REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
IMUS CITY

VILMA P. JUMAGDAO SINGHBAL

Complainant,

-versus- NPS Docket No. IV-28-INV-

23B-0215
For: CYBER LIBEL IN REL. TO
R.A. 10175
MYRNA MATANTE JUMAGDAO
ANA RAZEL JUMAGDAO BARDAJE
ANGELINA MERTANTE JUMAGDAO
Respondents.
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REPLY AFFIDAVIT
(as to counter affidavit of ANA RAZEL JUMAGDAO BARDAJE, ANGELINA
MERTANTE JUMAGDAO, MYRNA MERTANTE JUMAGDAO dated April
05, 2023)

I, VILMA P. JUMAGDAO, Filipino, married, of legal age,

after having been duly sworn to in accordance with law,
hereby depose and states, that:

1. Close perusal of respondents allegations would lead

to the following conclusions:

a. That the allegations in the complaint filed by yours

truly before this Honorable Office holds no water.

b. That the allegations begun when I raised a threat

against one of the respondent herein Myrna
Mertante Jumagdao

c. That I raised words or statement against their

family regarding their status and conditions in a
bad way;

d. That I’ve been a bad daughter to my mother.

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 2. The instant criminal complaint against the respondents
is based on meritorious grounds which are sufficiently
supported by documentary evidence and testimony as
provided in all ANNEXES being attached in the complaint
affidavit. And as such, the instant criminal complaint cannot
be considered as malicious, baseless, felonious, unfounded
and unjust.

Herein, complainant vehemently refutes all of the above

contentions by the respondents and all the witnesses herein.

Respondent created a false statement that the allegations of

the complainant is not true and will never fall on Violations of
Cyber Libel in relation to R.A. 10175;

Online libel is simply libel, in its traditional sense, committed

through a computer system or any other similar means which
may be devised in the future. In other words, the traditional
elements or requisites of libel still apply. For an imputation to
be libelous under Art. 353 of the RPC, the following requisites
must be present:

(a) it must be defamatory;

(b) it must be malicious;
(c) it must be given publicity; and
(d) the victim must be identifiable.

A fifth element or requisite is added under R.A. 10175 for

online libel: the act must be committed through a
computer system or any other similar means which may
be devised in the future.

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Before I proceed to answer the unfounded and baseless
allegations made by the Respondents and all the witnesses
herein in their counter affidavit and sinumpaang salaysay, it is
important to point out that the allegations therein were made
by them to cause confusion as to what is the real issue in this
complaint - - which is WHETHER or NOT ALL THE
RESPONDENT ARE LIABLE IN CYBER LIBEL CASE IN REL.
TO R.A. 10175.

Baseless, Immaterial, Irrelevant Allegations that deserve

scan consideration

A perusal of their counter affidavits will show that they failed

to disprove the charges I had made against them.

In essence, the allegations made by the Respondent in their

counter affidavits are all misrepresentation and self serving.

Aside from being self serving statements supported by

unverified self serving documents and statements which are
all hearsay such as affidavit of witnesses, and attached
Barangay clearance. All the allegation stipulated are all LIES,
FABRICATED AND FALLACIOUS.

3. First let me attack the countervailing issue herein this

case as to whether or not all the respondent herein are liable
with cyber libel case in relation to R.A. 10175, first and
foremost identity of all the facebook account herein cannot be
proved or need of certificate of extraction coming from PNP
Cybercrime division as all the respondent admitted the facts
that they posted and maligned the complainant in public or
facebook social media.

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 4. ANA RAZEL JUMAGDAO BARDAJE also admitted that
her account used in publishing post and comment belongs to
her, as Prosecutor Andrada asked her during preliminary
investigation dated April 05, 2023 if she was the one behind
that account/comment wherein she admitted.

5. Libelous statement, has been a cause that greatly affects

the integrity, dignity of the complainant herein.

6. Second their allegations that I am the one who

confronted my mother to raise a threat against Myrna
Jumagdao holds no water.

