REPUBLIC OF THE PHILIPPINES

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COUNTER-AFFIDAVIT
I, , 68 years of age, Filipino, widow of after being sworn in
accordance with law, hereby depose and state that:
1. I am the person who is charged for the crime of parricide in
Criminal Complaint No. 1234;
2. I vehemently deny all the allegations in the complaint filed
against me for being false, fabricated and malicious,
calculated to harass me and motivated by jealousy and
revenge by my brother-in-law;
3. In contrast to such malicious intent of my brother-in-law, I
truthfully state:
a.

That Isao and I first met and became romantically

involved in

b.
That on June 2, 1961, I gave birth. family and my
family decided not to contract marriage at that time
because I was minor but agreed to contract marriage
after I finish
my college education;
c.

That sometime in 1964 before the agreed date of our

marriage, Isao and I separated. Isao continued
supporting our daughter Maria until she finished her
studies and they remained close despite the fact that
we have our own respective families;

d.

That on May 1, 2012, years old and

years old
respectively, without any legal impediment got
married at Saint Peter and Paul Basilica, which was
attended by our relatives and friends;

e.
That on July, 2012, I brought my husband
Isao
to
because he kept on complaining of dizziness and shortness
of breath which gave him discomfort even at night. He
was attended by his physician s who already knew
the history of my husbands ailment;

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f.

That informed me that my husband had a serious lung

problem called Chronic Obstructive Pulmonary Disease
(COPD) and it was
diagnosed last January, 2010
and such deceased is incurable. told me that since
2010 cyanide substance (0.10 parts per
million)
was already found in my husbands blood which
rapidly
affected his health condition especially that
he is already old. That
the amount of cyanide
substance in the blood of Isao
decreased to
0.04
parts per million;

g.

That according to, when he discovered that the source

of cyanide substance in my husbands blood was
from his workplace, he advised my husband to give up his
job to totally flash
out the cyanide substance in his
blood;
h.
That my husband worked for which uses cyanide in the
production of synthetic fiber
and plastics. He resigned
in March 2010 when his cough started to
get worse and
started to feel dizziness and shortness of breath;
i.

That since July, 2012, I accompanied my husband to

once a month for check-up and oxygen therapy with
pulmonary
rehabilitation to teach him how to breathe
in correct ways to stay
active and to lengthen his life;
j.

That on or about 10:30 in the evening of December

13, 2013, I found my husband in our room on the floor
with his face facing down the
floor. I immediately
called his name and touch him but I received no
response. Not sure of what I should do, I called
and told him of my husbands situation. Dr. said that
he will
come as soon as possible;

k.

Then I started to panic so I called the Police station

telling them that my husband might be dead due to
cardiac arrest. I remember also calling my brother-in-law
telling him the same thing;
l.

That I sat beside my husband calling his name over

and over again and praying so hard that help will be
here soon. Then I felt that someone touched my
shoulder and guided me to sit on our bed that was
when I recognized checking my husband and doing
CPR. declared my husband dead at 10:45 in the
evening of
the same date;

m.

Then the Police arrived followed by my brother-in-law

who was asking so many questions and that was when
I felt severe
headache and became unconscious;
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n.
That when I woke up I learned that the police is about
to conduct
a post mortem examination ony husbands
body and that my
brother-in-law strongly accused me of
killing my husband;
o.

That the cause of death according to who first

attended my husband at the time of his untimely
death and my husbands physician since 2010
was
cardiac arrest due to his
Chronic Obstructive Pulmonary
Disease;
p. That the presence of cyanide substance in the blood of
my husband has been detected since January, 2010 with
the development of my husbands Chronic Obstructive
Pulmonary
Disease (as stated in par. f);
q.
That nothing in the initial police report conducted by
SPO4
Mabuting Pulis stating that there were traces of
cyanide in the maintenance medicine bottle of my
husband and inside a plant pot;
4. I am executing this counter affidavit to attest to the truth of
the foregoing statement and to pray for the dismissal of the
complaint-Parricide against me.
TO THE TRUTH OF THE FOREGOING, I have signed this
Counter-Affidavit on December 29, 2014
Affiant
SUBSCRIBED and SWORN TO BEFORE ME, this 29th day
of December 2014 at presenting her drivers license no. 0011253A valid until July 2015 and I hereby CERTIFY that the affiant
personally appeared before me and hereby verify that she
voluntarily executed this counter-affidavit, she has read and
understood the contents thereof which are true and correct of her
own knowledge and information.
Notary Public
Until December 31, 2015
Attorneys Roll No. 333156, April 31, 2009
MCLE Compliance No. II-000199; 01-03-2012
MCLE Compliance No. III-123456; 06-01-2014
PTR No. 158755; 01-10-2010
IBP No. 681410; 04-30-2011,
www.into.1234 @yahoo.com
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Doc. No.
Page No.
Book No.
Series of 2014

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