Republic of the Philippines

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
Cagayan de Oro City

JESSA MAE PIQUERO CELOCIA

Complainant,
NPS Docket No. X-06-INV-22G-1507
For: Violation of RA 9262
- versus -

ETHAN DAVE ESPEJO TOLEDO

Respondent,
X-------------------------------------------X

REPLY-AFFIDAVIT
(Re: Counter-Affidavit dated August 15, 2022)
I, JESSA MAE PIQUERO CELOCIA, 25 years old, Filipino, single, college graduate,
unemployed, and presently residing at 3rd St. Coca-cola Subd., Iponan, Cagayan de Oro City,
after having been duly sworn to in accordance with the law, hereby depose and state that:
1. I am the complainant in this case particularly charging respondent ETHAN DAVE
ESPEJO TOLEDO of violating Section 5(e)(2)(4) and 5(i) of RA 9262 otherwise
known as “Anti-Violence Against Women and Their Children Act of 2004”;

2. I hereby reiterate and replead all the positions and arguments contained in my Complaint-
Affidavit as may be considered material and relevant in this Reply-Affidavit;

3. I received the Counter-Affidavit of respondent on August 18, 2022 vehemently denying

the statements and allegations of my Complaint-Affidavit. However, his allegations were
not supported by any documentary evidence nor witnesses to support his defense;

4. A careful perusal of the allegations made by respondent are mere bare denials, self-
serving and negative allegations, and defenses that are bereft of any proof to substantiate
the same;

5. It can also be gleaned in the Counter-Affidavit of respondent that he only answered some
of my allegations in my Complaint Affidavit but did not answer most of the allegations
and evidences attached therein as respondent has none to controvert those;
Refutation to Respondent’s Blantantly
Untruthful and Fraudulent Presentation of Facts

6. At the outset, it must be emphasized that respondent only attached his recent employment
contract but did not present a single evidence-as he has none-to belie and rebut the
allegations and strong evidences presented that he committed the crime of economic,
psychological, verbal, and sexual abuse against me. In his attempt to exculpate himself
from the criminal acts he committed, respondent resorted to interweaving lies and
peddling falsehood, thus making him liable for a separate crime of perjury;

7. Respondent did not immediately take responsibility when I was pregnant with our first
child. In fact, he wanted me to abort it so he can pursue his ex-girlfriend, Ms. April Joy
 V. Mosqueda, again. Out of 9 months (270 days) of pregnancy, he only went to see me
five (5) times to give the abortion pills or to have sex with me. And that starting my 5 th
month of pregnancy, he already blocked and ghosted me. On the following weeks, I
found out that he had been seeing Ms. Mosqueda again since the day he found out that I
was pregnant. I also found out that he was having sex with me and Ms. Mosqueda on
alternate times that it made me cry and had chest pains every night. In attempt to justify
his cheating, he manipulated his friends with lies and twisted stories saying we were still
not married and he will just take responsibility for the baby alone in which I was
ridiculed and humiliated by it. Despite that, he did not take care of me during pregnancy
but was just busy with hanging out and was only present when I was about to give birth.
To corroborate my statements, Ms. April Joy Mosqueda would like to testify but because
she is too busy this week, she cannot go with me to swear his Witness Affidavit to this
Honorable Office but can be reserved during pre-trial;

