Republic of the Philippines

Department of Justice
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
Pasay City

PEOPLE OF THE PHILIPPINES,

Complainant,

-versus- I.S. No. __________

For: Violation of Sec. 5
Article 2 of RA 9165 (Selling
of Dangerous Drugs

HAROUN AL-RASHID A. PANDAPATAN,

Respondent.

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

COUNTER-AFFIDAVIT

I, HAROUN AL-RASHID A. PANDAPATAN, Filipino, of legal age, and

with residence at 32 F. Victor St. Brgy. 62, Pasay City, after having been

duly sworn in accordance with law, hereby depose and state that:

1. I was charged by SPO4 KAREN PEARL CUE for violation of Sec. 5

Article 2 of RA 9165 (Selling of Dangerous Drugs);

2. I did not sell drugs and I vehemently deny all the allegations that

she has stated on her complaint- affidavit. There is no truth to the

charges being leveled at me. The statements of the complainant

and the witnesses are full of lies and were meant to extort money

from me;

3. The facts on the complaint affidavit that she has made against

me were merely fabricated stories because I refused to give in to

her demand of giving twenty thousand pesos (P 20,000.00);

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 4. On 8 August 2015 at around 10:30 P.M, I was at my friend ANVARI

F. ARGUELLES house in Emma St. Brgy. 57, Pasay City watching

basketball in the television. ARGUELLES asked me to buy a pack of

cigarette in the store.

5. While I was walking along Delas Alas St. to buy a pack of cigarette,

I was approached by P03 ANGELIQUE BIEN TIONGSON. At the time

she was wearing civilian clothing and was posing as seller of

cigarettes in the streets;

6. TIONGSON asked me if I wanted to buy cigarettes from her. Since

there is no nearby sari-sari store, I decided to just buy cigarettes

from her instead;

7. Upon giving TIONGSON the money, she placed something inside

my right pocket. I took it out and saw plastic sachet containing

shabu;

8. It was at that moment when CUE appeared and informed me that

this is a entrapment operation;

9. CUE demanded twenty thousand pesos (P20,000.00)from me or

else they will arrest me for selling drugs;

10. When I refused to pay the said amount, CUE placed handcuffs on

me and brought me to the police station;

11. I strongly believe that CUE filed the complaint to extort money

from me and to harass me;

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12. I am voluntarily executing this affidavit to attest to the truthfulness

of the foregoing facts and to support the outright dismissal of the

complaint filed against me.

AFFIANT FURTHER SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto set my hand this 12th day of

August 2015, in Pasay City.

HAROUN AL-RASHID A. PANDAPATAN

Accused/Affiant

SUBSCRIBED AND SWORN TO before me, this 13th day of August

2015 in Pasay City.

SUBSCRIBED AND SWORN to before me this 13th day of August 2015

in the city of Pasay. I further certify that I have personally examined the
Affiant and I am satisfied that he/she voluntarily executed and
understood his/her statement.

CARYL JANE VILLANOZA

Administering Officer

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2015.