REPUBLIC OF THE PHILIPPINES )

CITY OF ILOILO )S.S.

X---------------------------------------X

JOINT COUNTER-AFFIDAVIT

WE, NAME and NAME, of legal age, Filipino, and residents of

[address], after having been duly sworn to in accordance with law do hereby
depose and say that:

1. We are executing this affidavit to refute the allegations of Rufin

aCaliwan and Purita Limpio in their affidavits;

2. Rufina Caliwan known as “Pining” and Purita Limpio are lying under
oath because (1) despite the loud noise coming from the house of Pining, I
never went out from our house on September 4, 2014 and that (2) on the same
night, it was Pining who defamed, slandered, and threatened me as heard and
witnessed by our neighbors;

3. Rufina Caliwan alias Pining is known for her notoriety in our place;
for several instances we have seen her going home with different men, and
there was one instance when she was scandalized by the wife of one of her
men when the wife caught her husband leaving the house of Pining at around
6:00 o’clock in the morning, we are aware of this as we were outside our house
during the incident happened and I (Mario) was the one who pacified the wife
to refrain from making further scandal on the neighborhood. Pining used to
bring friends and drink outside her house whether or not there is a special
occasion and late at night when they get drunk they make a lot of noise and
sometimes her friends would run and shout on the street, waking up the whole
neighborhood;

4. Pining started to become aggressive and irritable towards us and our

other neighbors when we and some of the homeowners have talked to her
regarding the noise every time she hosted her untimely drinking sessions with
her friends on her lawn just outside her house;

4. The truth is that on September 4, 2014 at around 8:30 in the morning,

the peace of the neighborhood has been disturbed by the loud voices, laughing
and singing of Pining and her guests, which we later came to know that it was
due to her on-going birthday celebration.

5. Despite the disturbance caused by the noise, I (Ofelia) did not

anymore react to it to avoid any further misunderstanding with Pining and
because Mario was on duty at the Police Precinct, it was just me and our house
helper Rhodora Pasilona in the house;
~1~
 6. At around 10:30 in the evening of the same day, Rufina Caliwan,
apparently drunk, went out of her house with her guests. Facing our house,
she suddenly shouted the following slanderous, defamatory, and threatening
words in Tagalog Dialect, “HOY BUMABA KAYONG LAHAT DYAN.
ANONG GUSTO NIYO, BARILAN O BUGBUGAN? TAMA ANG SABI
NI DAHLIA MGA INGGETERA KAYO. MGA PANGIT KAYO. MGA
PUTANG INA NIYO. MASAMA ANG MGA UGALI NIYO. BUKAS
PAGLABAS NIYO PAGPAPATAYIN KO KAYO”, which when translated
into English it means, “Hey, all of you get down from there. What do you
want, shooting or mangling? What Dahlia said is true that all of you are
envious. You are all ugly. You sons of bitches. You are all ill-mannered.
Tomorrow, when you go out, I will kill you” referring to us, these slanderous,
defamatory, and threatening words were uttered in the presence of her guest
and heard and witnessed by our neighbors who were already outside their
houses;

7. Despite of her defamatory and threatening acts, we remained silent,

waited for Pining and her guests to return to her house and later on,we reported
the matter to officials of Barangay Malinong;

8. A Barangay Conciliation proceeding regarding the incident was then

set at 10:00 in the morning on October 14, 2014 at the barangay hall of
Barangay Malinong Village;

9. On September 7, 2014, Rufina Caliwan filed an administrative

complaint against me (Ofelia), however, the same was dismissed on
September 10, 2014;

10. On October 14, 2014, during the conciliation proceeding, Mario

was not present because he is on duty the Precinct, Pining was violent and was
raising her voice despite the repeated reminder of the Barangay Chairman Jose
Protacio del Rosario to avoid from shouting, and for several occasions, she
attempted to attack me (Ofelia) and Rhodora Pasilona, had she not been
prevented by the Barangay Kawagad who were present;

11. After the conciliation proceeding, I (Ofelia Ocampo) and Rhodora

were about to go home at about around 12:00 noon, when Pining suddenly
assaulted Rhodora Pasilona, while uttering, “Tarantada, putangina mo. Hayop
kang bata ka!” in English, “Idiot, son of a bitch. You kid, you’re an animal!”
referring to Rhodora, these defamatory words were uttered in the presence of
several Barangay Officials who were present during the entire incident;

12. Despite her attacks, I (Ofelia) saw Rhodora laying on the floor in
fetal position, protecting herself from the blows of Pining until Pining was
pulled away by the Barangay Officials;

~2~
 13. Thereafter, I (Ofelia) brought Rhodora Pasilona to Corazon Locsin
Montelibano Memorial Hospital to seek medical attendance for the injuries
she sustained;

14. Attached are the affidavits of our witnesses to expose the lies of
Rufina Caliwan and Purita Limpio;

13. I (Ofelia) never uttered any defamatory words neither did I

performed any slanderous act against Rufina Caliwan; I (Mario) never
threatened, in any manner, Rufina Caliwan.