8. We do not quarrel like normal couples do since respondent have a wide range of strange
behaviors far from the normal and healthy behaviors of a normal person. He often
subjected me to gaslighting, blameshifting, manipulation, silent treatment, stonewalling,
neglect, ridicule, verbal abuse, pathological lies, triangulation, and other psychologically
abusive tactics. He avoids accountability, rarely admits faults, and never apologize to his
mistakes that often makes me lose my sanity trying to understand and make sense of his
behaviors. He refuses to discuss our problems with me instead he discloses it always to
his family and friends. He always projects and deflects his flaws to me and engages into
blameshifting and smear campaign that our family and relationship problems had been
known to public. Due to the humiliation I have suffered because of respondent’s lies and
slander of me, I resorted to explain my side and narrated the abuse I have suffered from
respondent and his family. Despite that, it did not stop respondent to abuse me. He
always want to control and manipulate me. He lacks empathy and engages in impulsive
and irresponsible behavior. He has been aggressive and hostile which resulted to the
abuses he inflicted to me and our children. To conclude, it was respondent’s narcissistic
personality and abusive behaviors that made me depressed. To support my statement, I
will submit respondent’s signed handwritten statements made on August 8, 2021 about
the abuse he and his family inflicted on me herein attached as Annex “AA” and series;

9. Our quarrels were not the reason I left their house on March 2021. Instead it was because
of respondent and his family’s abuse towards me. Nevertheless, I came back to their
house two (2) weeks after and live with him from April 2021 to June 2021. I was then
told to go home again to my parent’s residence together with our two minor children
since respondent’s mother sold their main house. Respondent then lived alone in their
other house. He then started to ghost and abandoned us starting July 2021. Later on, I was
then told that I and our children are not allowed to go to respondent’s house nor live with
him. Thus, it was not me who left respondent but it was respondent who suddenly
ghosted and blocked me without any reason and eventually abandoned me and our
children;

10. I did not post derogatory remarks against respondent’s family. In fact, it was respondent’s
mother and aunts who spew insulting and degrading comments to me in personal, in
social media, in our private conversation and in their family group chat in Messenger.
While living together, respondent’s mother, Mrs. Annie Jean Espejo-Atwater have been
occasionally sending degrading remarks such as “Bagag nawong”, “Ambisyosa”,
“Feeling asawa”, “Pabaya nga inahan” even if I did not do anything wrong.
Respondent’s aunt, Mrs. Mechebel Espejo-Subrado, also kept on nagging to us almost
every day. There were also times respondent’s mother would comment insulting words
on my Facebook posts such as “Murag iro klase nga inahan”, “Babaeng amaw”,
 “Hypocrita” merely because of respondent’s lies and blameshifting tactics every time he
would commit mistakes or encounter scandals and issues. There were also times that
respondent’s mother would chat lies about me in their family group chat saying “Missing
ang inahan for 2 days kay nagbuhat ika 3 anak”. Even though there are evidences of
conspiracy between respondent and his mother and aunts in committing psychological
abuse towards me, I would just limit the charge to respondent. Screenshots of libelous
comments of respondent’s mother Ms. Annie Jean Espejo-Atwater and respondent’s
aunts Mrs. Mechebel Espejo-Subrado and Ms. Melanie Espejo are herein attached as
Annex “BB” and series;

11. Respondent did not exert efforts to provide support to our children. In fact, I encountered
hardships in asking for support since respondent always blocks me and would just
unblock me if he has something to say towards me. From pregnancy last January 2019 to
June 2020 (18 months), respondent did not give support to our first child. Also, from
March 2021 to December 2021, respondent deliberately gave insufficient support. And
starting January 2022 up to present, respondent did not give child support anymore. He
just gave enough support of Php5,000 from July 2020 to February 2021 (8 months).
Furthermore, respondent intentionally denied us of financial support but exerted effort in
treating food and giving gifts to his numerous women. Regarding the shoes and clothes
that respondent’s mother gave, it is not true that I refused it. Though it is true that I sold 3
sets of clothes, it is only because it was already outgrown by my children for its sizes are
0-3 months and I just sold it since respondent did not give any financial support. But last
March 3, 2022, respondent’s aunt Ms. Melanie Espejo had verbally harassed me outside
our house including the reason that I sold the outgrown clothes. It was then that I decided
to return all the outgrown clothes that they gave;

