Republic of the Philippines )

Province of Bataan ) s.s.

Balanga City )
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AFFIDAVIT OF WITNESS

I, Manalansan Bartolomo, of legal age, with office address at

HLDC Corporate Center, 43-35 Don Bonifacio Avenue, Pulung
Maragul, Angeles City, Pampanga after having sworn in accordance
with law, do hereby depose and state THAT:

1. I am a security guard at Fiesta Communities Incorporated

(FCI) and currently assigned in the ground, covering Lot 31-D and Lot
31-E, Barangay Balsic, Hermosa, Bataan.

2. Approximately, around 7:35 pm of March 11, 2020, I was

on my usual duty, when Crisanto Awitan, Operation Manager of Excel
Homes, and Abellera, Officer in Charge of Lasis Security Agency,
together with 10 armed security guards, and 20 workers entered Lot
31-D and Lot 31-E belonging to FIESTA COMMUNITIES.

3. That I was shocked by their number and was intimidated

by their presence because at nighttime there were persons moving in
front of me, and some were carrying guns, shovels, bows and other
materials for fencing.

4. I asked one security guard belonging to Lasis security

what is their purpose in entering the land, and he said “just talk to our
official”. Later on, the official identified himself as Abellera, officer in
charge of Lasis Security Agency. He said that they will erect a fence
and told me to go away, otherwise “something might happen”.

5. I told Abellera that the land belongs to FCI, but such

refusal failed, as they started to erect fence consisting of barbed
wires.

6. Upon seeing their doings, I took pictures regarding their

actions but I was warned heavily that I should not go near the place
they were trying to fence or something might happen to me.

7. Later that evening I observed that 1 guard house of our

security team was taken and brought by the intruding security guards.
To add more, the workers of Excel homes took concrete pipes of FCI
and used them for building their tents.

8. Also, I observed that there were materials and equipment

left by FCI in the premises. Hence, such materials were trapped
inside the fenced area.
 9. I executed this affidavit to attest the truth of the foregoing
facts and to support the filing of Criminal Cases of Robbery and
Usurpation of Real Rights in Property against the officers, workers,
and president of Excel Homes, as well as the security guards of Lasis
Security Agency for conspiring, confederating and mutually helping
the former in the commission of unlawful acts.

AFFIANTS SAYETH NAUGHT.

IN WITNESS WHEREOF, I hereunto affixed my signature this

___day of ____________ at ____________, _______________.

_______________________
Affiant

SUBSCRIBED AND SWORN to before me this ___ day of

_______ at _______________. I HEREBY CERTIFY that I have
personally examined the herein affiants and I am satisfied that they
voluntarily executed and understood their given affidavit.

_____________________
Administering officer