REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
MAKATI CITY

JUAN D. CRUZ,
Complainant,

NPS No. MKT-123-456

-versus-
For: Robbery with Homicide

PEDRO C. RODRIGUEZ,
Respondent.

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

COUNTER – AFFIDAVIT

I, PEDRO C. RODRIGUEZ, Filipino, of legal age, single, with residential address at 1234
Dreamhouses Village, San Mateo, Rizal after being duly sworn in accordance with law, do
hereby depose and state the following:

1. I am the respondent in the instant complaint;

2. I vehemently deny the allegations that the instant complaint has leveled against
me for lack of knowledge as to the truth of the said allegations, the truth being
that;
A. In the morning of May 16, 2019, I was at the place of my work in
San Mateo, Rizal where I work as a carpenter;

B. At about five (5) in the afternoon of May 17, 2019, I received a

call from my cousin informing me that the complainant has filed
charges against me for the crime of Robbery with Homicide;

C. I am the eldest of ten siblings and is sole breadwinner of the

family because my parents are both of old age and are sickly;

D. It is physically impossible for me to commit the crime charged

because I had been in San Mateo, Rizal since January 2000, working as
a carpenter to earn a living;

E. I have never seen the complainant nor have I been to or near the
vicinities of ABC Building, Makati City;
 F. I have never been employed at the 7/11 store across ABC
Building, Makati City;

3. The allegations stated in the Complaint-Affidavit are mere malicious fabrications

by the complainant.

4. I am executing this counter affidavit to attest to the truth of the foregoing

statements and to support for the dismissal of the case filed against me.

PRAYER
WHEREFORE, premises considered, it is respectfully prayed that the instant
criminal complaint be DISMISSED for lack of merit.
FURTHER, the respondent respectfully pray for such and other reliefs as may be
deemed just and equitable in the premises.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 19th day of May
2019, in Makati City, Philippines.

PEDRO C. RODRIGUEZ
Affiant

SUBSCRIBED AND SWORN TO before me this 19th day of May 2019, in Makati City,
Philippines, affiant having exhibited to me his TIN 123-456-78 as competent evidence of his
identity.
Miguel Capahi
Counsel for the Defense
Roll of Attorney No. 1234
PTR No. 5678, January 2015, Cebu City
IBP No. 91011, January 15, Cebu City
MCLE Compliance No. I-121314 – 10/21/16
Doc. No. 2
Page No. 2
Book No. 3
Series of 2019.

CERTIFICATION

I HEREBY CERTIFY THAT I have personally examined the affiant and I am satisfied
that he voluntarily executed and understood his own affidavit.

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 Miguel Capahi
Counsel for the Defense
Roll of Attorney No. 1234
PTR No. 5678, January 2015, Cebu City
IBP No. 91011, January 15, Cebu City
MCLE Compliance No. I-121314 – 10/21/16

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