Republic of the Philipines

Department of Justice
Office of the Provincial Prosecutor
Lagawe, Ifugao

I.S. NO. II-08-INV-161-2011

COUNTER AFFIDAVIT

I, KELLY LIKIYAN, of legal age, married, presently the METER READER

OF THE IFELCO KIANGAN SUBSTATION, after having been sworn to under
the law, depose and state:

1. That I am a permanent employee of the Ifugao Electric Cooperative,

Inc. (IFELCO), appointed as the Meter Reader of the IFELCO Kiangan,
Ifugao Sub-station.(Copy of the IFELCO appointment hereto attached
as Annex “1” as part hereof)

2. That the IFELCO with principal office at Poblacion East, Lagawe, Ifugao
Province is a private electric utility cooperative.

3. That as part of my duties and functions, and as an agent of the IFELCO,

I am authorized to discontinue the electric service of any consumer in
my area who is in arrears in the payment of his electric consumption.

4. That as head of the Kiangan IFELCO Substation, I had been in the

campaign to inform the consumers of their faithful payment of their
electric consumption and of the provisions of the anti-electricity and
electric transmission lines/materials pilferage act of 1994.

5. That among the registered electric consumers of Poblacion, Kiangan,

Ifugao is a certain FELIPE BINUHE.

6. That in the records of the IFELCO, this FELIPE BINUHE WAS found
TWICE to have illegally reconnected to the power lines of IFELCO after
having been disconnected due to unpaid electric bills.
7. That disconnections from the power lines, are effected by the IFELCO
meter readers as part of their official functions.
(Copy of the Consumers Subsidiary Ledger of FELIPE BINUHE hereto
attached as Annex”2” and “2-A” hereof.)

8. That in cases of in flagrante illegal connections and unauthorized

reconnections, the meter readers are authorized to immediately
disconnect the electric service and/or retrieve the electric meters
provided for by the IFELCO. The electric meters, upon installation for
the consumers use, remain as property of the IFELCO despite the cash
deposit made by the consumer.

9. That the electric consumer_FELIPE BINUHE was twice caught in

flagrante to have connected to the service wires of the IFELCO without
the consent of the IFELCO.

10. That the retrieval/confiscation of the electric meter by the IFELCO

AGENT in the person of KELLY LIKIYAN was done to stop the illegal
reconnection of and to avoid the losses of IFELCO through pilferage.

11. That I am executing this sworn statement to answer the unfounded

charges of__________________________and to initiate a criminal
case against FELIPE BINUHE-for violation of RA 7832.

KELLY LIKIYAN

SUBSCRIBED AND SWORN to before me this _____ day of

_________________, 2016 at Lagawe, Ifugao.