Republic of the Philippines

OFFICE OF THE EXECUTIVE JUDGE

Regional Trial Court
Makati city

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus - SW NO: _________________________

FOR: Violation of R.A. 10591
(Illegal possession of firearms]
Gino Andrew Valencia
1507 Anastacio St., corner Antipolo St,
Guadalupe Nuevo, Makati City

Respondent,
x-------------------------------------------x

Republic of the Philippines)

City of Makati ) S.S
x - - - - - - - - - - - - - - - - - x)

AFFIDAVIT

I, PCINSP GIDEON T INES JR, of legal age, married, active member of the
Philippine National Police and presently designated as Chief, Station Investigation and
Detective Management Section, Makati City Police Station, Southern Police District,
NCRPO located at Ayala Avenue Ext., corner Yakal St., Makati City, after having been
duly sworn to, in accordance with the law do hereby depose and state;

1. On February 7, 2019 at about 1:30 pm, Station Intelligence Section personnel

of Makati City Police Station led by PCINSP AARON ELAGO, implemented the Search
Warrant issued by this Honorable Court for Violation of R.A. 10591 (illegal possession
of firearm) at 1027 Badas St., Barangay South Cembo, Makati City. The
implementation of the Search Warrant resulted in the arrest of four (4) suspects
including the target of the SW namely Jerald Paul Tayamora y Borda and recovery of
two (2) caliber .38 revolver, one (1) Caliber .45 airsoft pistol with one magazine, one (1)
5.56 Air soft Rifle with one magazine and Seven (7) pieces medium heat sealed sachet
of shabu.

2. After the arrest of the suspects, the undersigned subjected suspect Jerald for
investigation wherein he revealed the name of the leader and supplier of firearms he is
illegally selling. Suspect revealed a certain Gino, who have under his possession and
control one (1) caliber 45 pistol and one (1) 9mm and several ammunitions of the same
caliber inside his house and his private vehicle located at Anastacio St., Corner
Antipolo St., Barangay Guadalupe Nuevo, Makati.

3. Wherefore, with this information given by suspect Jerald supported by the

Spot Report submitted by the Chief, Intelligence Section, Makati City Police Station
who implemented the Search Warrant at 1027 Badas St., Barangay South Cembo,
Makati City has reason to believe that Gino Andrew Valencia, residing at 1507
Anastacio St., Corner Antipolo St., Barangay Guadalupe Nuevo, Makati City is involved
in gunrunning activities and the above-described firearms revealed by Jerald Paul
Tayamora were under his possession and control, that is contrary to law;
4. That I am executing this Affidavit to attest to the veracity of the facts taken
above and for the purpose of supporting the application of Search Warrant;
 AFFIANT FURTHER SAYETH NAUGHT:

IN WITNESS WHEREOF, I have hereunto set my hand this ____ day of

February 2019 at Makati City.

PCINSP GIDEON TANGAN INES JR

Affiant

SUBSCRIBED AND SWORN TO before me this _____ day of February 2019

here at Makati City, Philippines.

__________________________________
Executive Judge

.
 Republic of the Philippines
OFFICE OF THE EXECUTIVE JUDGE
Regional Trial Court
Makati city

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus - SW NO: _________________________

FOR : Violation of RA 10591
[Illegal Possession of Firearm]

Gino Andrew Valencia

1507 Anastacio St, corner Antipolo St.,
Barangay Guadalupe Nuevo, Makati City
Respondent,
x-----------------------------------------x

DEPOSITION OF WITNESS

Ako si, Jerald Tayamora y Borda, 33 taong gulang, walang trabaho, nakatirasa
441 Pulilio St., Barangay Pitogo, Makati City ay sumumpa ayon sa ating saligang batas
na magsasabi ng mga sumusunod:

TANONG1 : Sabihin mong muli ang iyong pangalan?

SAGOT1 : Ako si Jerald Tayamora y Borda

T2 : Kilala mo ba si PCINSP GIDEON T INES JR? ang aplikante ng Search

Warrant na ito?

S2 : Oo sir, siya ang hepe ng CID at SDEU ng Makati City Police Station
na matatagpuan sa Ayala Avenue Ext., cor. Yakal St., Makati City;

T3 : Alam mo ba ang lugar na 1507 Anastacio St., Corner Antipolo St.,

Guadalupe Nuevo, Makati City?

S3 : Oo sir.

T4 : Kilala mo ba kung sino ang nagmamay-ari ng nasabing bahay sa address

nayan?

S4 : Oo sir, bahay ni Gino Andrew Valencia a.k.a Gino.

T5 : Mayroon ka bang personal na kaalaman na si Gino Valencia ay nag

iingat ng mga baril?

S5 : Oo sir.

T6 : Alam mo ba kung anong klaseng baril ang itinatago ni Gino Valencia sa

Kanyang bahay?
S6 : Isang 9mm Taurus po at isang caliber 45.
T7 : Paano mo natiyak na 9mm Taurus at caliber 45 ang baril ni Gino?

