Republic of the Philippines)

Province of Northern Samar)S.S.

Municipality of Catarman)

JOINT-COUNTER-AFFIDAVIT

WE, MARK JAMES B. MORENO and AMELITA B. MORENO,

both of legal age, all Filipino citizen and a residents of San Jose,
Northern Samar, after having sworn into in accordance with law,
depose and say that:

1. We are the Respondents in NPS Docket No. VIII-II-INV-19B-

00030 for Attempted Homicide now pending at the National
Prosecution Service, Catarman, Northern Samar;

2. The allegations therein are devoid of merit based on the

following grounds:

3. On February 8, 2019, at about 7:25 in the evening, we went at

Brgy. North, San Jose, Northern Samar, then and there we
discovered that our is messy, so I, (Mark) asked my auntie
Marife if what happened considering that I observed that our
things and/or belonging are really messy. And she said “get out
of this house, your mom constructed a house without asking
my permission, you don’t have respect, leave this place”
(kalayas kam didi, nagtindog si imo mama balay wara magsarit
sa akon, wara kam respeto, kalayas kam), so I leaved and
proceeded to Brgy. Balite where we are temporarily staying
while my auntie is still at Brgy. North with my Grand Mother
to avoid conflicts.

4. That upon arrival thereto, I saw my mom crying, and my father

explain me the situation so he advise us to blotter the incident,
so we immediately proceeded to the Police station to report the
same, however, upon arrival thereto a police officer told us that
a Brgy. Blotter is a requirement before the police blotter be put
on record, so we directly went to Brgy. North and took pictures
with our belongings which are messy and report the said
incident to the Brgy. Attached herewith is the copy of Bgry.
Blotter of the said incident dated February 8, 2019 marked as
Annex “A”.

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5. That we went to our house to confront my auntie to settle the
matter, and upon arrival thereto, my mother asked them to
open the gate for them to talk but auntie Marife is uttering an
offensive and defamatory words to my mother and instead lock
the same, so my mother push the wooden gate, and because
the gate is made in light materials and is hoary, it suddenly fell
down so my mother were able to enter the same, nevertheless,
I asked her to go home and just talk about it on the next day
before the Brgy. but my mother is persistent to determine and
inquire why are they doing it to us despite that she is helping
them and their mother and that she believes that she did
nothing with them, so I went back to my motorcycle along the
road and I let her talk to her sister while her sister auntie
Marife is shouting “HALA MAKMAK KASTIGUHA AK SULOD
DIDI” and I said “Ayaw gad auntie kay narespeto ak sa iyo,
ayaw man kami pagsugara siton ky pamilya man kami niyo”.
So she holds their mother while pushing it outside and told me
“ ADI SI NANAY KASTIGUHA, HALA KASTIGUHA KY KRIMINAL
KA MAN, MAO INE NAGSUGO NGA WAKAYON KO NGAN
TILTIGON AN PADER” and her mother replied “DRE GAD AKO
AN NAGPAWAKAY SITON, SIYA LA NAG BUOT, NGAN AYAW
GAD AK NOY PAG KASTIGUHA KAY AROG NAK” and I said,
“Deri ko gad ikaw nanay lalabtan, dre man ako sugan siton”.

6. That I (Amelita) told Janeth “you should not treat our mother
like that, you have to respect her, she is so old and weak due
to old age” and suddenly she beat me while uttering malicious
and offensive words until my head was hit in the pole and made
me fell down while she continue to beat me;

7. That when my son (Mark) observed the same, he immediately

rush for help and save and defend me, but upon entering the
place, he accidentally fell down and when he was able to get up
and saw me lying while my sister is at my top beating me, he
make defense to discontinue the attack and immediately pick
a piece of hallow block and throw it to Marife which is the
reason that I was able to escape so my son hurriedly lifted me
up and ask me to go home but I instead told him to go home
first as I will report to the police that my sister attacked me;
attached herewith is the copy of the request letter of the San
Jose Municipal Police Station to Norther Samar Provincial
Hospital to conduct a medico legal examination relative to the
incident dated February 9, 2019 marked as Annex “B”.
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 8. That as such, I suffered injuries on different parts of my head.
Attached herewith is the copy of the Medico Legal Certificate
dated February 14, 2019 Marked as Annex “C”.

9. We are executing this Counter-Affidavit to attest to the

truthfulness of the foregoing statements, to VEHEMENTLY
DENY all the allegations contained in the instant case, for the
same to be DISMISSED as it is bereft of merit and lies.

IN WITNESS WHEREOF, We have hereunto affixed our

signature this 27th day of February 2019 at Catarman, Northern
Samar.

MARK JAMES B. MORENO AMELITA B. MORENO

Affiant Affiant

SUBSCRIBED AND SWORN TO before me this 27th day of

February 2019 at Catarman, Northern Samar. I also certify that I
have personally examined the Affiants and that I am satisfied that
they fully understood the contents of his Counter-Affidavit, the same
having been read and explained to him in the dialect that he knows
before he signed it.

PROOF OF SERVICE/EXPLANATION

I hereby certify that I have sent a copy of this Counter-Affidavit

and its annexes to PSI RUSSEL D. CALUBAG through registered mail
due to distance, time constraint and impracticality of personal
service
___________________________
Copy furnished:
PSI RUSSEL D. CALUBAG
San Jose Municipal Police Station
San Jose, Northern Samar
Registry Receipt No. _______
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