Republic of the Philippines

REGIONAL TRIAL COURT

11TH Judicial Region
Branch 1
Tagum City, Davao del Norte

THE PEOPLE OF THE CRIMINAL CASE NO. 27804,

PHILIPPINES 27805 and 27809
Plaintiff,

-versus- For: VIOLATION OF SECS. 7,13

AND 14 ART. II OF R.A. 9165
FELICISIMO NUEZ KNOWN AS THE
BERNARDINO, JR., COMPREHENSIVE
Accused, DANGEROUS DRUGS ACT OF
2002
x-------------------------------x

JUDICIAL AFFIDAVIT OF VENNA BANDOLON

I, VENNA BANDOLON, of legal age, Filipino, and living at

Purok Uraya, Brgy. Mankilam, Tagum City, Davao del Norte, after
having been duly sworn to in accordance with law, hereby depose
and state:

PRELIMINARY STATEMENT

The person examining me is ATTY. LYNDON MELVI C.

SUMIOG, with office address at Retardo Law Office, 2 nd fr., Lagunzad
Bldg., Osmena St., Tagum Cty, Davao del Norte. The examination is
being held at ___________________. I am answering his questions
in Cebuano, a dialect I understand, fully conscious that I do so under
oath and may face criminal liability for any false testimony and
perjury.

PURPOSE: This Judicial Affidavit of VENNA BANDOLON, is

executed to serve as her direct testimony in the instant case. It is
being offered:

A) To prove that there was NO actual “buy-bust’ operation that

took place on September 18, 2021 in Uraya, Mankilam, Tagum
City, Davao del Norte;
 B) To prove that the house she was living in at Uraya, Mankilam,
Tagum City is their family dwelling and not a drug den;
C) To prove that there was merely a frame-up at night of
Septmeber 18, 2021;
D) To state the true events transpired at the time of the alleged
arrest;
E) all other matters, facts and circumstances to which his
testimony relates.
.

QUESTION 1 (Q1) : Before we start ma’am, this counsel

should remind you that you are under
oath. Do you understand?

ANSWER 1 (A1) : Yes, Sir. I understand.

Q2 : Is the taking of your affidavit voluntary?

A2 : Yes, it is, Sir.

Q3 : Do you know that you may face criminal liability for

false testimony or perjury for any false statement you
make herein?
A3 : Yes, Sir.

Q4: Kindly state your name and other personal

circumstances.
A4: I am Venna Bandolon, single, of legal age, and a resident
of Uraya, Mankilam, Tagum City, Davao del Norte.

Q5: Where were you in the night of September 17, 2021?

A5: I was at our house in Uraya together with my common-
law husband, Jayson, our two children Vea, five (5) years
old, Kyle, two (2) months old, and Josephine, my
husband’s sister and her boyfriend Jay;

Q6: Can you describe to me what had transpired on the night

of September 17, 2021?
A6: About past 8 o’clock in the evening of that night, while I
was at the sala with my daughter playing with her

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 cellphone and my husband playing with his computer, we
were bothered by the noise of our dogs. I told my
husband to check it out but before he could open the
door, a group of armed men suddenly barged in and
pointed their guns at us. Three (3) of them continued to
point their guns at us in the presence of our 5-year old
daughter while the others entered our bedroom where my
husband’s sister, her boyfriend and our other 2 months
old child were there. There were also men who went
around our house;

Q7: Did you happen to know who were these men and what
are their purpose?
A7: When I asked them who they are and what are their
intentions, they did not answer;

Q8: What happened next, if there’s any?

A8: My husband told his sister to call their uncle but all of our
cellphones were then confiscated. After that, they brought
us all in one room except my husband and Jay. Both of
them were brought to another room. After a while, they let
Jay joined with us in our room.

When another armed man entered back at our room, I

once again asked him about their true intentions at our
house. He just answered that we already know who they
are looking for, especially me, because I am one of their
targets. He then looked for a certain “Kloy-kloy.” When I
told him that I don’t know any Kloy-kloy, he clarified that
he’s also known as Jeffrey. I replied I don’t know the
whereabouts of Jeffrey anymore since it has been a long
time that he visited our house.

Q9: So you knew this certain Jeffrey?

A9: Yes, I know him. He frequently comes at our house but it
was a long time ago already. I have no idea where Jeffrey
is now.

Q10: What happened next, if there’s any?

