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    Counter Affid Osok

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    Marceliano Monato III
    Jose "Totong" Osok provides a counter-affidavit to deny the charges of "grave threats" filed against him by Jundril N. Verano. Osok states that he is a native of the area and was unaware of the details and boundaries covered by the lease agreement between API and APIARBI Coop. On the date of the alleged incident, Osok approached two groups discussing a serious matter but claims he did not participate or make any threats. Through this counter-affidavit, Osok prays for the dismissal of the complaint filed against him.

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    Counter Affid Osok

    Uploaded by

    Marceliano Monato III
    38 views2 pages
    Jose "Totong" Osok provides a counter-affidavit to deny the charges of "grave threats" filed against him by Jundril N. Verano. Osok states that he is a native of the area and was unaware of the details and boundaries covered by the lease agreement between API and APIARBI Coop. On the date of the alleged incident, Osok approached two groups discussing a serious matter but claims he did not participate or make any threats. Through this counter-affidavit, Osok prays for the dismissal of the complaint filed against him.

    Original Description:

    Affidavit for Grave Threats

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    Jose "Totong" Osok provides a counter-affidavit to deny the charges of "grave threats" filed against him by Jundril N. Verano. Osok states that he is a native of the area and was unaware of the details and boundaries covered by the lease agreement between API and APIARBI Coop. On the date of the alleged incident, Osok approached two groups discussing a serious matter but claims he did not participate or make any threats. Through this counter-affidavit, Osok prays for the dismissal of the complaint filed against him.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    38 views2 pages

    Counter Affid Osok

    Uploaded by

    Marceliano Monato III
    Jose "Totong" Osok provides a counter-affidavit to deny the charges of "grave threats" filed against him by Jundril N. Verano. Osok states that he is a native of the area and was unaware of the details and boundaries covered by the lease agreement between API and APIARBI Coop. On the date of the alleged incident, Osok approached two groups discussing a serious matter but claims he did not participate or make any threats. Through this counter-affidavit, Osok prays for the dismissal of the complaint filed against him.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    Republic of the Philippines )

    Province of Agusan del Sur ) S.s


    x----------------------------------x

    COUNTER-AFFIDAVIT

    I, JOSE "TOTONG" OSOK, of legal age, Filipino, and resident of Poblacion, San Luis,
    Agusan del Sur, after having been duly sworn to in accordance with law do hereby depose
    and state:

    1. That I am the same persons charged under NPS. No. 13-03-INV-16A-030 for
    "GRAVE THREATS" filed by complainant JUNDRIL N. VERANO on January 20, 2016 at the
    Provincial Prosecution Office, Patin-ay, Prosperisdad Agusan del Sur.

    Background
    2. That I am a Manobo native and lived in the subject area since birth, and known
    the place very well. And the place have been part of ancestral domain of our ancestors since
    time immemorial, where they hunt animals for food and cultivate for farming.

    3. That the API rented from API-AGRARIAN REFORM BENEFICIARIES MULTI


    COOPERATIVE, INC. (APIARBI COOP for brevity) around one thousand four hundred twenty
    seven hectares (1427 ha.) with no specific address of coverage.

    4. A cursory reading of the original Lease Agreement bet APIARBI COOP and API,
    nothing in the said agreement which provided the details as to what lots or certificate of
    title subject of lease.

    5. That they themselves could not identify the exact locations of the metes and
    bounds of the rented place, and for a long time they have been indiscriminately planting
    areas in large breadth amounting two thousand hectares (2000 ha) more or less.

    6. The complainant's attached Original Certificate of Title is addressed in Manat,


    Trento, Agusan del Sur. However, the place of incident occured in Tudela, Trento, Agusan
    del Sur. This supports our argument that they do not know the coverage of their lease
    agreement.
    Narration of Events

    Page 1 of 2
    Counter Affidavit of JOSE "TOTONG" OSOKNo. 13-03-INV-16A-030 for "GRAVE THREATS".
    7. That on December 8, 2015, I have seen from a distance MINDANIO "DANAO"
    MIQUE, LINDEY "LOLOK" MIQUE ROLDAN "ABEL" BORANTES standing in the road with
    Erpie Mancawan-Chief Security of API, complainant JUNDRIL N. VERANO, and 7 SCAA
    bearing arms and more than thirty (30) weed-workers bearing Lagarao nearby.

    8. When I sensed that they have discussion on serious matter, I approached the two
    groups because I want to know what it is all about.

    9. Complainant JUNDRIL N. VERANO requested me to submit proposal, which I have


    no idea what he is referring to. Later, I can deduced from the statement that he means a
    proposal about what we want to demand with the API. And I told him "paabot lang sir kay
    amo pa ning plastaron" (Just wait sir, because we ha have to place this in order).

    10. That after such date of events, I have received a summon from the barangay and
    later on received subpoena.

    11. I was surprised when my name is included among those who were charged with
    "grave threats"

    12. That I have no participation in such incident whatsoever.

    Prayer
    That I am executing this counter affidavit to attest to the truth of the foregoing
    statement and to pray for the dismissal of the complaint filed against me.

    I WITNESS WHEREOF, we herby affix our signatures this ____________________ in


    ____________Agusan del Sur, Philippines.

    JOSE "TOTONG" OSOK


    Affiant

    SUBSCRIBED and sworn to before me on June____________, 2015 in


    _____________________ Agusan del Sur.

    Page 2 of 2
    Counter Affidavit of JOSE "TOTONG" OSOKNo. 13-03-INV-16A-030 for "GRAVE THREATS".

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