REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
BIÑAN CITY

ZURIANO N. MANALORA ,
Complainant,

vs.
I.S. No. 12345-15
WATSON F. ELEMENTARYO, For: Murder
Respondent.
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AFFIDAVIT-COMPLAINT

I, WATSON F. ELEMENTARYO, 56 years of age, married

and a resident of Block 30, Lot 9, Hamogany St. Purok
Deisysiete, Malaban, Biñan, Laguna, after having been duly
sworn in accordance with law, hereby depose and say that:

1. I am the respondent in a complaint filed by Zuriano

M. Manalora for Murder before the Office of the Provincial
Prosecutor of Biñan, Laguna under I.S. No. 123456-15;

2. I vehemently deny the accusations against me for

being false, without basis and with malice, the truth being as
follows:

2.1. I am the incumbent barangay chairman of Malaban,

Biñan, Laguna;

2.2. As a neighbor and the barangay chairman, I was

invited in a birthday party of ____ on February 14, 2016;

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 2.3. I arrived at the birthday party at 7:00 o’clock in the
evening and immediately was asked to have something for
dinner;

2.4. As there were other guests invited who were also

from our barangay, I mingled with them and stayed at the
party for about two (2) hours;

2.5. I left the place together with some of our barangay

councilors who also attended the party at about 9:00 in the
evening and proceeded to the barangay hall;

2.6. I stayed at the barangay hall for a while and I left for
home leaving the barangay councilors on duty at that time at
the barangay hall and I proceeded home to sleep;

2.7. I was not advised of the incident of death of one

Simeonette M. Manalora who was allegedly assaulted on the
evening of February 14, 2015, however in the early morning of
February 15, 2015, upon learning of the incident, I
immediately went to the house of the Manalora Family and
extended help;

3. It is not true that I went to the father of the victim,

Zuriano Manalora to borrow money from him but I went to
him at about 10:00 in the morning to talk to him for his
assistance in the on-going barangay project to which he
agreed;

4. I have no grudge against him as he has always been a

cooperating member of the barangay;

5. I have no knowledge nor participation in the death of

the Simeonette M. Manalora and I am willing to assist ther
family in searching for the culprit;

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 6. The councilors whom I was with at the time we were
at the party and the barangay hall are executing their
affidavits to show my innocence.

7. I request that this case be dismissed for being false

and lack of factual basis.

IN WITNESS WHEREOF, I have hereunto set my hand

this 25th day of March, 2015 at Biñan City, Laguna.

WATSON F. ELEMENTARYO
Respondent

SUBSCRIBED AND SWORN to before me this _____ day

of March, 2015 at Biñan City, Laguna and I FURTHER
CERTIFY that I have personally examined the affiant and I am
satisfied that he/she has read and personally understood the
contents of his foregoing Counter Affidavit.

IMBENTO NAME
Prosecutor II
Roll No. 51379-2006
IBP No. 808787-1/3/11
PTR No. 4128464- 1/3/11; Leyte
MCLE Compliance III No. 0013601
Issued on April 22, 2015

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