REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE ASSISTANT PROVINCIAL PROSECUTOR
Hall of Justice
Hilongos , Leyte

REYSA GALADO CAGABHION,

Complainant,
NPS NO. VII-02f-INV-19A-00004
-versus- FOR: VIOLATION OF RA 9262
DRANREB CRISTINO,
Respondent.
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COUNTER – AFFIDAVIT

I, DRANREB D. CRISTINO, of legal age, single, Filipino and a

resident of Brgy. Tinago , Inopacan, Leyte having been duly sworn to
in accordance with law, do hereby depose and say that :

1. I am the Respondent in the instant Complaint for Violation of

Republic Act 9262 or the Anti-Violence Against Women and their
Children Act which is pending before the Office of the Assistant
Provincial Prosecutor docketed as NPS NO. VII-02f-INV-19A-00004;

2. I can be served with subpoena, and other notices of this

Honorable Office at our residential address in Brgy Tinago, Inopacan
, Leyte ;

3. On February 21, 2019, I received a copy of the complaint-

affidavit, and had full knowledge thereof for the first time.

ADMISSIONS & DENIALS

4. Paragraph 1 of the complainant’s Judicial Affidavit is hereby

admitted.

5. Paragraphs 2 and 3 of complainant’s Judicial Affidavit are

denied for lack of knowledge or information sufficient to form a
belief with respect to the truth of the matter.
 6. Answer to Question no 1 of the Judicial Affidavit is hereby
denied for lack of knowledge or information sufficient to form a
belief with respect to the truth of the matter.

7. Answers to Questions no. 2, 3, 4, 5, 7 and 8 of the Judicial

Affidavit are hereby denied for lack of knowledge or information
sufficient to form a belief with respect to the truth of the matter, the
truth of the matter is found in the counter statement of facts portion
of this counter-affidavit.

8. Answer to Question no. 6 is partly admitted with respect

only to the statement that she arrived on December 19, 2018 at
around 3:00 a.m. the rest are denied for lack of knowledge or
information sufficient to form a belief with respect to the truth of the
matter, the truth of the matter is found in the counter statement of
facts portion of this counter-affidavit.

COUNTER STATEMENT OF FACTS

9. On December 15, 2019, I arrived from my work so very tired,

my time of duty was 4: 00 a.m to 2: p.m. . The herein complainant
was very suspicious why I left the house that early, so in the
afternoon she went to Chowking where I worked , to check if I was
really telling the truth . She saw me on duty and even asked my
manager as to what time did I report, but prior to that she saw me
talking to somebody a woman - a customer, she felt jealous and
slowly provoking for an argument. I immediately asked my manager
that I have to go home because the jealousy of the complainant was
already annoying to the customers.

10. When we arrived in our place in Banilad Cebu, the

complainant did not stop her suspicion that I have a woman, she kept
on nagging and hitting me physically. I covered my head and my
face with both hands to protect me from her blows. I told her to stop
hitting and yelling me because at that time I really needed a rest, I
was so tired .I have no knowledge of the hematoma on her left arm
how she got it.

11. I will not be surprised if she had it by her own doing

because sometime in September 2018 she took 10 paracetamol tablets
thus, she was admitted in Perpetual Succour Hospital in Cebu. At
that time we also had argument and I left her, that’s why she
attempted suicide by taking 10 paracetamol tablets. It was a difficult
time for our family because my mother had to loan money from a
loan shark for hospital and other expenses in order to save her.

A copy of the Affidavit of my mother – Clemencia Cristino is

hereby attached as Annex A .Its contents are incorporated and made
part of this Counter Affidavit by way of reference.

12. When the complainant arrived on December 19, 2018 in

Inopacan she was not with our son, she was alone. If she was with
our son, the more that there is no truth of her allegation that I pushed
her because I would put my son in danger in that way.

A copy of the Affidavit of our neighbor Jomar Villamor is

hereby attached as Annex B. Its contents are incorporated and made
part of this Counter Affidavit by way of reference.

13. In most cases it was the complainant who physically

harmed me whenever she had fits of jealousy.

A copy of the Affidavit of our neighbor Pedro Betsoso Dandoy

Jr. is hereby attached as Annex C. Its contents are incorporated and
made part of this Counter Affidavit by way of reference.

14. The complainant has a very difficult personality and I’m fed
up with her attitude. In one occasion she hit me on the head with a
mirror.

15. The complainant would always resort to threatening me

that she will commit suicide if ever I will leave her.

16. If the complainant was truly been harmed and incurred

physical injuries because I boxed her in Cebu as she alleged, why did
she still follow me to Leyte.

17. If the complainant was in her right mind she could have
sought help from the Barangay to obtain Barangay Protection Order
instead of following me.

18. To date the complainant is texting me, she wants the case to
be settled, so that I will be spared from criminal prosecution saying it
was actually her parents who are interested in filing the case.
 19. In my part I ‘m willing to settle the case in the proper
authorities . I want her to understand that I don’t want to live with
her anymore.

IN WITNESS THEREOF, I have hereunto affixed my signature

this __________________________ at Hilongos, Leyte, Philippines.

DRANREB D.CRISTINO
Affiant/Respondent
VIN -3721-0035A-11194DDC 1000

SUBSCRIBED AND SWORN TO BEFORE ME this

________________, in Hilongos Leyte, Philippines. I hereby certify
that I have and translated to the affiant the contents of the Counter -
Affidavit in Cebuano dialect, and that I am convinced that the same
is executed freely and that he fully understood the contents hereof.

Doc. No._____;
Page No._____;
Book No._____;
Series 2019.

Explanation:

Copy of the foregoing Counter Affidavit was served upon the

Complainant via registered mail due to lack of messenger to effect personal
service.