Sample Reply Affidavit (Criminal Case)

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Republic of the Philippines

Department of Justice
CITY PROSECUTION OFFICE
City of Muntinlupa

Docket No _____________
CATRIONA GRAY – BONDAD
Complainant,
For: Violation of R.A. 9262
- Versus - Violence against Women and
their Children
CLINT BONDAD
Respondent,
x--------------------x

REPLY - AFFIDAVIT

I, CLINT BONDAD, of legal age, Filipino and married to herein


Complainant, and a resident of Phase 5, Block 6, Lot 7, Tensuan Site,
Poblacion, City of Muntinlupa, after having been duly sworn in
accordance with law, hereby depose and state:

1. That I refute the allegations contained in the Complaint Affidavit


of herein Complainant for being founded on malicious belief and
mere baseless suspicions;

2. That I deny the allegation on Item no. 2 that I am legally married


to the Complainant. As seen on the attached marriage certificate,
our marriage happened in October 2009 with a marriage license
that was issued in January 2009. In the case of De Castro v De
Castro1, Supreme Court said that “ x x x the absence of any of
the essential or formal requisites shall render the marriage void
ab initio, whereas a defect in any of the essential requisites shall
render the marriage voidable''. Provided that our marriage
occurred 9 months after the issuance of our marriage license,
makes our marriage void from the beginning due to absence of

1
GR No. 160172 De Castro vs De Castro, February 13, 2008
an essential requisite. ; Attached herein as Annex “A” is the
Marriage License that was issued in January 2009.

3. That I admit having produced five (5) children namely, Ma. Venus
(15 years old), Shamcey (13 years old), Janine Mari (12 years
old), Ariella (9 years old), and Maxine (7 years old) and duly
acknowledged them as their father; Attached herein as Annex
“B1-5” are the copies of the Birth Certificates of the five children.

4. That I admit leaving my family in May 2018 to work in Saudi


Arabia as an Overseas Filipino Worker in my diligent attempt to
support my family.

5. That I deny the allegation in item no. 5 because I never stopped


attempting to communicate with my family. In fact, most often, I
reached out to Ma. Venus and ask her about the whereabouts of
the Complainant since she persistently refuses to answer my
calls.

6. That I even tried to contact my mother to ask her to try and figure
out why the Complainant is not responding to me and that is
when my mother informed me that the Complainant has been
having an extra-marital affair with my best friend Sam Milby.
Attached herein as Annex “C” is the statement of the
Respondent’s mother.

7. That the allegation in item no. 6 is nothing but a simulated


statement because ever since I was not able to reach out to the
Complainant, I have been sending remittances to my mother so
that she can convey my support to my children which the
complainant persistently refused to accept having believed that
the money does not come from me but from my mother’s own
pocket. Attached herein as Annex “C” is the statement of the
Respondent’s mother.
8. That I deny the allegation in item no. 7 because such an
allegation of the Complainant was a misinterpretation of what I
previously said. It is true that I previously forbade her to have a
job and be engaged in a professional occupation only because
during such time, she was pregnant with our fifth child and the
suggestion for her not to work does not originate from me but
from her doctor. Attached herein as Annex “D” is the medical
certificate of the OB-GYN putting the Complainant under Bed
Rest.

9. That I deny the allegation in item no. 8 because the Dental


Records could not validly and accurately prove that the five (5)
teeth were lost due to physical maltreatment and could easily be
lost due to natural causes.

10. That I deny the allegation in item no. 9 because the pictures of
the burn and the scars does not accurately and sufficiently prove
that the same are brought by physical maltreatment. In fact, such
burns and scars could easily be self-inflicted since the
Complainant has a history of medically diagnosed mental
depression and anxiety before we got married. Attached herein
as Annex “E” is the psychiatric report for the Complainant dated
2006.

11. That I deny the allegation in item no. 10. for being maliciously
blamed on me. The six (6) china plates the complainant blamed
me for breaking were actually broken when an earthquake hit our
city sometime in 2012. That the pictures attached on the
Complaint does not sufficiently and accurately prove my intention
to break the aforementioned inherited plates.

12. That I deny the allegation in item no. 11 for being maliciously
alleged. The Complainant has, based on my personal knowledge
as her husband, engaged in fetishism and enjoyed casual dirty
remarks when we are consummating our love. I, being a good
husband and partner, do succumb to such fetishism in my
attempt to pleasure my wife as part of my responsibility as the
Husband.

13. That I deny the allegation in item no, 12 for being misleading and
bluntly untrue. Before I and the Complainant were married, I
discovered the illicit affair of my best friend Sam Milby and the
Complainant. To protect her from humiliation, no one except my
mother knew of the illicit affair. The incident on 2010 when
according to the Complainant I used her as payment for my debt
was actually the second incident that I caught her continuing the
illicit affair by making sexual congress with my best friend Sam
Milby while I was drunk and asleep.

14. That I deny the allegation in Item no. 13 for being misleading and
founded on malicious and baseless suspicion. When I returned
to the Philippines, it is true that I went straight to my mother’s
house since I have enough reason to believe that the
Complainant has already cohabited with Sam Milby in our
matrimonial dwelling. But that did not stop me from attempting to
get my children. In fact, I asked the Barangay Chairman the day
after I arrived in the Philippines to help me confront the
Complainant and get the custody of my five (5) daughters. But
despite my efforts, she refused to give them to me. Attached
herein as Annex “F” is the statement of the Barangay Chairman.

15. That the allegation of the Complainant in item no. 13 that I have
been cohabiting with one Rachel Peters is a baseless and
malicious suspicion because Rachel Peters is one of the
boarders and room lessors of my mother. Attached herein as
Annex “ G” is the statement of Rachel Peters.

16. That I am executing this Reply - Affidavit based on my personal


knowledge to attest to the truth and veracity of the foregoing.

Affiant further sayeth naught


IN WITHNESS WHEREOF, I have hereunto set my hand this ___ day
of February 2022 in City of Muntinlupa

CLINT BONDAD
Affiant / Complainant

SUBSCRIBED AND SWORN to before me this ____ day of February,


2022, in City of Muntinlupa, I certify that I have personally examined
the affiant and I am satisfied that she has read and understood the
contents of the foregoing Affidavit and that she voluntarily executed the
same.

PUBLIC PROSECUTOR
City of Muntiunlupa
ANNEX “A”
Marriage License issued to Clint Bondad and
Catriona Gray in January 2009
ANNEX “B1”
Birth Certificate of Ma. Venus
ANNEX “B2”
Birth Certificate of Shamcey
ANNEX “B3”
Birth Certificate of Janine Marie
ANNEX “B4”
Birth Certificate of Ariella
ANNEX “B5”
Birth Certificate of Maxine
ANNEX “C”
Statement of Clind Bondad’s Mother

ANNEX “D”
Medical Certificate of Catriona Gray - Bondad’s
OB GYNE.
ANNEX “E”
Psychiatric Report diagnosing Catriona Gray of
Clinical Depression and Anxiety issued in 2006.
ANNEX “F”
Statement of Barangay Chairman of Southville
4, Muntinlupa City.
ANNEX “G”
Statement of Rachel Peters

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