Republic of the Philippines

MUNICIPAL TRIAL COURT

9th Judicial Region
Branch ___
Zamboanga City
PEOPLE OF THE PHILIPPINES,
Plaintiff,

Criminal Case No: 12345

-versus-

FOR:

CHRISTIAN DOMINGUEZ
y ATILANO,
SLANDER
Accused.
x---------------------------------------------------x

COMPLIANCE
Plaintiff, through counsel, and unto this Honorable Court, most
respectfully submits the Judicial Affidavit of MARY S. PEREZ
pursuant to Section 2 of A.M No. 12-8-8-SC otherwise known as the
Judicial Affidavit Rule.
Respectfully Submitted. Zamboanga City, Philippines, October
04, 2016.

ATTY. RHEA DOLL B. GONZALO

Gonzalo Law Office
nd
No. 4, 2 Floor, Blanco Building, NS Valderrosa St.,
Zamboanga City
IBP No. 824567 09/18/2017
Roll No. 65788 06-16-2017
PTR No. 0992567 09/18/2017
Zamboanga City
Initial MCLE Compliance as per Bar Matter 850 5-6-14
Email: attyrheadollgonzalo@yahoo.com
0916-143-9360

copy furnished:
ATTY. ANN LORAINE L. TAM
Assistant City Prosecutor
Office of the Prosecutor
Hall of Justice
Zamboanga City
Republic of the Philippines
MUNICIPAL TRIAL COURT
9th Judicial Region
Branch ___
Zamboanga City
PEOPLE OF THE PHILIPPINES,
Plaintiff,

Criminal Case No: 12345

-versus-

FOR:

CHRISTIAN DOMINGUEZ
y ATILANO,
SLANDER
Accused.
x---------------------------------------------------x

JUDICIAL AFFIDAVIT OF MARY S. PEREZ

I, MARY S. PEREZ, of legal age, Filipino, single, and a resident
of Blk. 24, Lot 09, Paraiso Lane, Guiwan, Zamboanga City,
Philippines, state under oath as follows:
PRELIMINARY STATEMENT
That the person examining me is Atty. Rhea Doll B. Gonzalo
with address at Gonzalo Law Office, No. 4, 2nd Floor, Blanco
Building, NS Valderrosa St., Zamboanga City. The examination is
being held at the same address on October 04, 2016, in English
language, which I am conversant with. I am answering her questions
fully conscious that I do so under oath and may face criminal liability
for false testimony and perjury.

PURPOSE: This affidavit/ testimony of MARY S. PEREZ is being

offered to prove that the accused was not in Zamboanga City on the
date and time specified in the Information since on that same time
and date (September 18, 2016, 07:00 P.M), accused was on a
business trip with his wife at Boracay. The affiant, as the travel agent
of the accused will testify that she was the one who booked the
tickets of the accused in his travel to Boracay, thus the manifest
impossibility of accused committing the crime imputed upon him.
1.

Q: Please state your name and personal circumstances for

the record.
A: I am MARY S. PEREZ, of legal age, Filipino, single, and a
resident of Blk. 24, Lot 09, Paraiso Lane, Guiwan,
Zamboanga City, Philippines.

2.

Q: Q: Why are you here today?

A: I am here to prove that the accused Christian Dominguez
y Atilano was in fact not in Zamboanga City at the date
specified in the complaint. As his travel agent, I am tasked to
book his tickets to and from Zamboanga. I was the one who
arranged all his travels and as such, I can testify that he was
in Boracay, Aklan at the date stated in the complaint. Thus,
the manifest impossibility that he committed the crime
imputed on him.

3.

Q: Do you personally know the accused?

A: I know the accused, Maam. He has always been our
companys loyal client. As a businessman, he frequently
travelled in and out the Philippines. He has always booked
his trips and tours through our travel agency- Viaje Travel
and Tours.

4.

Q: Now, I would like to ask you how frequently does he travel

based from his booking on your travel agency?
A: Well, I do not know the average Maam, for he has been
our client since 2010. However, for this year Maam, he has
travelled for 10 times to date.

5.

Q: Now, you mentioned that he travelled for 10 times this

year, can you please tell me his most recent travel taking
into consideration the booking he made in your agency?

A: Well, yes Maam. For this year, the most recent booking
he has arranged with us was dated September 14, 2016 as
the travel date while September 21, 2016 was the return
date.
6.

Q: Can you please tell me specifically the origin and

destination of the September 14, 2016 travel?
A: Certainly Maam. The itinerary of the travel was from
Zamboanga-Manila- Boracay. This is for the reason that
there are no flights catering directly from Zamboanga to
Boracay.

7.

Q: Can you please specify as well the booking reference

code of the itinerary you have just mentioned?
A: It is J92412R on Philippine Airline flight 262.

8.

Q: How about the origin and destination of the September

21, 2016 travel?
A: Well, actually Maam. The original arrangement was for
me to book an open ended ticket for them- meaning that the
return date be left open at any time they wish to return to
Zamboanga. So, on September 19, 2016, Mr. Dominguez
called me to book their return flight on September 21, 2016
which I complied with immediately. This is also manifested in
the Passenger Booking List which we are obliged to submit
every month to the airline concerned.

9.

Q: Do you have a copy of this airline booking which you are

talking about?
A: Yes.
Witness hands over a certified copy of the Passenger
Bookings which it submitted to Philippine Airlines bearing the
name of Christian Dominguez Atilano as a passenger on
September 14, 2016 and September 21, 2016. A copy is
attached hereto and marked as Annex 1.

10.

Q: Okay. So you told me that you are the accuseds travel

agent, were you also the one responsible for booking their
hotel accommodation in Boracay?

A: Yes, Maam. As a tour operator, we dont only book flights

but we also arranged tour packages. I was also the one who
booked their hotel at La Plaza Suites in Boracay. I was the
one who emailed the front office for reservation and booking,
particularly Ms. Madeline Cortez.
11.

Q: Do you have a copy of this email and registration that you

are saying?
A: Yes, Maam.
Witness hands over a copy of the email reflecting his
transaction with Ms. Madeline Cortez, front desk receptionist
of La Plaza Suites, Boracay. He also hands an electronic
copy of the Reservation Information Sheet at La Plaza
Suites, Boracay. A copy is attached hereto and marked as
Annex 2 and 3 respectively.

12.

Q: Do you have anything more to say?

A: None, Maam.

IN WITNESS WHEREOF, I have hereunto set my hand this October

04, 2016 at Zamboanga City.

MARY S. PEREZ
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, a notary public

in and for the city of Zamboanga, Philippines this October 04, 2016.
Affiant personally known to me as the same person who personally
signed the foregoing instrument before me and vowed under penalty
of law to the whole truth of the contents of said instrument.
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