dinner with Brgy. Tanod Ryan [Dosarab];

5. That on the scheduled date for submission of the Respondents’ Counter-

Affidavit, only Ronnie Castaños filed while the other two respondents failed;

6. That it must be taken into full consideration the long-line of cases decided by
the Supreme Court that alibi is the weakest defense as ruled in the cases of
Sumbillo vs. People of the Philippines, GR No. 167464, Jan. 21, 2010; People of
the Philippines vs. De Jesus, GR No. 93852, Jan. 24, 1992 and People of the
Philippines vs. Quinevista, GR No. 110808, May 31, 1995, just to name a few;

7. That to note, the house of respondent Ronnie Castaños is only 300 meters
away from the scene of the incident that would not render it improbable for
him to be in the place at the time of the commission of the crime;

8. That it is as well very dubious that respondent Castaños would use as a witness
a Brgy. Tanod of the said Barangay to underline upon the Investigating
Prosecuting Attorney the weight of his statements;

9. That the statement of the witness, Brgy. Tanod Ryan [Dosarab], is bereft of any
merit. In the Affidavit1 executed by Ryan Dosarab, he mentioned in paragraph
2 thereof that when he finally reached the place (house of Ricardo Cejar), he
saw Ricardo Cejar walking outside of their house and Rowen Paniza who was
carrying a bolo. This is very improbable since Ricardo Cejar has been shot
hitting his left abdomen with retained intact slug as shown in the Medico-Legal
Certificate attached in the Complaint. Thus, it is a fallacy to state that after
that incident Ricardo Cejar is just there walking outside of his house;

10.That further, in the same Affidavit of witness Ryan [Dosarab], he mentioned in

paragraph 3 thereof that when he arrived at the scene of the crime, he saw
none of the three accused at that certain point of time and place. Granting that
it is true, the accused were nowhere to be found because they immediately
escaped from the scene after that shooting incident as well explained in the
1
Affidavit attached to the Counter-Affidavit of Respondent Ronnie Castaños dated October 12, 2010.
Page 1 of 2
COUNTER-AFFIDAVIT
Jose Rex T. Cordero
NPS No. VI-11-INQ-11A-00066
 Complaint and that witness Ryan Dosarab only arrived later and was not on the
place when the shooting happened as stated in his Affidavit;

11.That also the Affidavit2 executed by Wilfredo Lastrilla is fictitious, fictional and
questionable. The truth of the matter is that Wilfredo Lastrilla was never on the
place when the incident happened. It is quite obvious that the Affidavit
executed by Ryan [Dosarab] is devised to excuse the three Respondents herein
and that of Wilfredo Lastrilla to impute who the perpetrator instead;

12.That nowhere in the Counter-Affidavit filed attached a Medical Certificate to

attest to the supposedly devastating effects of the mauling allegedly caused by
herein Complainant and Rowen Paniza against Levy Castillanes. Thus, the
allegations as to this effect are mere fabricated;

13.That non-inclusion of Respondent Ronnie Castaños in the Police Blotter Extract

cannot alone absolve him of the crime charged as Police Blotters are mere
entries of booking/recording of incidents relayed to the investigating police
officer who responded to the area. That to take note, police officers only
investigated after the incident and were never in the place when the incident
happened. Further, nowhere could be found in the Police Blotter Extract the
person/s who relayed the information to them. Thus, the Police Blotter Extract
is not a conclusive evidence to prove as to who the real perpetrators are that
will absolve Respondent Ronnie Castaños or any of the respondents herein;

14.That finally, we are the victims of a crime committed and not the perpetrators.
We suffered injury that in absence of any medical attention could be proved
fatal;

15.As such, we are executing this Reply-Affidavit to attest to the truth of the
foregoing statements and to pray upon the Investigating Prosecuting Attorney
to resolve the case against the herein Respondents for the crime of
Frustrated Murder with the Use of an Unlicensed Firearm and/or any
criminal case that may be filed as the evidence warrants.

IN WITNESS WHEREOF, I hereunto affix my hand this ___ day of _______, ___
in the City of Iloilo, Philippines.

JOSE REX T. CORDERO

Affiant

SUBSCRIBED AND SWORN to before me this ___ day of ____, __ in the City of
Iloilo, Philippines. Affiant exhibited to me his identification indicated below his name
as his competent proof of identity. I further certify that affiant attests to the truth of
the foregoing facts based on his own personal knowledge and I am satisfied that he
voluntarily executed and understood his Affidavit.

2
Affidavit attached to the Counter-Affidavit 0f Respondent Ronnie Castaños dated October 12, 2010.
Page 2 of 2
COUNTER-AFFIDAVIT
Jose Rex T. Cordero
NPS No. VI-11-INQ-11A-00066