Republic of the Philippines )

City of Cagayan de Oro ) S.S.

COUNTER-AFFIDAVIT

I, MICHAEL ANGELO PANTALEON RAMOS, of legal age, Filipino, single and a

resident of Zone 3, Upper Bulua, Cagayan de Oro City, under oath, do hereby state and
dispose that:

1) I am one of the Respondents in NPS No. X-06-INQ-17H-1246 for Violation of

Sections 5, 11, 12 & 15, Article II of RA 9165 entitled “PO3 Carmel Jorge Vallar and PO2
Arnel Sumanpan, vs Jonathan Mondejar, Mervin Cartagena and Michael Angelo Ramos”
2) I am indicted only for alleged violations of sections 11 & 12 (possession and
with paraphernalia). I have not committed any of the crimes alleged in the complaint
against me. I did not possess any illegal drugs and did not own and/or use any drugs
paraphernalia on and during the alleged buy-bust of the other co-respondents at
12:50AM, more or less, of 17 August 2017, at Zone 3, Bulua, Cagayan de Oro City. I was
a victim of circumstance and of being at the wrong time at the wrong place.

3) It is clear from the Judicial Affidavit of PO3 Vallar and PO2 Sumanpan that the
target of the buy-bust operation was a certain Jonathan Mondejar. I am not involved in
any illegal drugs activity.

4) I was originally not at the house / site of the alleged buy-bust operation. I was
at a house about four (4) or five (5) houses away from the alleged buy-bust house. I was
still washing my shirts that midnight and I wanted to smoke cigarette.

5) So after washing, I went out of the house and proceeded towards a store in the
Bulua highway. But before I could reach the store in the Bulua highway, I would pass by
the house where the alleged buy-bust took place.

6) Upon passing by the house where the alleged buy-bust took place, I saw Toto
playing dart inside the house and I asked him if he has cigarette, to which Toto said he
had none at the moment. I then heard Jonathan Mondejar said “Kinsa na?” (Who is
that?), to which Toto answered it is “Milo,” my nickname. Jonathan then opened the
door of one of the rooms of the house and asked me if I had food in my house and I
answered in the affirmative.

7) So I went back to my house and got some food (visceral organs in “Halang-
halang”) for Jonathan and company. When I was back at the house where the alleged
buy-bust took place (where Jonathan was) to deliver the food, Jonathan asked me if I
could buy coke and cigarettes for them. I readily assented to because I intended to buy
cigarette also from the store in the Bulua highway.

8) After buying coke and cigarette, I went back to the house where Jonathan was
to deliver the coke and cigarettes (Marlboro and Jackpot). I was about to leave already
the house but Jonathan and Mervin asked me to stay awhile and wait for the utensils
(yahong & plates) of the food I brought. So I stayed awhile. In the house were Mervin
Cartagena, Jonathan Mondejar, Marlon and Toto.
 9) I was standing at the door of the room where Jonathan Mondejar and Mervin
Cartagena ate the food I brought. Then suddenly, I saw a woman asked for Jonathan and
they exchanged something. Seconds after the exchange, there was commotion already
and some of the people in the house started running.

10) I did nothing illegal or wrong that night in the house where the alleged buy-
bust was. In fact, some of the arresting officers told me that they saw me when I was
walking and passing by them when I bought cigarette and coke for Mervin and Jonathan
to and from the store at the Bulua highway.

11) The alleged two (2) sachets found in my left pocket are not there in my
pocket. I do not know where those 2 alleged sachets came from. I had nothing in my
pocket that night.

12) And the alleged inventory of drugs paraphernalia found inside the room
where Jonathan Mondejar and Mervin Cartagena ate were not there when I was inside
the room and also when I was standing by its door. I never saw those materials and
things. In fact, there is no table in that room. Mervin and Jonathan just ate the food I
brought sitting on the small bed.

13) I execute this affidavit to attest to the truthfulness of the foregoing and to
dismiss this case wrongly imputed against me, in the interest of justice and equity.

In witness whereof, I have hereunto affix my signature this ________________ in

Cagayan de Oro City, Philippines.

MICHAEL ANGELO PANTALEON RAMOS

Affiant / Respondent
ID No.

SUBSCRIBED AND SWORN TO before me this _______________________ affiant

having shown his competent evidence of identity written below his name and signature.
I further certify that affiant had voluntarily executed the Counter-Affidavit, that he had
read and understood the contents thereof, and that they are based on his personal
knowledge.

Doc. No. _____

Page No. _____
Book No. _____
Series of 2017