Supplemental Arguments
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Transcript of Supplemental Arguments
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7/31/2019 Supplemental Arguments
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Republic of the Philippines )
Quezon City ) S.S.
SUPPLEMENTAL-AFFIDAVIT
I, Sgt Mike Manuel Jarillo 828182 (MI) PA, of legal age, married, Filipino and presentlyassigned at OCPM, GHQ &HSC, AFP, CGEA, Quezon City, after having been sowrn to in
accordance with law do hereby depose and say:
1. This pertains with the complaint of Ms. Ana F. Raga of alleged Non-payment of debt
and Sexual Harassment filed against me;
2. With due courtesy of this Honorable Office of the Provost Marshal, it is mostrespectfully submit this supplemental affidavit to give some material facts that I have
failed to assert on the my counter-affidavit that was firstly submitted before this
Honorable Office to assail some other points of inconsistencies on her statement on her
Complaint-Affidavit which are as follows, to wit:
3. First, I admit paragraph 1 but Ms. Raga, in controverting her complaint, had contendedthat what I have paid from her were way below to the agreed ten percent (10%)
interests.
4. Assuming arguendo, that I never mentioned that, we have agreed upon that the mode of
payments of my loan shall be collected through my ATM card, the said ATM card was
served as the collateral of my principal loan from her.
5. Thus, there were no impossibilities for her to collect the payments of my loan for all the
while my ATM card was in her possession.
6. In fact, the same kind of scheme are customary practice between lenders and borrowers
that in every contract they entered to involving big amounts, it is common for them to
secure a collateral such as valuable items i.e. ATM cards and/or real properties,therefore, it is apparent in our transaction that when she handed me the ATM card, by
virtue of full payment of my debts, the intimidation, undue influence or fraud is
absence on my part, otherwise, she immediately reported the said actuations.
7. Second, I have no opportunity to have made a acknowledgement receipts since she
already collecting payments from my ATM account and the fact that we are comadre
and comparde it never bothered me to secure from her a receipts since we wereentrusting each others and the only proof I can presented are the statment of accounts
which can be determined where the transactions are made, and it can be idenbtified that
she made transactions on the ATM machines near from her residence which can besupported by Bank reports and statement of accounts.
8. Third, I would like to assail the charges she filed against me for sexual harrasment, for
clarificatory reason, the same is occured only in a work places and the person involves
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are employers who made sexual advances to their employees who exerising superior
authority over the latter which is out of conformity, nevertheless, her allegations of
sexual harrasment were merely fabricated and tainted of corrupt intent or ill motive notonly her purpose to incrimanate me but also to besmirch or debase my reputation as a
soldier, who, in the span of my service, I have no derogatory nor criminal records on
file.
9. Lastly, I would like to reitirate that all our debts of my wife from her were already been
fully paid more than the said principal amount we have borrowed from her, and whatpayments she demanded for are those interests she imposed with our principal loans
which was outrageous and not lecit in nature as we have guided by the law on credit
transactions that excessive imposition of interst must be regulated by the court. As it
can be gleaned of that she malisciously inserted and falsified the acknowledgementreceipts she presented before the office of the Provost Marshal indicating the with
10% until fully paid, which it clearly shows that she had maliciously added such
informtion just to influence others to convince with her allegation which it was obvious
from her that in her own she knows that the said loans were already fully paid and toensureshe has more claims to collected by adding such interest taht it was not reflected
before.
10. In the light of the foregoing, it is most respectfully prays that the complaint filed by the
above complainant be dismissed, not only on the basis of the pieces of the evidencepresented, also on the following grounds as follows:
a. her complainant was lacked of valid cause of action to pursue the said
complaint since there I already fulfilled my obligation from her and what shewas asking for was contrary to the tenor of our agreement the imposition of
excessive interest;
b. her complaint of allegedly sexual harrasment with the presented facts as I am
not performing superior authority against her and there is no employer-
employee releationship between us, and the character and place as she allegedfrom her complaint, where the alleged occurrence took place were not
intertwined. Since the same The burden
c. in the litany of the Supreme Court cases, similar at the case at bar, prior
exhaustion of remedies must first be instituted, provided that the due process
and imparial balance of the pieces of evidence must be carefully considered inorder not to prejudice the substantive rights of one who are being questioned.
11. For the substantial interest of justice, the undersigned respectfully submit to theintegrity and impartiality of this Honorable Office, the cases be dismissed on the basis
of the as a God fearing person and maintains a clean living as I have no intention to
tarnish the integrity of this duly established Office;
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12. Again, I am executing this affidavit to attest to the truth of the foregoing instrument and
for any legal purposes and intent this may serve.