7. I never raise such sentences or statement against them,

all I knew is, my mother created such words or statement just
to create a quarrel along the side of each family. I’ve not come
to a certain conditions wherein, I deprive my mother to have a
better life.

8. Well in fact, our family from 1st consanguinity upto the

last, knew, how I am responsible daughter to my mother since
then. In addition, since my mother was in samar and currently
in bataan, I together with all of my brothers and sister get
together to help her just to cope up her conditions as she is
getting older already.

9. Everytime we saw each other, we spent our time just to

relax and enjoy, just only for my mother’s interest. Please see
attached copies of photo together with my mother and my
children having a enjoyable time for numbers of days which
are marked as ANNEX “A-series”, to form part hereof.
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 10. Actually, I didn’t know how come that my mother created
such words against the family of my brother. Well in fact, I
never confronted nor communicated my mother on that
certain time as I am busy spending my life in my family and
work here in Cavite.

11. In connection, despite of such words raise by my mother,

all the respondent herein didn’t take their initiative to confront
and ask me, to verify if I truly raise that words against them or
for Myrna M. Jumagdao, as a matter of fact, all the
respondents herein raise all their emotions publicly just to
certainly maligned my refutations and dignity as a person. To
declare in public that I am an abusive woman.

12. It was a saddened part of my life, wherein, despite of

such help I rendered to my mother, this is a return. I’ve been a
good daughter to my family and even my brothers and sister
can testify on that, I have no records also with all the
Barangay and government agencies regarding their allegations
that I frequently degraded their personal integrity. There has
been no proof on their claims.

13. For now, I have been depressed and stressed of such

actions done by all of the members of family of my brother or
the respondent herein, as I was receiving thoughts and
accusations coming from the other people that I am a abusive
woman and bad daughter to my parent, because of that post.
Please see attached copies of Sinumpaang Salaysay of my
additional witnesses to prove that I regularly visit my mother

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and support her financially in all aspect of her need, marked
as ANNEX “B-series”, to form part hereof.

14. My job and daily routine has been affected already as I

am contemplating as how I appeared in the eyes of my entire
family. Their allegations and testimony of all the witnesses
cannot be accepted herein this case, as they did not prove the
entire issue as whether or not all the respondents are liable
with cyber libel case in rel. to R.A. 10175.

15. All told all the elements of R.A. 10175 also known as
Cybercrime prevention act of 2012 are present in this case, as
all the respondents admitted the fact that it was their account
used to maligned and degrade the complainant. They maligned
me, as they publicly post a wrongful thought of my personality
which is baseless in the first place. Therefore, I reserved my
right to file a perjury case against all the respondent herein
and all the witnesses as they published under oath a words
under their sinumpaang salaysay which has not been
supported by concrete evidences.

16. Nothing can be clearer than the fact that probable caused
exist to release an information against all the respondents,
such post or statement and comments are malicious, and it
was publicly posted and seen by numbers of people, witnesses
on my part that they saw respondents post was established
and lastly, facts of admission coming from all the respondents
occurred.

17. I, therefore, most respectfully pray that the criminal

information for VIOLATION OF CYBER LIBEL IN REL. TO R.A.
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10175 be filed against MYRNA MATANTE JUMAGDAO, ANA
RAZEL JUMAGDAO BARDAJE, ANGELINA MERTANTE
JUMAGDAO as there is more than probable cause for their
indictment.

18.I am executing this Reply-Affidavit to attest the truth of

the foregoing declarations and to support my complaint for
VIOLATION OF CYBER LIBEL IN REL. TO R.A. 10175
against the respondents.

AFFIANT FURTHER SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto set my hand

and affix my signature this 19 th day of April, 2023, at Imus
City, Province of Cavite, Philippines.

VILMA JUMAGDAO SINGHBAL

Affiant

SUBSCRIBED AND SWORN to before me, this April 19,

2023 at Imus City, Province of Cavite, Philippines. And I
hereby certify that I have personally examined the affiant and
that I am satisfied that she voluntarily executed and
understood the contents of her affidavit and the same was her
free act and deed.

ALPHA L. ANDRADA
Assistant City Prosecutor