Republic of the Philippines)CITY OF ZAMBOANGA. . . . . ) S. S.X- - - - - - - - - - - - - X

JOINT COUNTER AFFIDAVIT

We, ____________, single, and __________, widow, all of legal age, and residing at __________________, after having been sworn in accordance with law, hereby depose and say:

1. That we received a subpoena in I.S. No. 07-00000000 for alleged Grave Threats requiring us to submit our counter-affidavit to the complaint consisting of the Sworn Statement of a certain NAME OF PERSON;

2. That we vehemently deny the charge or insinuations of the complainant against us that we have committed or conspired with other persons to commit or that we have done acts constituting the offense alleged in the complaint;

3. That the truth of the matter is that I, NAME OF PERSON, am the lawful owner and possessor of subject of the present complaint known as Lot 0 situated at _____________________ and which Lot I acquired by way of a Deed of Sale executed by its lawful owners and possessors Spouses ________ and __________;

4. That as the owner and lawful possessor by purchase of the said property, I, ____________, am actually residing in the said property, which include a residential house which used to be owned by the sellers thereof, since January 2011.

5. That prior to the sale of the said property, the complainant, by the kindheartedness and tolerance of the ___Name___ spouses, allowed her to construct a small house within the lot after the complainant pleaded with them to allow her to stay since, according to her, she did not have a place where to stay.

6. After the sale of the lot, however, the Name_ spouses have advised the complainant to leave the premises since they have already sold it and so, sometime in March 2012, complainant, who also had frequent quarrels with others in the neighborhood, left and abandoned the said house and went to reside elsewhere.

7. That subsequently, there were people who came to inquire if the house constructed by _________ in the premises was for sale or rent. This prompted us to put a sign that the house is not for sale nor rent. When ____________ came to know about it, she came to the place and destroyed the sign which

prompted us to put another sign in place of the one destroyed.

8. That in order to protect the property, we reinforced the fence in front of the premises using coco lumber. On 25 November 2013, complainant __________ came to the vicinity and destroyed the fence and tried to force herself into the premises. When we came to know of her presence and her acts of violence, we came out to see her and asked why she was destroying the fence and advised to desist from the same.

9. That complainant then started to shout invectives at us while running to and fro saying “Mga bobo. Wala kayong titulo. Mga skwater lang kayo. Kayak o magbayad ng tayo para patayin kayo” after which she left the place.

10.That from then on, complainant continued to harass us by bringing unknown persons to the place as though to intimidate us. Sometime in December 2013, she also brought some policemen to the place in the company of media men. And sometime in January 2014, she same to the premises and tried to destroy the fence with the use of a hammer.

11.That it is thus not true that __________ has her residence in the premises, or that she owned the said house or that we threatened her. On the contrary, it was complainant who committed malicious mischief or attempted to commit trespass to our dwelling, or threatened in an unlawful manner and slandered us.

12.That as the lawful possessor of the premises in question, we have the perfect right fence it and to exclude other from the use and enjoyment of the same and for this purpose, may use such reasonable force and may be necessary in order to prevent or repel any threatened or actual physical unlawful invasion of the same by another.

13.That attached hereto as Annexes “2” and “3” are the Affidavits of __________ and _____________;

14.That we are executing this Affidavit to refute the charges against us and for all the purposes that this may serve under the law.

IN WITNESS WHEREOF, we have hereunto set our hands on this ____ of February 2014, in the City of Zamboanga, Philippines.

______________ _______________

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Affiant Affiant

SUBSCRIBED AND SOWRN to before me by the Affiants on this ___ day of February 2014 in the City of Zamboanga, Philippines.

I HEREBY CERTIFY that I have personally examined the affiants and that I am satisfied and convinced that they voluntarily executed the same.

