Republic of the Philippines)

Province of Isabela )s.s.

Municipality of Cabagan )

COUNTER-AFFIDAVIT

I, PEDRO BALISI y TULIAO, of legal age, married and a resident of

Bungad, San Pablo, Isabela, after having been duly sworn to in accordance with
law, hereby depose and say:

1. That I’m the respondent in the criminal complaint with NPS Docket No.
II-04-INV-21D-00440 for Acts of Lasciviousness in relation to RA No.
7610;

2. That I deny the all the allegations stated in the complaint of the Valerie
Banguel y Larsen;

3. The truth of which is that on April 14, 2021 at around 7 o’clock in the
morning, I went out to buy cigarette. While it is true that I saw the
complainant Banguel in the store owned by Anastacia Frogoso. That I
was pulling my from my pocket when the complainant walked towards
the counter to get the things she bought. As I was pulling my hand, the
back of my hand accidentally touched her back but not her butt;

4. After I bought my cigarette, I went back home. The complainant

likewise went home. She did not scream complain or said anything to
me. She did not say anything to Anastacia Frogoso;

5. There is no truth to her allegations. The filing of this complaint is an act

of harassment and as leverage to the criminal complaint of rape filed by
my daughter Cinderella Balisi against Juan Laman, Sr., the uncle of
herein complainant. My daughter was raped inside our bathroom by her
uncle Juan Laman and as a result of the said heinous crime, was
daughter is now pregnant. Attached hereto is the copy of complaint
docketed as NPS Docket No. II-04-INV-20K-01157 as Annex “A” and
the resolution dated January 18, 2021 as Annex “B”;

6. Juan Laman Sr., was arrested and is now under the custory of BJMP
Cabagan. The father of herein complainant and Juan Laman Sr are
relatives and it is known in the community that they are determined to
file a case against me since my daughter is determined to prosecute
 the rape case she filed against Laman. They tried several times to settle
the rape case amicably but as a father I will never agree as my 15 year
old daughter’s future is trashed by Laman. He even publicly humiliated
my daughter in the barangay telling the public that my daughter is his
girlfriend which is not true. My daughter is now pregnant, helpless and
depressed because of the defloration, humiliation and destruction
caused by Lam who is a rapist and a criminal. Matias Banguel even
went inside my house and furiously told me that her daughter will file
this case against me as leverage to the rape case filed against Laman.
Attached hereto is the affidavit of Salvacion Taguinod as proof that the
true intention of this complaint is to harass me and my daughter and
that there is no truth to the allegations of complainant Banguel.

7. That I’m executing this counter-affidavit to attest the truth of the

foregoing statement and for the purpose of seeking for the outright
dismissal of this case filed by the complainant against me.

IN WITNESS WHEREOF, I have hereunto set my hand this 18 th day of

May, 2021 at Cabagan, Isabela.

PEDRO BALISI
Respondent/Affiant

SUBSCRIBED AND SWORN to before me this 18 th day of May, 2021 at

Cabagan, Isabela.

Copy Furnished:

Valerie Banguel Y Larsen – Bungad, San Pablo, Isabela

Republic of the Philippines)
Province of Isabela )s.s.
Municipality of Cabagan )

AFFIDAVIT

I, SALVACION SILVA TAGUINOD, of legal age, married and a resident

of Bungad, San Pablo, Isabela, after having been duly sworn to in accordance
with law, hereby depose and say:

1. That I’m the same person executing this affidavit voluntarily;

2. That all the allegations stated in the complaint of the Valerie Banguel y
Larsen against Pedro Balisi are not true;

3. The truth of the matter is that on April 14, 2021 at around 7 o’clock in
the morning, Pedro Balisi, my father in law went out of the house and
crossed the street out to buy cigarette in the store owned by Anastacia
Frogoso. The private complainant Vanessa Banguel was there also
buying something. I was outside and saw him while buying his cigarette
and right after went back to the house, I did not hear any commotion
nor any reaction from Vanessa Banguel.

4. After I bought my cigarette, I went back home. The complainant

likewise went home. She did not scream complain or said anything to
me. She did not say anything to Anastacia Frogoso;

5. We were shocked when Matias Banguel furiously shouted at my father

in law and went inside our house and hit the head of Pedro Balisi
several times. That was a day after Pedro Balisi allegedly touched the
butt of Valerie Banguel or on April 15, 2021 at around 8 o’clock in the
morning. He told my father in law that he will file the instant case as
leverage to the case Cinderella Balisi filed against Juan Laman Sr.

6. That I’m executing this counter-affidavit to attest the truth of the

foregoing statement and for the purpose of seeking for the outright
dismissal of this case filed by the complainant against Pedro Balisi.

IN WITNESS WHEREOF, I have hereunto set my hand this 18 th day of

May, 2021 at Cabagan, Isabela.
 SALVACION SILVA TAGUINOD
Respondent/Affiant

SUBSCRIBED AND SWORN to before me this 18 th day of May, 2021 at

Cabagan, Isabela.

Copy Furnished:

Valerie Banguel Y Larsen – Bungad, San Pablo, Isabela