S7 : Kasi mahilig ako sa baril at alam ko ang mga ibat ibang klase ng baril
kung anong brand nito.

T8 : Paano mo natiyak na may itinatagong baril si Gino at saan nakalagay?

S8 : Nakita ko po mismo doon sa loob ng bahay ni Gino ang nasabing mga

baril na nakalagay sa isang closet na kulay brown sa loob ng kanyang
kwarto at may baril din siyang nakatago sa loob ng kanyang sasakyan na
CRV kulay berde na nakalagay sa ilalim ng upuan.

T9 : Papaano mo naman nalaman na ang iyong binanggit na mga baril ay

pinag- iingatan ni Gino?

S9 : Ganito po, palagi akong pumupunta sa bahay nila Gino dahil ito ay
matagal ko nang kakilala at sa kanya ako kumukuha ng baril kapag may
titingin na buyer. Mayroon din siyang personal na baril na palagi niyang
sukbit at nakalagay sa kanyang sasakyan. Nakikita ko na inilalabas ni
Gino ang kanyang baril at minsan ito ay dinadala niya kapag siya ay
umaalis ng bahay. Matagal ko nang kakilala si Gino kaya alam na alam
kong may baril siya na nakatago sa loob ng kanyang bahay na nakalagay
sa loob ng kanyang kwarto na nakatago sa isang brown na closet sa loob
ng kanyang bahay.

T10 : Sa anong dahilan naman at nagbibigay ka ng iyong salaysay.

S10 : Upang maisyuhan ng Search Warrant ng hukuman ang bahay ni Gino

sa1507 Anastacio St., near corner Antipolo St., Barangay Guadalupe
Nuevo, Makati City.

AFFIANT FURTHER SAYETH NAUGTH:

JERALD TAYAMORA Y BORDA

(Deponent/Affiant)

SUBSCRIBED AND SWORN to before me this ____ day of February 2019 at

Makati City. Likewise, I have personally examined the affiant and I am fully satisfied
that the affiant voluntarily executed and understood his foregoing affidavit.

____________________________________
(Executive Judge)
 Republic of the Philippines
Philippine National Police
National Capital Region Police Office
Southern Police District
MAKATI CENTRAL POLICE STATION
STATION INVESTIGATION SECTION
Ayala Ave., Ext. cor. Yakal St., Makati City Tel. 843-7522

OFFICE OF THE EXECUTIVE JUDGE

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus - SW NO: ________________________

FOR : Violation of RA 10591
[Illegal Possession of Firearms
and ammunition]

GINO ANDREW VALENCIA

No. 1507 Anastacio St., corner Antipolo St.,
Barangay Guadalupe Nuevo, Makati City
Respondent.
x-----------------------------------------x

APPLICATION FOR SEARCH WARRANT

COMES NOW, the undersigned applicant, PCINSP GIDEON T INES JR, active
member of the Philippine National Police, presently assigned at the Makati City Police
Station, Makati City and designated as Chief, Criminal Investigation Section and
concurrent Chief, SDEU after having been duly sworn to in accordance with the law
states, that:

1. I am the applicant in applying for a Search Warrant on the premises of Gino

Andrew Valencia a.k.a. Gino located at No.1507 Anastacio St., corner Antipolo St.,
Barangay Guadalupe, Makati and occupied by the same person;

2. The undersigned strongly believes upon perusal and evaluation of the

statement and pieces of evidence submitted by Jerald Tayamora y Borda after his
arrest on February 8, 2019, at about 1:30 in the afternoon that Gino Andrew Valencia
had been reportedly concealing and is in possession of firearms and ammunitions
which is a violation of R.A. 10591 (Comprehensive Firearms and Ammunition
Regulation Act);

3. The premises owned/occupied by Gino Andrew Valencia a.k.a. Gino located

at No. 1507 Anastacio St., corner Antipolo St., Barangay Guadalupe Nuevo, Makati
City, have the following items, which could be used and/or intended to be used in the
commission of an offense and that could be a threat to other constituents. Among the
items under the custody, possession and/or control of Gino Andrew Valencia a.k.a
Gino Owner/Occupant of the above-mentioned address are kept and/or stored at the
abovementioned premises, particularly located in his closet color brown situated on his
living room inside the house and in his private vehicle described as CRV color green of
the subject person to wit:
 a. One (1) caliber 9mm firearms with ammunitions of the same
caliber
b. One (1) caliber .45 with several ammunitions of the same caliber

4. All the above-described articles and objects are kept and concealed in the
above-given address was seen by the deponent Jerald Tayamora y Borda, who was
arrested by the Intelligence operatives by virtue of a Search Warrant issued by this
Honorable Court.

5. In the deposition of witness, Jerald Tayamoira stated that subject person has
several firearms described above and are being kept inside his closet cabinet located
inside the living room.

6. Hence the undersigned applicant believes that Gino Andrew Valencia,

Owner /Occupant of the house/premises located at 1507 Anastacio St., corner Antipolo
St., Barangay Guadalupe Nuevo, Makati City is clearly violating R.A. 10591
(Comprehensive Firearms and Ammunition Act).