12. Regarding the nude picture he sent to my friend on January 24, 2021 as stated on
paragraph 18 of my Complaint Affidavit, respondent just resorted in flimsy excuses
devoid of any scintilla of truth. Firstly, it would be implied that the picture was taken
behind my back in which it showed the posterior side of my back, my buttocks, and
respondent’s hand while having sex with me. It would be impossible for me to take a
picture of myself in that angle. Secondly, it can be seen in our Messenger conversation
that I asked him why he sent it and he just replied “Hehehe” like he was laughing. I also
asked him in person about it but he just smirked and laugh like it was nothing and was
nonchalant of the embarrassment I felt. Lastly, I would never send obscene pictures of
myself especially that I am a faithful partner and I also protect my reputation since I am
also a licensed professional teacher;

13. I vehemently refute respondent’s averments in paragraph 4(e) of his Counter-Affidavit

and hereby replead and reiterate that respondent is a notorious womanizer in which he
had an overwhelming number of three hundred (300) women already. The messages I
attached is true and authentic and is not my own doing. In fact, I had a lot of messages
and evidences of his numerous affairs but since it is voluminous, I did not attach it but
will just reserve it during pre-trial. Some of the women he victimized would also like to
testify. In fact, I was contacted by GMA Kapuso Mo Jessica Soho (KMJS) and featured
our life story as “Jenny” and “Alex” and was aired last July 3, 2022. It featured
respondent’s outrageous womanizing, victimizing females of his feet fetish, and his non-
support to our children and they even got to interview some of respondent’s victims.
Furthermore, respondent’s sexual harassment case about his feet fetish while we are still
in a relationship will be provided by University of Science and Technology of the
Southern Philippines (USTP)-Office of Student Affairs (OSA) upon court order. In fact,
some of his women after knowing that respondent has a partner and children, willfully
admitted that they had sexual intercourse. Aside from Ms. April Joy Mosqueda, these
 women are Ms. Gerard Mae Alfeche, Ms. Janine Kristy Abang, Ms. Ley Ann Manatad,
Ms. Floren Dela Pena, Ms. Kylie Camille Pacana. To corroborate my statements of
respondent’s womanizing, photos of some of respondent’s women are herein attached as
ANNEX “CC” and series;

14. It is also not true that I posted messages accusing him of abandoning me since everyone
already knows that respondent had abandoned us. In fact, he proudly told some of his
friends that he suddenly ghosted and abandoned me without any reason. He had also
posted his women on social media and he was seen by a lot of people dating different
women every day that it can be implied that he already abandoned us. It was also
respondent who keeps on cyberstalking me every day with different dummy accounts on
social media to keep on having surveillance of me. It is also not true that I presented
myself as a victim because I am already a victim of respondent’s verbal, emotional,
mental, psychological, sexual, and economic abuse;

15. It is not true that respondent provided me with a nanny of our children when we were
living together. It is also not true that I wanted him to take care of the children and that I
am busy with texting and posting in social media. In fact, days after I gave birth, he kept
on volunteering in their work to join their week-long and month-long business trips even
though it was the important times I needed his physical and emotional support since I was
still weak after giving birth and I have to take care of a newborn and a toddler.
Furthermore, it was respondent who is very addicted with social media and dating apps
that he was always on his phone chatting, matching, and video calling different women
while I was just on my phone to do my job as a momfluencer and to advocate as I am one
of the admins of Cagayan de Oro’s breastfeeding and cloth diapering groups;

16. Respondent’s actions of leaving me to take care of the children alone and without help
led me to a lot of struggles physically, mentally, and emotionally. That in the long run,
especially after respondent ghosted me and abandoned us, it caused me severe mental and
emotional anguish and heightened my postpartum depression and anxiety. That when I
felt extreme psychological symptoms, I was compelled to visit a psychiatrist, Dr. Jose
Coruna, on August 21, 2021, initially to have a psychological evaluation for VAWC. But
since I was overwhelmed by the fees and did not have enough money, I went to have a
counselling instead in which I was given prescription medicine namely Clonotril to help
relieve my anxiety and insomnia. I was also told that I would be subject to several
sessions for an accurate diagnosis of my mental health status and was told to come back
on September 16, 2021. But due to financial constraints, I was not able to finish my
sessions. Due to the stress I experienced from respondent, I also suffered physically in
which I had psoriasis break out and pimple break out. I also suffered migraines and
fatigue. Aside from that, I had constant toothaches because some of my teeth should be
pulled out but it is still not extracted until this day because the loan my mother got for
this were already used to financially support our children. Copies of prescription
medicines and receipts of my visits to the psychiatrist, dermatologist and dentist are
herein attached as ANNEX “DD” and series;