IN WITNESS WHEREOF, we have hereunto affixed our signatures

this [date] day of [month], [year] at [place], Philippines.

NAME NAME
Affiant Affiant

SUBSCRIBED AND SWORN to before me this this [date] day of

[month], [year] at [place], Philippines and I hereby certify that I have
personally examined the affiant and that I am satisfied that she voluntarily
executed and understood the same.

~3~
REPUBLIC OF THE PHILIPPINES )
CITY OF ILOILO )S.S.
X---------------------------------------X

COUNTER AFFIDAVIT

I, [NAME], [age] years old, [citizenship], [civil status], presently

residing at [address], after having been duly sworn to in accordance with law,
do hereby depose and say:

1.I am executing this affidavit to refute the allegations of Rufina

Caliwan and Purita Limpio in their affidavits;

2. That Rufina Caliwan alias “Pining” and Purita Limpio are blatantly
lying under oath because (1) I and Mrs. Ofelia Ocampo never went out of the
house on the evening of September 4, 2014, that (2) on the said night, it was
Pining who uttered slanderous and threatening threats as witnessed and heard
by her guests and our neighbors, and that (3) it was in fact Pining who defamed
and assaulted me as witnessed by the barangay officials of Barangay
Malinong Village;

3. That I am working asa house helper of the spouses Mario and Ofelia
Ocampo for almost 5 years;

2. Rufina Caliwan is known for her ungainly reputation and for several
time, I have seen her going home with different men and I even witnessed an
incident early in the morning where she was confronted by a woman claiming
to be the wife of the man that was with her;

3. Pining used to bring guests in her house whether or not there is a

special celebration, and would get drunk and would shout and laugh in the
middle of the night, waking me and the spouses Ocampo;

4. The truth is, on September 4, 2014, at around 10:00 o’clock in the

morning, we heard loud voices from the house of Rufina Caliwan alias
“Pining”, when I went out to see what was happening, I saw that there were
many people there was a karaoke, I later came to know that it was the birthday
of Pining;

4. That on the same day, despite the noise and disturbance caused by
the loud noise, I noticed that Ma’am Ofelia Ocampo remained silent;

5. That at around 10:30 o’clock in the evening of the same day, I was
already in my room when I heard someone is shouting outside, I suddenly
went out of my room to peep on the window, I saw Rufina and 3 other people
standing outside her house, facing towards the direction of our house, while
she was uttering slanderous and threatening words in Tagalog Dialect which
runs like these, “HOY BUMABA KAYONG LAHAT DYAN. ANONG
~4~
GUSTO NIYO, BARILAN O BUGBUGAN? TAMA ANG SABI NI
DAHLIA MGA INGGETERA KAYO. MGA PANGIT KAYO. MGA
PUTANG INA NIYO. MASAMA ANG MGA UGALI NIYO. BUKAS
PAGLABAS NIYO PAGPAPATAYIN KO KAYO”, which when translated
into English it runs like these, “Hey, all of you get down from there. What do
you want, shooting or mangling? What Dahlia said is true that all of you are
envious. You are all ugly. You sons of bitches. You are all ill-mannered.
Tomorrow, when you go out, I will kill you” referring to all of us inside the
house, these slanderous and threatening words were uttered by Rufina in the
middle of the night and in the presence of her guest,and heard and witnessed
by the neighborhood;

6. That after shouting foul words and throwing threats, Pining went
inside her house with her friends and Ma’am Ofelia called the Barangay to
report the incident;

7. That on October 14, 2014 at 10:00 o’clock in the morning, Ma’am

Ofelia and I went to the barangay hall of Barangay Malinong Village;

8. While we were inside the barangay hall, Pining was very aggressive
and loud and from time to time she was forcefully pounding the table as
witnessed by the barangay officials;

