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Republic of The Philippines

Department Of JusticeNational Prosecution ServiceOffice Of The City ProsecutorZamboanga City


PEOPLE OF THE PHILIPPINES,
Plaintiff,
-versus-
PEDRO SANTOS,
Accused.

IS NO
.
123456For:
Rape

COUNTER-AFFIDAVIT
I, Bea Alfonso, Filipino, of legal age, and with residence Tuguegarao City, after having been duly sworn
in accordance with law, hereby depose and statethat:(1) This complaint-
affidavit is being filed to charge PEDRO SANTOS, Filipino, of legalage, and with residence at Tuguegarao City, of the
crime of Rape under Article (Art.) 266 of the Revised Penal Code (RPC), committed as follows:(a) On 27 October
2018, at around 10:00 in the morning, I was barely 6 years of age and playing outside my house when JUAN DELA
CRUZ came by and invited me to play computer games with him at the house of
SANTOS.(b) On the way to their house, we passed by a narrow path where SANTOSsuddenly pushed me and JUAN
DELA CRUZ inside a small, low building, which turned out to be
SANTOS’
comfort room.(c) SANTOS then barred the door, whipped out a fan knife and poked it
against us and told us “Huwag kayo mag-iingay, kung hindi papatayin ko kayo!”
(d) SANTOS then asked me to step on the rim of the toilet bowl facing him and for DELA CRUZ to hold me from
behind. Out of fear for my life, I followed his orders.
While I was standing on the toilet bowl with my legs apart and DELACRUZ arms tightly around my waist, SANTOS
drew his short pants down to his knees, and after lowering my underpants, he inserted his penis into my
vagina.(f) After satisfying his carnal desires, SANTOS once again pointed the knife at DELA CRUZ
and told him “Gayahin mo ako! Ipasok mo ang ari mo sa ari niya!”
(g) DELA CRUZ pretended to insert his penis to my vagina while Mercado wasmasturbating.(h) Thereafter, he reiter
ated his threats to kill us. He gave me a five-pesocoin and told me to buy candies with it, however I threw it
away.(2) It took me several months before I was able to overcome my fear and told my mother, LINDA ALFONSO,
what happened to me.(3) Appalled by what happened, my mother and I went to the police station to report the
crime committed by SANTOS against my person. The police took my sworn
statement, a copy of which is hereto attached and made an integral part hereof as Annex “A”.
Thereafter, I was examined by their medico-legal officer. A copy of the Medico-Legal Report is likewise hereto
attached and made an integral part hereof
as Annex “B”

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