Republic of the Philippines )

Quezon City ) s.s.

COUNTER-AFFIDAVIT
Re: I.S. No. 5092409

I, JUNIPER R. MAGDALEO, of legal age, resident of 14 Aguinaldo Drive, Ayala Hills,

Quezon City, with assistance of counsel, do hereby state under oath that:

1. I am forty-six (46) years old, residing in Malolos, Bulacan, and the business owner of
a single proprietorship “Chicken and Feeds” with the purpose of raising and selling poultry;

2. I recently learned that I have been made a respondent in I.S. No. 5092409, a charge
for HOMICIDE filed by a certain TERESITA H. TIMBOL (Teresita) on 2 October 2018 before
the Office of the City Prosecutor for Quezon City;

3. The charge is based on my allegedly entering their house on 23 March 2011 and
stabbed ALBERTO H. TIMBOL (Alberto), the complainant’s husband due to his demand of
payment of money I had allegedly borrowed from him.

4. There is no truth to the allegations in TERESITA’s complaint. There is no factual nor

legal basis to charge me with HOMICIDE. The Complaint must be dismissed. To rebut and
contradict TERESITA’s malicious lies, I set forth the true circumstances below:

4.1. That I had known ALBERTO H. TIMBOL since high school in La

Salle Greenhills but was not a close friend of his, having last seen him in the 10th
Anniversary Reunion in 1998;

4.2. That I have never borrowed money from ALBERTO which alleged in
the complaint as the reason for the ill-will between us since he demanded
payment which I could not repay;

4.3. That I could not have been in Manila on the alleged date of crime on
23 March 2011 since I was in Los Angeles, California that time to visit my sister
and her family, as evidence by my boarding pass on flight RJ 209 and affidavits
of relatives of my being in the U.S. at that time, attached in Annex A and B;

6. For this reason, it is certainly incomprehensible that I should stand accused of

HOMICIDE by MRS. TERESITA H. TIMBOL since the elements of homicide are not proven. I
had no motive nor intent to kill the victim as was not present in the house of the complainant on
the alleged night of the crime.

7. Considering the foregoing, I respectfully submit that there is no prima facie basis to
conclude that the crime of homicide or that any crime at all has been committed. The Complaint
against me should, thus, be dismissed.

TO THE TRUTH OF THE FOREGOING, I have signed this Statement on 22 October

2018.

JUNIPER R. MAGDALEO
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME this 23rd day of October 2018

HENRY R. CANLUBANG
 Investigating Prosecutor

CERTIFICATION

I HEREBY CERTIFY THAT I HAVE PERSONALLY EXAMINED THE AFFIANT

AND AM SATISFIED THAT HE VOLUNTARILY EXECUTED AND UNDERSTOOD HIS
AFFIDAVIT.

HENRY R. CANLUBANG
Investigating Prosecutor