Tiaga Counter Affidavit

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REPUBLIC OF THE PHILIPPINES


DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
DAVAO CITY

PATRICIA NICOLE DELA CRUZ Docket No: 00002


Complainant ,
-versus-
LEO PAUL TIAGA For: Violation of Article 308
Respondent. Of REVISED PENAL CODE

x---------------------------------------x
COUNTER – AFFIDAVIT
I, LEO PAUL TIAGA, of legal age, Filipino, single, and a
resident of Blk.6 Lt.2 Kasaganaan Mutual Homes, Catitipan, Davao
City, after being duly sworn in accordance with law, hereby depose
and state:
1. I am the respondent in the complaint filed by PATRICIA
NICOLE DELA CRUZ, which alleges theft against me
under Article 308 of the Revised Penal Code.
2. I categorically deny all allegations of theft made against
me. I was not present at the parking lot of Gaisano Mall
Davao on September 25, 2024, at approximately 6:00 PM,
and I have no knowledge of the incident described in her
affidavit.
3. On that date and time, I was at home with my family,
preparing dinner. My parents and siblings can confirm my
presence there, as we all gathered together at
approximately 5:30 PM and spent the evening discussing
our day and sharing a meal.
4. Furthermore, I contest the claim that any witness saw me
leaving the area with a bag matching hers. If there was
indeed a witness, I would request that such a person be
brought forward to provide a statement.
5. The accusation has caused me significant distress, as I am
being wrongfully implicated in a crime I did not commit.
This situation has adversely affected my personal and
professional life.
6. I affirm that I am prepared to cooperate with law
enforcement authorities in any investigation related to this
matter to prove my innocence.
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7. I am executing this counter-affidavit to assert my rights and


to formally contest the allegations made against me by Ms.
Dela Cruz.
8. I attest to the truth of the foregoing statements based on
my personal knowledge and belief.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed


that the instant criminal complaint against the respondent be
DISMISSED for lack of sufficient evidence and merit.

Further, the respondent respectfully prays for such other reliefs as may
be deemed just and equitable in the premises.
IN WITNESS WHEREOF, I have hereunto affixed my signature
nd
this 2 of October, 2024 at Davao City, Philippines.

LEO PAUL TIAGA


Affiant

SUBSCRIBE AND SWORN to before me this 2nd day of


October, 2024 in the City of Davao, Philippines. and hereby
certify that I have personally examined the affiant and am
satisfied that he voluntarily executed and understood this
counter affidavit.

NOTARY PUBLIC

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