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Republic of the Philippines

Department of Justice
OFFICE OF THE PROVINCIAL PROSECUTOR
PROVINCE OF ISABELA
Hall of Justice, Ilagan City

Missy joy Alindayu

Complainant,
NPS NO. 246
-versus-
For: QUALIFIED THEFT
Perfecto Beltran
Respondent.
x-----------------------------------------x

COUNTER AFFIDAVIT

I, Perfecto Beltran, of legal age, Filipino, Single and a resident of

Ilagan city under oath hereby depose and state that:

1. I am the respondent in NPS NO.246 filed against me by the

herein complainant Missy Joy Alindayu on the charge of
Qualified Theft;

2. I vehemently deny the charges and allegations against me by

the complainant;

3. I work with the Diaz Construction as a labor for more or less

two (2) years;

4. On May 10, 2018 at around 12 o’clock in the morning, I was

inside the Building waiting for the time that we will be called
by the foreman to resume work;

5. After several mi nutes, I saw two men outside the plant going
inside the plant. They passed by where I was staying. I went
outside fearing I might get involved. I was then called by my
mother to accompany her to go to Cabagan to visit my
grandfather who was confined there;
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6. The day after, on May 11, 2023, we went back in Iligan City
from Cagayan de Oro. I learned that I was accused of being
involved in the stealing of certain copper ground pole. I asked
my mother to accompany me to go to the plant, where I work,
to inquire because I fear I may get blamed and to show them I
am innocent;

7. Outside the gate of the plant, the security told us to wait and
later that day brought us to the ;

8. I am innocent of the crime charged against me. The charges

against me are purely baseless and untrue;

9. I am executing this affidavit in order to attest to all the

foregoing facts and for whatever legal purpose it may best
serve.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed

that the instant criminal complaint be DISMISSED for lack of merit.

Further, the respondent respectfully prays for such and other

reliefs as may be deemed just and equitable in the premises.

IN WITNESS WHEREOF, I have hereunto set my hand this

19 day of June, 2023 in the City of Ilagan, Philippines.
th

Perfecto Beltran
Affiant

SUBSCRIBED AND SWORN to before me this 19th day of

June, 2023 in Ilagan City, Philippines and I further certify that I have
personally examined the affiant and I am satisfied that he has read
and personally understood the contents of her foregoing “Counter-
Affidavit.”
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NOTARY PUBLIC

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of ______.