A10: They brought me outside the room to talk to me and
instructed me to open my cellphone. When I hand it over
back to them, they read the messages in my cellphone.

Q11: Who were with you in that room?

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A11: The armed men. My husband was also there.

Q12: What were they doing with your husband at that moment?
A12: They asked him questions and every time they do not like
his answers, they would hit him.

Q13: Where would they hit him and for how many times?
A13: Sometimes on his stomach, chest or back area. I cannot
remember how many times but just everytime he
answered that they do not like the answer, they would hit
him.

Q14: What about you, what were they doing with you, if there’s
any?
A14: They asked me again about Jeffrey and the last time that
I saw him. I told them that I think it was over two (2)
months ago because I remember the last time Jeffrey was
here, I was still pregnant at that moment. That’s when one
of the gunmen interrupted me and told me that they were
monitoring us for two (2) months.

Q15: Were you aware of this monitoring?

A15: No, Sir.

Q16: What happened next, if there’s any?

A16: One of the gunmen ordered me to contact Jeffrey via
Messenger and invite him to the house.

Q17: What did Jeffrey say?

A17: I was not able to contact him. He was offline. I also
cannot call him via messenger. I tried several times but to
no avail.

Q18: What did the gunmen say when you were not able to
contact Jeffrey?
A18: They told me to find a way to contact Jeffrey or else I will
also be charged together with my husband.

Q19: So, what happened after that, if there’s any?

A19: I did not stop trying to contact Jeffrey. While I was busy
with my cellphone, some of the gunmen were searching
our things and put on top of the table when they found
scissors, lighter, cutter and cigarettes. They then
instructed me to go back inside the room.

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Q20: What happened inside the room, if there’s any?
A20: One of the gunmen went inside the room and asked for
the location of husband’s things. When I told them where,
they seized it and brought it at the living room and
instructed us to go to just go to sleep.

Q21: So when he left you inside the bedroom, what happened

next, if there’s any?
A21: Me and my companions just sat there and wait for their
further instructions. We cannot go to sleep because we
were trembling out of fear. We just observed on what was
going on outside.

Q22: Can you describe your observations?

A22: We heard someone at the back of our house calling at his
cellphone. I heard him saying “isa ray naa diri.” I also
heard dragging of our furniture in the living room as of
they were rearranging it. After a while, I heard several
cars coming and going at our house and its doors
slamming open and close and our front door opening and
closing as if there were several persons were entering
and leaving our premises. I even heard a woman crying
from the living room whom I have no idea who.

Q23: What else, if there’s any?

A23: After several hours, I heard a loud voice shouting
“Positive! Positive! Dapa! Dapa!” Then I heard someone
reciting something in Tagalog.

Q24: Were you not able to see what was happening outside
your room?
A24: I did see, eventually, sir.

Q25: How?
A25: My husband’s sister asked the men to let us out from our
room to pee. At first, they did not allow us to, but after
several negotiations, they did eventually.

Q26: What did you see at the living room then?

A26:

Q15: Do you confirm the truth and veracity of all the allegations
contained in this judicial affidavit?

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 A15: Yes, I confirm and I am willing and able to testify in court
regarding the contents of this judicial affidavit.

Q16 Is there anything else you want to say?

A16 : No, sir.

Examining Lawyer: AFFIANT FURTHER SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto set my hand this

_________________ in Tagum City, Davao del Norte.

FELICISIMO N. BERNARDINO JR.,

Affiant

SUBSCRIBED AND SWORN TO before me this

_____________________ in Tagum City, Davao del Norte, affiant
exhibiting to me sufficient evidence of her identity.

Doc. No.______;
Page No.______;
Book No.______;
Series of 2021.

SWORN ATTESTATION OF THE EXAMINING LAWYER

I, LYNDON MELVI C. SUMI-OG, after having been duly sworn

to in accordance with law do hereby attest:

That I conducted the examination of the witness who executed

the foregoing judicial affidavit; that I faithfully recorded the questions I
asked and the corresponding answers that the witness gave; that
neither I nor any other person then present coached the witness
regarding her answers.

Done this _____________, in Tagum City, Davao del Norte,

Philippines.

LYNDON MELVI C. SUMI-OG

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 Examining Lawyer

SUBSCRIBED AND SWORN TO before me, this

_______________ at Tagum City, Davao del Norte, affiant exhibiting
to me sufficient evidence of her identity.

Doc. No.____
Page No.____
Book No.____
Series of 2021.