Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Talisay City, Cebu
Branch 1

PEOPLE OF THE PHILIPPINES

Plaintiff,

-versus- CRIM. CASE NO. 17905

For: GRAVE THREATS

EDWIN CABILUNA a.ka. BOY

EDWIN CABILUNA, JR. a.k.a.EDWIN,
CLIFFORD CABILUNA
Accused
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COUNTER-AFFIDAVIT

I, EDWIN CABILUNA, Filipino, of legal age, married and a resident

of Brgy. Tapul, Talisay City, Cebu, after having been sworn in accordance
with the law, hereby depose and state:

1) That I am the accused who was WRONGFULLY,

MALICIOUSLY and CAPRICIOUSLY charge in the above
captioned case filed by complainant;

2) That I vehemently deny, belie and refute the false accusations

levelled against me in the affidavit-complaint executed by
JEWARSKIE EGO-OGAN, as the same is designed to pursue me
in the false hope that, for fear of litigation, I would succumb to
their iniquitous, undeserved and dissolute demand;

3) That the allegations contained in the complaint affidavit are all

lies;

4) That there is no truth of the matter that I, my son Edwin and my

son Clifford were conspiring in inflicting harm towards the
complainant. There is no truth also to the fact that we were armed
with bolo and threaten the complainant to kill him;

5) The truth of the matter is that on June 14, 2020 at 12:30 o’clock in
the afternoon, my son went to the volleyball court and he saw the
complainant Jewarskie Eo-ogan. He approached Jewarskie and told
1
 him to go home inorder to avoid confrontation with me because he
was challenging me into a fist fight;

6) After my son said that to Jewarskie, he got a stone in the ground

and came towards him;

7) That my run towards our house after he tried to throw a stone on

my son;

8) In sum, the instant complaint was clearly filed for purposes of

exasperating me or for any other malicious reason;

9) That based on the foregoing glaring factual truths, the undersigned

respondent only begs that this case be treated for what it really is, a
criminal suit without basis in fact and in law;

10) I further reserved the further presentation of other evidence,

documentary or otherwise;

11) This affidavit is executed to attest the truth of the foregoing facts
and to support my plea for the outright dismissal of the instant case.

IN WITNESS WHEREOF, I have hereunto set my hand this __ day

of _____________________ 2020 at _____________, Philippines.

_________________________________
EDWIN CABILUNA
AFFIANT

SUBSCRIBED AND SWORN to before me this __ day of ________2020

at____________________.

______________________
City Prosecutor