7. The undersigned applicant respectfully attached the following annexes to

support this application, to wit:

Annex “A” - Application for Search Warrant;

Annex “B” - Certification and Verification;
Annex “C” - Deposition of Witness;
Annex “D” – Spot Report of Implementation of SW
Annex “E” - Sketch of the location of the subject
Annex “F” – Referral signed by Acting Chief of Police

In view of the foregoing, the undersigned has strong reasons to believe that a
SEARCH WARRANT should be issued to enable the undersigned to conduct a search
at the house/premises of Gino Andrew Valencia and to take possession of the
above-mentioned properties to be brought before this Honorable Court.

PRAYER

WHEREFORE, PREMISES CONSIDERED, the undersigned prays to this

Honorable Court for the issuance of a search warrant authorizing him and his agents or
any peace officer, to search the premises described in his application at any time of the
DAY or NIGHT, and to seize the illegal FIREARM AND AMMUNITIONS that may be
found therein and bring to this Honorable Court, to be dealt with as the law may direct.

Respectfully submitted.

February ____, 2019, Makati City Philippines

PCINSP GIDEON T INES JR

Applicant

SUBSCRIBED AND SWORN to before me this ___ day of February 2019 in

Makati City, Philippines. I HEREBY CERTIFY that I have personally examined the
applicant and I am satisfied that he voluntarily executed the foregoing Application for
Search Warrant and that the allegations therein are true and correct of his own
knowledge.

_________________________
 Presiding Judge
CERTIFICATION AND VERIFICATION

I, THE UNDERSIGNED, under oath, depose and say that:

1. I am the applicant in the above-entitled application for Search Warrant;

2. I personally caused the preparation of the foregoing application for

Search Warrant and have read its content and the allegations therein,
which are true and correct to my own personal knowledge and belief.

3. I further certify that (a) I have not therefore commenced or filed any
application for a Search Warrant involving the same issues in any court,
tribunal or quasi-judicial agency and to the best of my knowledge, no
such other application for Search Warrant is pending therein; (b) If there
is such other pending Application for Search Warrant, I will therefore
inform this Honorable Court of the present status thereof; (c) If I should
thereafter learn that the same and similar application for Search Warrant
has been filed or its pending , I shall report that fact within five (5) days
there from to this Honorable Court, wherein the aforesaid application for
Search Warrant has been filed.

PCINSP GIDEON T INES JR

Applicant
 Republic of the Philippines
Philippine National Police
National Capital Region Police Office
Southern Police District
MAKATI CENTRAL POLICE STATION
OFFICE OF THE CHIEF OF POLICE
Ayala Ave., Ext. cor. Yakal St., Makati City Tel. 843-7522

February 19, 2019

Hon. Elmo M. Alameda

Executive Judge
Regional Trial Court, Branch 150
Justice Hall, Makati City

Dear Executive Judge Alameda;

Greetings!

Respectfully referred to your Honorable Court for appropriate action is an application

for Search Warrant for Violation of R.A. No. 10591 (Illegal Possession of Firearms
and Ammunition).

The undersigned strongly recommends approval of its issuance to allow the applicant,
PCINSP GIDEON T INES JR, Chief, Criminal Investigation Section and concurrent
Chief, SDEU of Makati City Police Station and his agents of the law to search the
premises of 1507 Anastacio St., corner Antipolo St., Barangay Guadalupe Nuevo,
Makati City owned or rented and controlled by herein respondent Gino Andrew
Valencia.

This will enable them to take into custody and present to this Honorable Court the
articles, which is the subject of the search and to be dealt with the law.

The undersigned prays unto this Honorable Court most favorable action.

ROGELIO P SIMON
Police Senior Superintendent
Chief of Police
 Republic of the Philippines
Philippine National Police
National Capital Region Police Office
Southern Police District
MAKATI CENTRAL POLICE STATION
OFFICE OF THE CHIEF OF POLICE
Ayala Ave., Ext. cor. Yakal St., Makati City Tel. 843-7522

MEMORANDUM

FOR : Director, CSG

(Attn: Chief, FED)

FROM : Chief of Police, Makati CPS

SUBJECT : Request for Record Check

DATE : February 19, 2019

--------------------------------------------------------------------------------------------------------------------

1. This pertains to the application for Search Warrant of PCINSP GIDEON T

INES JR, Chief, SIDMS of this police station wherein after casing and surveillance, the
target of the SW named Gino Andrew Valencia, residence of 1507 Anastacio St.,
corner Antipolo St., Barangay Guadalupe Nuevo, Makati City have found in his
possession one (1) caliber 45 and one (1) caliber 9mm firearms with several
ammunitions of the same caliber.

2. In this connection, respectfully request furnished this police station any

pertinent data/information of the above-named subject, if he legally owns a firearm.

2. Further request favorable action.

FOR THE CHIEF OF POLICE, PSSUPT ROGELIO P SIMON:

GIDEON TANGAN INES JR

Police Chief Inspector
Chief, SIDMS