Republic of the Philippines)

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CITY OF ZAMBOANGA. . . . . ) S. S.X- - - - - - - - - - - - - X

JOINT AFFIDAVIT

We, ________ and __________, married, all of legal age, and residing at Barangay, province, city, municipality after having been sworn in accordance with law, hereby depose and say:

1. That we personally know __________ and ___________, both of whom are respondents in a case for Grave Threats who, we understand, are required by the authorities to submit their counter-affidavit to the complaint consisting of the Sworn Statement of a certain _____________ with alleged residence at ______________________________;

2. That there is no truth to the charge or insinuations of the complainant against said respondents that they have committed or conspired with other persons to commit or that that they have done acts constituting the offense alleged in the complaint;

3. That the truth of the matter is that Name of person, is the lawful owner and possessor of the Lot subject of the present complaint known as Lot 0 Block 0 situated at _____________________

4. That she acquired the said Lot by way of a Deed of Sale which we executed in her favor as lawful possessors and holders of right over the same.

5. That as the owner and lawful possessor by purchase

of the said property, Name of person, actually resides in the said property, which include a residential house which used to be owned by us as the sellers thereof.

6. That prior to the sale of the said property to ____, we, out of our kindheartedness and tolerance, allowed an acquaintance, __________ to construct a small house within the lot after she pleaded with us to allow her to stay since, according to her, she did not have a place where to stay after she and her family were told to leave their place of abode.

7. That, as above-stated, we sold the our house and lot to ____________ who, from then on, resided in and possessed the said premises.

8. That we sold the lot, we demanded the complainant ___________ and her live-in partner to vacate and leave the premises;

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9. That _________ and her live-in partner, who had frequent quarrels with others in the neighborhood, left and abandoned the said house and went to reside elsewhere, bringing with them all their things. As a matter of fact, some of our neighbors, and me, ____________, even helped them put their things on a white truck which they hired for the purpose.

10. That we are executing this Affidavit to refute the allegations of complainant against ___________ and her mother and for all the purposes that this may serve under the law.

IN WITNESS WHEREOF, I have hereunto set my hand on this ____ of February 2014, in the City of Zamboanga, Philippines.

____________________ _________________ Affiant Affiant

SUBSCRIBED AND SOWRN to before me by the Affiant on this ___ day of February 2014 in the City of Zamboanga, Philippines.

I HEREBY CERTIFY that I have personally examined the affiant and that I am satisfied and convinced that he voluntarily executed the same.

Republic of the Philippines)

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CITY OF ZAMBOANGA. . . . . ) S. S.X- - - - - - - - - - - - - X

AFFIDAVIT WITNESS

I, ____________, of legal age, married, and residing at _________________________, after having been sworn in accordance with law, hereby depose and say:

1. That I personally know ____________ and ____________, who are respondents in a case for Grave Threats based on the complaint consisting of the Sworn Statement of a certain _______________with alleged residence at _______________;

2. That there is no truth to the charge or insinuations of the complainant against said respondents that they have committed grave threats against her;

3. That the truth of the matter is that ___________, is the lawful owner and possessor of the Lot subject of the present complaint known as Lot ________________________ where she is actually residing;

4. That on 25 November 2013, complainant ___________ came to the vicinity and destroyed the fence and tried to force herself into the premises;

5. That when __________ came to know of her presence and her acts of violence, she and her mother came out to see __________ and asked why she was destroying the fence and advised to desist from the same.

6. That complainant then started to shout invectives at them while running to and fro saying “Mga bobo. Wala kayong titulo. Mga skwater lang kayo. Kayak o magbayad ng tayo para patayin kayo” after which she left the place.

7. That from then on, complainant continued to harass __________ by bringing unknown persons to the place to intimidate them. Sometime in December 2013, she also brought some policemen to the place in the company of media men. And sometime in January 2014, she same to the premises and tried to destroy the fence with the use of a hammer.

8. That I am executing this Affidavit to refute the allegations of complainant against _________ and her mother and for all the purposes that this may serve under the law.

IN WITNESS WHEREOF, I have hereunto set my hand on this ____ of February 2014, in the City of Zamboanga, Philippines.

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___________________ Affiant

SUBSCRIBED AND SOWRN to before me by the Affiant on this ___ day of February 2014 in the City of Zamboanga, Philippines.

I HEREBY CERTIFY that I have personally examined the affiant and that I am satisfied and convinced that he voluntarily executed the same.

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