9. At around 12:00 o’clock noon of the same day, after the proceeding
in the barangay and while I and Ma’am Ofelia were about to go home, Rufina
Caliwan rushed towards me and punched my jaw on the left side, I felt dizzy
and fell to the groundwherein she kept on throwing blows at me while uttering
defamatory the words in Tagalog dialect which are, “tarantada, putangina mo.
Hayop kang bat aka!” which means, “Idiot, son of a bitch. You kid, you’re an
animal!” referring to me, the incident and these defamatory words were
uttered by Pining and heard and witnessed by the Barangay Officials who
were present during the entire incident;

10. After Pining assaulted me,I was immediately brought by Ma’am

Ofelia to Corazon Locsin Memorial Hospital to seek medical attendance for
the injuries I sustained;

11. Because of the acts of Pining, I have felt humiliated and sustained
injuries my face and my elbow;

12. Attached are the Affidavits of my witnesses and the my medical

certificate to expose the lies of Rufina Caliwan and Purita Limpio;

IN WITNESS WHEREOF, I have hereunto affixed my signature this

[date] day of [month], [year] at [place], Philippines.

~5~
 NAME
Affiant

SUBSCRIBED AND SWORN to before me this [date] day of

[month], [year] at [place], Philippines and I hereby certify that I have
personally examined the affiant and that I am satisfied that she voluntarily
executed and understood the same.

~6~
REPUBLIC OF THE PHILIPPINES )
CITY OF ILOILO )S.S.
X---------------------------------------X

AFFIDAVIT

I, [NAME], [age] years old, [citizenship], [civil status] and residing at

[address], after to being sworn to in accordance with law hereby depose and
say that:

1. I am the neighbor of Spouses Mario and Ofelia Ocampo and Rufina

Caliwan as my house is located just across the street fronting the house of the
Spouses Ocampo;

2. I have been a resident of the Barangay Malinong Village for almost

30 years;

3. Sometime on March 2008, Rufina Caliwan bought and occupied the

house next to the Spouses Ocampo;

4.After her occupancy of the house, I noticed that Rufina Caliwan has
had many visitors and guests with her.In the evening, she seldom went home
without bringing friends and they would usually stay up late at night in her
front yard and drink alcoholic liquors;

5. Sometime in August 2012, at around 6 in the morning, I was

awakened by the shouting and pounding noise outside, I peeped at the window
and saw that a woman was in front of the house of Rufina Caliwan,
hysterically shouting and pounding on the door, then I saw Mr. Mario Ocampo
went out of their house and talked to the woman, moments later, I saw a man
came out from the door of Rufina Caliwan, pulled the woman inside his car
and left.

6. On February 2013, at around 10:00 o’clock in the evening, my sleep

was interrupted by the sound of crushing bottles, and woke up and peeped on
the window and saw Rufina Caliwan and her friends, somehow drunk, running
and throwing bottles of liquors on the streets, however, trying to understand
her single, young and free lifestyle and trusting that when things get out of
hand, my neighbor SPO4 Mario Ocampo will be there to respond, I did not
anymore bother to call the attention of the Barangay;

7. On September 4, 2014, at around 9:00 o’clock in the morning, loud

music coming from the house of Rufina Caliwan could be heard, I later on
found out that it was her birthday;

8. On the evening of that day at around 8:00 o’clock, there was still loud
music and noise from Rufina’s house, I was already disturbed for I was
already tired and sleepy, however, I forced myself to bed;
~7~
 9. At about 10:30 of the same evening, I was again awakened by the
noise coming outside,I turned on the lights and I peeped to the window, this
time, I saw Rufina and her friends standing outside her house, apparently
drunk again, facing the house of Mr. and Mrs. Ocampo, in the middle of her
words, I heard Rufina uttering, “Putanginaniyo…Pagpapatayinko kayo…”,
which when translated would me, “Sons of a bitch, I will kill you”, looking
towards the house of the Ocampos;

10. After her fiasco, Rufina and her friends went inside her house, Mr.
and Mrs. Ocampo did not come out of the house, nor was there any response
from them.

IN WITNESS WHEREOF, I have hereunto affixed my signature this [date]

day of [month], [year] at [place], Philippines.

NAME
Affiant

SUBSCRIBED AND SWORN to before me this [date] day of

[month], [year] at [place], Philippines and I hereby certify that I have
personally examined the affiant and that I am satisfied that she voluntarily
executed and understood the same.

~8~