PROSECUTOR ANNA LIZA S.

PUEDA-GALVEZ
Investigating Prosecutor
Office of the Provincial Prosecutor of Iloilo
Iloilo City

Greetings:

I am formally filing my Counter-Affidavit in I.S. Nos. VI-II-INV-

19L-01294 for Violation of RA 9262 filed by Jessica Ladon pending
before your office for Preliminary Investigation.

Iloilo City.

February 14, 2020.

Very truly yours,

JOHANSEL MORENO

Copy furnished by registered mail:

Jessica Ladon
Brgy. Jibolo
Janiuay, Iloilo

Registry Receipt No. _______________

Dated: ___________________________

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REPUBLIC OF THE PHILIPPINES)
CITY OF ILOILO……………………) S.S.
x--------------------------------------------x

COUNTER-AFFIDAVIT

I, JOHANSEL MORENO, of legal age, single, Filipino and a

resident of Brgy. Cabatac, Maasin, Iloilo, after having been duly
sworn to in accordance with law do hereby depose and say:

1. That I am the Respondent in I.S. Nos. VI-II-INV-19L-01294 to

01297 for Violation of RA 9262 now pending investigation at the
Office of the Provincial Prosecutor of Iloilo;

2. That I vigorously and vehemently deny the invented and malicious

allegations in the affidavit of the complainant, particularly in
Answer 5. The truth of which is that it is the Complainant who
texted me earlier that day to meet her in Quix Mart. When we met
at said mart we had a conversation, and while talking someone
chatted her in Facebook Messenger. I asked her who was she
chatting to, she did not answer. I asked her for several times who
was she chatting to until she was annoyed and slap me out of
nowhere. After that I just keep quiet even though I feel humiliated
in front of many people. I never told her indecent words in
vernacular, nor slapped her for several times in the face;

3. That I likewise vehemently deny the allegations in the affidavit of

the complainant, particularly in Answer 7 for being baseless and
invented. The Complainant alleges that I destroyed her
belongings, particularly her dress, bags shoes, and a Samsung
S3 and because of that she called the police and I was arrested.
Although there were attached photos of the said items, it is still
highly probable that she was the oune who destroyed it, without
any attached affidavit of witness, who can corroborate it. In
addition, There was no attached Police Blotter Report regarding
the incident and my arrest on November 20, 2019 because in
reality there was none as it is a mere invented story by the
Complainant;

4. That I further vehemently deny the allegations in the affidavit of

the complainant, particularly in Answer 8. The complainant
alleged that she created an account through my cellular phone
without a password. This allegation is unbelievable as how can
she create a Facebook account without a password.

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5. That I vigorously and vehemently deny the baseless and invented
allegations in the affidavit of the complainant, particularly in
Answer 9. Me and the complainant had been in a romantic
relationship for so long. Being so, it is just normal to feel jealous if
you are into a relationship. But this jealousy is only jealousy and I
cannot inflict physical injuries to her.

6. That I vigorously and vehemently deny the invented and malicious

allegations in the affidavit of the complainant, particularly in
Answer 10. The truth of which is that I was only worried for her
because she arrived home at 1:00 AM. The day after she even
begged me to accompany her to their house in Janiuay. And after
a week, we even visited her mother in Capiz and stayed there for
a week.

7. That I also vigorously and vehemently deny the invented and

malicious allegations in the affidavit of the complainant,
particularly in Answer 11. The truth of which is that what I saw in
the conversation between the complainant and a police officer is
that the said police officer told the complainant to go to their
house in Cabatuan so that he can give her money and clothes.
And for that reason I was really jealous.

8. That I vigorously and vehemently deny the invented and malicious

allegations in the affidavit of the complainant, particularly in
Answer 12. The truth of which is that I also work in Aloha Place
Arrozcaldohan as a working student. Sometime in August 2019 I
only told her that next time she should wear decent clothes,
particularly in her lower garment because that time she was
wearing a micro short;

9. That I vigorously and vehemently deny the invented and malicious

allegations in the affidavit of the complainant, particularly in
Answer 14. The truth of which is that she has many chatmates
and she continuously entertain them. She has been doing it even
though we are still in a relationship. This triggered my jealousy
and out of it I told her some harsh words out of frustration. But I
never laid hands on her

10. That I am executing this affidavit in order to attest to the foregoing

facts and to request the Investigating Prosecutor, to dismiss the
case filed against me for being baseless substantiated by
fabricated lies and manufactured evidences.

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 IN WITNESS WHEREOF, I have hereunto set my hand and
affixed my signature this ___ day of February, 2020 at Iloilo City,
Philippines.

JOHANSEL MORENO
ID: ______________

SUBSCRIBED AND SWORN to before me this ____ day of

February, 2020 at Iloilo City, Philippines by affiant who has
satisfactorily proven to me his identity indicated below his name.
Affiant is known to me to be the same person who executed the
foregoing affidavit. I hereby certify that I have personally examined
the affiant and I am satisfied that he has freely executed the
foregoing affidavit and the allegations contained therein are fully
understood by him. I certify that I have personally examined the
affiant and I am satisfied that she voluntarily executed and
understood her affidavit.