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REPUBLIC OF THE PHILIPPINES)PROVINCE OF NORTHERN SAMAR) S.S.MUNICIPALITY OF CATARMAN)

COUNTER AFFIDAVIT

I, RAUL B. GALLEGA, single, Filipino citizen, and a resident of Barangay Polangi, Catarman, Northern Samar, after having been sworn to in accordance with law do hereby depose and say:

1. That I am a registered tricycle driver of the Municipality of Catarman, Northern Samar. Attached herewith is a copy of my Occupational Permit and marked as ANNEX A.

2. That I am one of the respondents of NPS-DOCKET No.VIII-II-INV-14-00086 for Violation of Section 77 of PD 705 as amended;

3. That I categorically and vehemently deny all the allegations set forth in the aforementioned complaint, and the truth of the matter is that;

4. That I have been a long-time motor tricycle driver, plying the CATARMAN-POLANGI route. That because driving a motor tricycle is my main source of income; I drive every day of the week from Monday to Sunday, from early in the morning until the early evening.

5. That as such, I never went or neither have I ever been to the place where the alleged incident happened.

6. That on or about seven oclock in the morning of March 14, 2014 I was already mobile and on the road driving from my residence at Brgy. Polangi to the Terminal in Catarman.

7. That I do not know personally the complainant for the reason that said complainant in not a resident of Brgy. Polangi, Catarman, Northern Samar and that I unequivocally state that said complainant does not also know me personally.

8. That the complainant obtained my personal information from one Lucing Perez. As such, the complaint is a mere concoction and evil contrivance of the same. That the main motive for making such outrageous and debauching complaint because of her personal hatred to Roger Perez Sr. for some family feud, a long-time ago, arising out of land disputes.

9. That I hereby execute this affidavit to attest to the truth to the foregoing facts

IN WITNESS WHEREOF, I have hereunto affixed my signature this ________ day of _______________, 2014.

RAUL B. GALLEGA Affiant

SUBSCRIBED AND SWORN TO before me this _________ day of ___________, 2014 at Catarman, Northern Samar, Philippines.


COUNTER AFFIDAVIT

I, ROGER L. PEREZ JR., single, Filipino citizen, and a resident of Barangay Polangi, Catarman, Northern Samar, after having been sworn to in accordance with law do hereby depose and say:

1. That I am one of the respondent to NPS-Docket No. VIII-II-INV-14E-00086 for violation of Section 77 of P.D. 705 as amended;

2. That I have received a subpoena from the National Prosecution Service, Office of the Provincial Prosecutor, Catarman, Northern Samar;

3. That I categorically and vehemently deny all the allegations set forth in the aforementioned complaint, that the truth to the matter is:

4. That I am a long-time farm worker in the parcel of agricultural land of Nimfa Basierto, located in Brgy. Polangi, Catarman, Northern Samar. That I am not the actual caretaker of the said land, but one who assists the said caretaker in chores and works around said land;

5. That I receive a modest compensation in exchange for my help with the farm work;

6. That on March 4, 2014 I was at the land of Nimfa Basierto in Brgy. Polangi. That on or around seven oclock in the morning of the said date, I was in the house of Guillermo Ovencio, the caretaker of the land of Nimfa Basierto. That I asked him about the work for the said day and he replied KINAHANGLAN MAGDALUS KIT DIDTO referring to a certain portion of the land;

7. That after Guillermo Ovencio had breakfast we went directly to the certain area of the land where weeds or grasses are growing thickly. That we continuously worked on the said area, removing all the weeds and grasses, from about seven oclock in there morning until I heard him telling me that it is already time for lunch, that was about eleven oclock in the morning;

8. That after having lunch at the house of Guillermo Ovencio, the two of us went back to the certain area, as referred above, and started weeding and cutting grasses again up until around five oclock in the afternoon;

9. That as such, I never went to the place where the alleged incident happened;

10. That the complaint is a mere concoction of Lucing Perez, who is still a relative to me. But by reason of previous family discord, which I have no personal knowledge, exhibits bad blood and hostility to my family, specifically against my father, Roger Perez Sr;

11. That I execute this affidacit to attest to the truth to the foregoing facts.


ROGER L. PEREZ JR Affiant



COUNTER AFFIDAVIT

I, BIENVENIDO M. GALLEGA, single, Filipino citizen, and a resident of Barangay Polangi, Catarman, Northern Samar, after having been sworn to in accordance with law do hereby depose and say:

1. That I am one of the respondent of NPS-Docket No. VIII-II-INV-14E-00086 for violation of Section 77 of P.D. 705 as amended;

2. That I have received a subpoena from the National Prosecution Service, Office of the Provincial Prosecutor, Catarman, Northern Samar;3. That I categorically and vehemently deny all allegations set forth in the aforementioned complaint, and the truth of the matter is that;

4. That I am a copra worker (parag-lukad) of Brgy. Polangi, Catarman, Northern Samar;

5. That ever since March 1, 2014, I was contacted by Mr. Jun Leao, a cocoland owner in Brgy. Polangi. That in the said meeting, he asked if he could avail my service as copra worker to process the coconut fruits in his land. That Mr. Jun Leao has always contacted me for all copra work that he has.

6. That since I had prior engagement until March2, 2014, I told him that, I would be able to do the copra work for him not until March 3, 2014.

7. That on Mach 3, 2014, I went to the cocoland of Mr. Jun Leao on or about eight oclock in the morning. That on the same date I started the copra making process, by harvesting or picking the coconuts from high-up in the tree. That said picking stage lasted for two days from March 3-4, 2014;

8. That on March 5, 2014 I started the second step in the copra making process which is hauling the coconuts spread across the grounds. That it took me almost the entire day to collect all the coconuts near the structure where the coconut meat shall be cooked (lun-an), that before the day ended I started husking the coconuts in preparation for breaking them open;

9. That on the next day, March 6, 2014, I started break open each coconut and it also took me almost the entire day. Wherein, during the early evening of the same date, I have already manage to stack the coconut halves in the lun-an and started the fire underneath;

10. That in every step narrated above, Mr. Jun Leao was present and supervising me, except at night where he goes home to his residence;

11. That it was not until midday of March 7, 2014 that I was finished with the whole copra making process. That on the same date me and Mr. Jun Leao went down to the Brgy. Polangi, where the Copra Trader is located and weighed and sold the produce;

12. That as such, I could not have been at the site where the incident happened and finish the entire process in the same time frame;

13. That the instant complaint is a mere concoction of Lucing Perez for her hatred against my family because of previous discord;

14. That I execute this affidavit to attest to the truth to the foregoing facts.


BIENVENIDO M. GALLEGA Affiant


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