Republic of the Philippines

11th Judicial Region

REGIONAL TRIAL COURT
Branch 3
Davao City

PEOPLE OF THE PHILIPPINES,

Plaintif,

CRIMINAL CASE NO. 005-2011

-versus-

FOR: KIDNAPPING FOR

RANSOM

PEDRO C. CARGO,
Accused.
x--------------------------------------------x

JUDICIAL AFFIDAVIT OF PEDRO C. CARGO

This Judicial Affidavit of Pedro C. Cargo, the accused, is executed to
serve as his direct testimony in this case.
This Judicial Affidavit was taken in Sta. Ana Police Station. The
questions were propounded in English by accuseds counsel, Atty. Ralph S.
Palmera, in the said establishment while answers were given by the witness
also in English.
PURPOSE: This Judicial Affidavit is ofered to prove the innocence of the
accused.
1.

Q. Please state your name and other personal circumstances for the
record.
A. I am Pedro Cargo, 28 years old, married and a resident of Cabantian,
Buhangin Davao City.

2.

Q. What is your connection to the Spouses Jessica and Rex Ayala?

A. I worked for them as a helper/driver sir.

3.

Q. How long have you been working for them?

A. I worked there for two years sir.

5.

Q. During those years you worked for them, where were you staying?
A. I stayed in their house sir.

6.

Q. What is the reason why you are no longer working for the spouses
Ayala?
A. I was terminated by sir Rex Ayala sir because I found out that he and
1

inday Taclob was having an afair.

7.

Q. Who is this inday Taclob youre referring to?

A. She is the yaya of Jason Ayala sir, my co-employee in the house.

8.

Q. You mean Danica Taclob?

A. Yes sir.

9.

Q. How did you know that they were having an afair?

A. I caught them having sex sir.

10.

Q. When did it happen?

A. It was on March 12, 2013.

11.

Q. Where did you caught them having sex?

A. Inside Danicas room sir.

12.

Q. What was their reaction after that?

A. Both of them were angry at me because I didnt knock at the door
before entering Danicas room.

13.

Q. What did you do after that?

A. I just got out right away and just pretended it didnt happen.

14.

Q. Did you told anybody about that incident?

A. Only to Kris sir.

15.

Q. Who is this Kris?

A. Kris Pilapil, the other house maid in the house.

16.

Q. Where were you on December 20, 2013 at around 10:30 in the

morning?
A. I was in Batanes sir.

17.

Q. Where specifically in Batanes?

A. At Bernardos Hotel sir.

18.

Q. Why were you there at that particular date and time?

A. We were celebrating our wedding anniversary sir.

19.

Q. You said we, who else was with you, if any?

A. I was with my wife sir.

20.

Q. You said while ago that you worked as driver/helper of Ayala family
for two years, what is your current occupation before you were
apprehended?
A. Im an employee of Mr. Henry Tan sir.

21.

Q. What do you do exactly for Mr. Henry Tan?

2

A. Im his driver/house boy sir.

22.

Q. How much did you spend on your vacation?

A. I did not spend anything sir because it was my boss who sponsored
our trip.

23.

Q. Where were you on the night of December 23, 2013?

A. I was driving the car of boss Henry sir.

24.

Q. What incident happened at that time of the evening, if any?

A. I was stopped by a police car sir and then they apprehended me.

25.

Q. What was the reason you were apprehended?

A. The police said that I am a suspect in the kidnapping of the son of
Rex Ayala sir.

26.

Q. Did you kidnapped the son of Rex Ayala?

A. No sir.

27.

Q. If you did not kidnapped the son of Mr. Rex Ayala, did you have
atleast any participation to the said kidnapping?
A. None sir.

28.

Q. What was the basis of your arrest according to the police?

A. The police said that Im carrying the ransom money.

29.

Q. It is true that you were carrying ransom money on that night?

A. No sir.

30.

Q. Who is the owner of the car you were driving on that night?
A. It is owned by Mr. Henry Tan sir.

31.

Q. Where were you taking the car of Mr. Tan on that night?
A. I was actually at the house sir watching TV and then sir Rex called
me and told me to get the car from Victoria Plaza parking lot and bring
it back to the house.

32. Q. Do you understand that you are answering the questions under
oath?
A. Yes, sir.
33.

Q. Do you also understand that you may face criminal liability for
perjury or false testimony if the answers you gave are false or untrue?
A. Yes, sir.

IN WITNESS WHEREOF, I have hereunto set my hand this 7 th day of

June 2014 at Davao City.

Pedro C. Cargo
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in and

for the City of Davao, this 7 th day of June 2014. Affiant personally came and
appeared with I.D. N0. 1234567 issued by the Social Security System on
February 1, 2010 at Davao City, bearing his photograph and signature,
known to me as the same person who personally signed the foregoing
instrument before me and avowed under penalty of law to the whole truth of
the contents of said instrument.

RALPH S. PALMERA
Roll of Attorney No.: 932115
IBP No. 123456, 1/6/2014, Davao City
Chapter
PTR No. 001234A, 1/6/2014, Davao City
MCLE Compliance No. II-0004567
TIN No. 188-031-800
Doc No. _____;
Page No. _____;
Book No. _____;
Series of 2014.

I, Atty. Ralph S. Palmera, of legal age, Filipino, with office address at

BPC Law Office, Door 400-405, 5th Floor, Abreeza Corporate Center, J.P.
Laurel Ave, Davao City, after being duly sworn, depose, and say that:
1. I was the one who conducted the examination of the accused, Pedro
C. Cargo;
2. I have faithfully recorded or caused to be recorded the questions I
asked and the corresponding answers that the witness gave;
3. Neither me nor any other person then present or assisting her
coached the witness regarding her answers.
IN WITNESS WHEREOF, I have hereunto set my hand this 7 th day of
June 2014 at Davao City.

Atty.

Ralph

S. Palmera
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in and

for the City of Davao this 7 th day of June, 2014. Affiant personally came and
appeared with Identification No. 0111-0822064-2 issued by the Land
Transportation Office at Davao City, bearing his photograph and signature,
known to me as the same person who personally signed the foregoing
instrument before me and avowed under penalty of law to the whole truth of
the contents of said instrument.

Armando Cristian Perez

Notary Public for Davao City
Until December 31, 2015
Notarial Commission No.
235-2014
Roll of Attorney No. 73652
PTR No. 63896;12/1/13;
Davao City
IBP No. 62852; 12/1/13;
Davao City
TIN 242-163-724
3RD Floor, Pryce Tower
Building
J.P. Laurel Ave.Bajada,Davao
City
Doc. No. ______;
Page No. ______;
Book No. ______;
Series of 2014.