Republic of the Philippines

DEPARTMENT OF JUSTICE
OFFICE OF THE PROSECUTOR
CITY OF MANILA

MAYA T. MANALOTO,
Complainant,

I.S. No. 111111

For: ACTS OF
LASCIVIOUSNESS

-versus-

MIKE S. LANSANGAN
Respondent
x-----------------------------------------------------x

ANSWER/COUNTER-AFFIDAVIT

I, MIKE S. LANSANGAN, Filipino, of legal age, single and a resident of

San Rafael Village, Tondo, Philippines, after having been duly sworn to in
accordance with law, hereby depose and state that:

1. I am the accused in Criminal Case No. 111111 for the crime of ACTS
OF LASCIVIOUSNESS under Article 336 of the Revised Penal Code;

2. I am employed as a school janitor of Marymount High School in the

City of Manila by providing services and grounds keeping activities,
cleaning and maintaining floor surfaces and windows, empty trash
receptacles and ensure appropriate disposing off of trash, and
cleaning restrooms and replenishing supplies;

3. I neither molest nor come up to the point of committing

lasciviousness acts to the Complainant (Maya T. Manoloto) as alleged
in her Complaint-Affidavit;
4. I deny all the allegations set forth in the Complaint-Affidavit for lack
of knowledge as to the truth of the said allegations, the truth being
that:

a. On the 3rd day of October, 2018, I was at the place of my work in

Marymount High School in the City of Manila supposedly working
the regular hours of duty from 8 o’clock in the morning to 5
o’clock in the afternoon;

b. That on the same day, while I was making my rounds, I saw

Manoloto inside the room with her male classmate Mr. Carlo
Aquino;

c. That I, asked them why they are still inside the classroom despite
the fact that it was already ten minutes past five in the afternoon,
Manoloto replied that she was still waiting for her father to pick
her up, and that Aquino was there to keep her company;

d. That, it was known in the school, even among the staff that the
two are in a current dating relationship, that, I was hesitant to
leave the two students alone because I will be risking my
employment when there are still students inside the room left
alone at such time;

e. That when I received the call from Mr. Pedro Martinez, part of the
maintenance team to hurry up to the auditorium because there
was a last minute request from Ms. Cynthia Dela Cruz,
Administrative Officer, to set up stage decorations, lights and
sounds for the activity to be conducted the following morning;

f. That, after receiving such call, I told the students for the last time,
to leave the said room but they did not respond anymore;

g. That, without seeing them leave the room, I proceeded to the

auditorium;

h. That, I was instructed by Mr. Martinez to get additional materials

from the stock room which is also located on the third floor;

i. That, when I reached the landing of the said floor, walking towards
the stock room, I saw Mr. Aquino walking away from the room
where I saw him and Ms. Manoloto earlier, I then proceeded to get
the additional materials needed, and after that, I checked the
room once again if anyone was there, and also to check if the door
was properly locked;
 j. That, upon inspection of the room, I saw Ms. Manoloto, in a
distressed condition, with her uniform partially unbuttoned, and
her face reddened. I approached her to check if everything was
okay, that I put my right arm across her shoulders to comfort her;

k. That, while my arm was on Ms. Manoloto’s shoulder, Mr. Silverio

Cagandahan, the security guard on duty, entered the room to
inform Manoloto that her father was already at the gate. That
upon knowing that her father was already at the gate, she
brushed my arm away, and stormed out of the room;

l. That I did not commit such a crime nor had the intent to do the
same;

5. The allegations stated in the Affidavit-Complaint are mere malicious

fabrications by the complainant which may have been spurred by the
bitter enmity harbored by members of her family.

6. I am executing this Counter-Affidavit for the purpose of attesting to

the truth of the foregoing statements, to inform the proper
authorities of the above facts, to support my prayer for the dropping
or dismissal of the instant case against me and for whatever purpose
this may serve best.

IN WITNESS WHEREOF, I have hereunto set my hand this

November 03, 2018 in the City of Manila, Philippines.

MIKE S. LANSANGAN
Affiant
SUBSCRIBED AND SWORN TO BEFRORE ME, this 3rd day of November
2018 in the City of Manila, Philippines. I further certify that I have personally
examined the herein complainant and I am satisfied that she voluntarily and
freely executed and understood her affidavit.

ATTY. CHRISTIAN POULEX SULIT

Notary Public
City of Manila, Philippines
PTR No: 04369143
MCLE Compliance No: 009142013

Doc. No: 123

Page No: 4
Book No: 5
Series of 2016.

CERTIFICATION

This is to certify that I have personally examined the herein affiant and
that I am satisfied that he voluntarily executed and understood his
statements in this Counter Affidavit.

GANDARA PARK
Prosecutor I