17. It is not true that I wanted to see him suffer and miserable. In fact, it was me who
suffered tremendously due to respondent’s abandonment and outrageous womanizing.
My life also became miserable since I met respondent because I was cheated multiple
times and was subject to different abuse and manipulation. My reputation was also
besmirched since I got strung along by respondent’s numerous issues and scandals;

18. I was not fully aware of respondent’s monthly salaries since he does not disclose it to me
especially when he was an IT staff at Concentrix and a Technical Engineer at Actionlabs
 Service Center. It is also not true that I want more because I only want enough child
support. It is also not true that I expect his mother to provide more. For the truth is that it
was his mother who offered to provide a nanny and monthly groceries because he wanted
us to separate and to get his son to live with her permanently in the United States. Since I
and my children would be abandoned forever by respondent, it is only fair that they
would provide a nanny to help me in taking care of the children so that I can also start to
look for a job and practice my profession. Since I do not have power over their decisions
to abandon us, I was compelled to agree to his mother’s offer. But they did not make
good of their promise and had stop providing us with a nanny. It can also be seen in our
agreement in Annex “K” that respondent offered diapers, milk and a nanny and even
promised to secure a house for the children since there is a high paying job that is
awaiting for him in the United States plus his mother is also earning 6,000USD or
equivalent to Php300,000. Furthermore, even if respondent’s present salary is only
Php10,000, respondent’s house rent, electric bill, water bill, internet bill, groceries, food
and water are already provided by his mother. To wit, Art. 201 of the Family Code of
the Philippines says, “The amount of support, in the cases referred to in Articles 195
and 196, shall be in proportion to the resources or means of the giver and to the
necessities of the recipient”. Thus, the reference is the resources and means and not just
the amount of salary of respondent. But despite of his lavish lifestyle, respondent had not
given any financial support in order to control me and so I cannot apply for a job. He just
used his salary in ordering vices and items in Shopee, buying beers and vapes, treating
his women with food and clothes, and spending on his hang out with friends.
Furthermore, we already have an agreement last October 30, 2021 attached as Annex
“O” and series to my Complaint Affidavit, that he will give Php6,000 for child support
and his mother would shoulder the Php4,000 for the salary of the nanny but despite of
that respondent still gave insufficient child support and eventually did not give any
financial support from January 2022 up to present. Furthermore, respondent had offered
last August 5-22, 2022 by continually chatting and harassing me saying that he will give
me all the needs of the children and will secure a house for them with the condition that
he can have sex with me anytime he wants despite having a present woman who he is
having sex with. Screenshots of respondent’s Facebook and Instagram stories of his
Shopee orders and frequent drinking of alcohol are attached as ANNEX “EE” and series;

19. I therefore respectfully pray that criminal information for economic, psychological, and
sexual violence of RA 9262 be now filed against respondent ETHAN DAVE ESPEJO
TOLEDO as there is more than probable cause for his indictment.

IN WITNESS WHEREOF, I have hereunto affixed my signature this _th day of

August, 2022 in Cagayan de Oro City, Philippines.

JESSA MAE PIQUERO CELOCIA

Affiant

SUBSCRIBE AND SWORN to before me this _th day of August 2022 in Cagayan de
Oro City, Philippines, I hereby certify that I have personally examined the affiant and I am
satisfied that she voluntarily executed and understood the contents of her affidavit.