REPUBLIC OF THE PHILIPPINES)

PASAY CITY )
PHILIPPINES ) S.S.

COUNTER-AFFIDAVIT

I, JOHN TAN, of legal age, married, residing at _____________________,

Pasay City after having duly sworn in accordance with law, hereby depose and state
that:

1. The Complaint against me is both baseless and malicious. It is dictated by revenge

of a jilted woman who could not cope with the realization that her lover has
deserted her.

2. I must vehemently deny the accusation of Forcible Abduction with Rape for being
unfounded. I must deny the allegations in paragraphs 3 through 5 of the said
Complaint for lack of credibilily and for being contrary to the facts. Her whole story
is self-serving.

3. I could not have been present in the alleged place of commission of the crime since
at that time I was attending a birthday party for my grandmother in Quezon City.
Appended to this counter-affidavit as Annex 1 is the sworn statement of Percy Lim
who can confirm my presence in said party.

4. I will likewise present the relevant CCTV footage in the alleged time and place of
occurrence will prove that I was never in that place and that the alleged crime never
happened.

5. I have known both the complainant and my co-accused Sam for a number of years.
I know them to be lovers though Sam is very much married. On a number of
occasions, Sam has shared with me his real feelings toward the Complainant. He
said he wanted to end his relationship with the Complainant because he is married.
He also told me that the more pressing reason is that he is apprehensive about the

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 personality of Complainant who has continually shown fits of depressions and
anger.

6. This complaint is malicious and is being filed solely as an act of revenge on the part
of Complainant as a consequence of Sams decision to separate from her after
several years of intimacy.

7. I am executing this Counter-Affidavit to attest to the truth of the foregoing

statements and likewise to impugn the crime of Forcible Abduction with Rape
against me by Complainant Virginia Pascua.

IN WITNESS WHEREOF, I have hereunto affix my signature this ___ st day

of 2016 in Pasay City.

JOHN TAN
Respondent-Affiant

ACKNOWLEDGMENT

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