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Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecution Services
OFFICE OF THE PROVINCIAL PROSECUTOR
Province of Misamis Oriental
2nd Floor IBP Building, Corrales, Cagayan de Oro City

JEANE CARIDAD y JUMARITO NPS NO. X-05-INV-17H-00524

Complainant

-VERSUS- FOR:

EUDELIZA ANONG y PAA ESTAFA AND VIOLATION OF

MA. LOURDES CAMILOTES BATAS PAMBANSA
Respondents.
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COUNTER AFFIDAVIT

I, MARIA LOURDES P. CAMILOTES, Filipino, of legal age, married and presently residing
at Block 26 Lot 19, Regency Plains Subdivision, Iponan, Cagayan de Oro City,
Philippines, do hereby depose and say:

1) That I am falsely and unjustly held as co-respondent/co-defendant of MS.

EUDELIZA PAA ANONG charged with the offenses of ESTAFA and VIOLATION OF
BATAS PAMBANSA 22 filed before the Office of the Provincial Prosecutor of the
Province of Misamis Orinetal, 2nd Floor, IBP Building, Cagayan de Oro City;

2) That MS. EUDELIZA P. ANONG is a personal friend and officemate. We are both
employed in the College of Business and Accountancy of Liceo de Cagayan
University. She is our Office Secretary and myself a Faculty Member.

3) That I have no knowledge that Ms. Anong is engaged in the business of money
lending with the complainant in this case, MS. JEANE JUMARITO CARIDAD;

4) That I do not personally know the complainant in this case and that our paths only
crossed through phone call after the time I shockingly received a Demand Letter
demanding payment for a debt which she alleged that I obtained through MS.
EUDELIZA ANONG as evidenced by the check which was signed by me.

5) That I am not a client and have never applied nor obtained a loan from MS.
EUDELIZA P. ANONG and MS. JEANE CARIDADs money lending business.
Furthermore, I am not aware of any of these transactions which transpired since
December 2015 and thereafter between the two parties mentioned as alleged by MS.
CARIDAD in her Complaint-Affidavit in Paragraphs 02, 03, 04, 05, and 06.

6) That I admit being the owner/issuer of EastWest Bank Check No. 0561699 but deny
responsibility for the same since said check was not issued for loan payment
purposes. Sometime in May 2016 MS. EUDELIZA PAA confided that she badly
needed money to buy food for her children. That she wanted to obtain money loan
from a cousin but the latter requires checks to be issued before release. Out of
empathy for her situation and despite my knowledge that checks should be handled
with reasonable prudence, I nevertheless allowed her to borrow said checks. Besides,
MS. EUDELIZA ANONG told me pahulama lang ko ug check Marie kay igo ra
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nako ipakita sa akong ig-agaw. Dili lagi nako ipa encash sa iya or ipa deposti
kay pulihan ra nako siya ug cash pag-abot sa allotment sa ako bana.
Translated into English language, please just let me borrow your checks, anyway
they will just be for show. Be assured I will not let the checks be deposited or encashed
because I will replace the checks with cash payment once my allotment arrives. Aside
from feeling a sense of need to help her, I trusted her in good faith because in our
office she is trusted with handling money matters and her husband is gainfully
employed as a seaman. Thus, I was assured that she would make good of her
promises and assurances;

7) That I deny being liable for EastWest Check No. 0561699 because I DID NOT GIVE
MS. EUDELIZA ANONG MY AUTHORITY TO FILL-UP THE AMOUNT, DATE, AND
PAYEE much more to issue and endorse it to another person. Furthermore, MS.
ANONG never informed me that she did not pursue her loan with her cousin and
that she planned to return the check to me but it was not materialized because I was
re-assigned to the Senior High School on Department in June of the same year. I did
not know that she decided to use said checks to pay her obligation with MS.
CARIDAD. I only knew of these facts when I received the demand letter from MS.
CARIDAD and in her sworn statements in her AFFIDAVIT (Attached as Annex A);

8) That thereafter, despite the burden on my part to physically transfer from one
building to another to see MS. EUDELIZA ANONG, I kept reminding her to attend to
the matter urgently as she no longer replied nor answered the texts messages and
calls of MS. CARIDAD. I facilitated that the two will be able to have a phone
conversation all this time but I found that MS. ANONG only gave empty promises to
MS. CARIDAD;

9) That I deny the allegation of MS. CARIDAD in Paragraph 10 that I still owe her a
balance of P 80,000.00. There was never a loan contract that existed between us.
Further, MS. JEANE CARIDAD and MS. EUDELIZA P. ANONG failed to prove that I
was able to personally receive the money and that the same was acknowledge
through a receipt or any other form capable of being used as evidence to prove my
liability for a loan contract as a co-borrower guarantor or co-maker;

10) That due to this situation and since the time I received the demand letter and phone
calls of MS. JEANE CARIDAD I suffered sleepless nights, loss of appetite, emotional
and mental stress, loss of focus in my work and in my duties at home as wife and
mother. Many instances, I have to hurriedly leave my students behind to facilitate
and make follow-up and convince with MS. ANONG to make arrangements with the
complainant for fear that I might be erroneously involved in a law suit;

11) This Counter Affidavit is being executed to attest to the truth of all the foregoing facts
and events and to disclaim all the accusations against me.

IN WITNESS WHEREOF, I have hereunto affixed my signature on this 27th day of

September, 2017 at Cagayan de Oro City.

MARIA LOURDES P. CAMILOTES

Respondent
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SUBSCRIBED AND SWORN to before me this ______ day of _________________

2017 in Cagayan de Oro City.

I hereby CERTIFY that I have personally examined the respondent and that I am
satisfied that she has voluntarily executed and understood her CounterAffidavit.