Republic of the Philippines
Department of Justice
NATIONAL PROSECUTION SERVICE I
PROVINCIAL PROSECUTOR’S OFFICE
Vigan City, Ilocos Sur
LOVELY ANNE JOY C. LAZO, NPS DOCKET NO. I-06-INV-0108-006969
MIRELA A. VERZOSA
Complainant/s.
-versus- FOR: ________________________
ARYAN CESAR J. MANGLAPUS,
RAQUEL A. BASABAS
JOHANNA A. VILORIA
Respondent/s.
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COUNTER AFFIDAVIT
I, ARYAN CESAR J. MANGLAPUS, RAQUEL A. BASABAS and JOHANNA A.
VILORIA, all of legal age, all single, Filipino Citizens and residents of Concepcion,
Cervantes, Ilocos Sur , Sto. Tomas, Candon City, Ilocos Sur and San Jose, Narvacan,
Ilocos Sur, Philippines, respectively, after having duly sworn to in accordance with law
do hereby depose and state that:
1. We received a subpoena on ______________________ directing us to file my
answer to the complaint-affidavit of complainants Lovely Anne Joy C. Lazo and
Mirela A. Verzosa for oral defamation within 10 days from receipt thereof;
2. We deny all the allegations contained in the complaint-affidavit of complainant,
the truth being that:
a. It was not true that we were eyeing complainant Lovely Anne Joy Lazo
according to her co-complainant but instead we were just having a usual “guy
sight-seeing” in the Plaza Maestro Commercial Complex, Vigan City, Ilocos
Sur on January 30, 2019 on or about 10 o’clock in the morning;
b. It was not true also that my co-respondents RAQUEL A. BASABAS,
JOHANNA A. VILORIA AND I uttered those offensive remarks to plaintiff
LOVELY ANNE JOY C. LAZO. Those accusations are false and unfounded.
The plaintiff is having a day dream or hallucinating when she alleged that we
have spoken those unpleasant words to her;
c. We were surprised when complainant LOVELY ANNE JOY C. LAZO swiftly
ran towards our direction, forcefully grabbed my hair and shoulders until I fell
in the concrete pavement. After falling, she even continued to grab my hair
and started screaming “Hoy! Aryan nga agin-e-emma ka paylaeng! Nakitak
mismo diay cellphone message ni boyfriend ko nga say-sayatem isuna!
Gayam, nakar-karo gayam ti kinapokpok, kinap*tam ken kinagatel mo
kanyak! Haan ko expektaren nga pati toy boyfriend ko sulutem! Usto talaga
diay kun-kunada nga ti nasa loob ang kulo ng mga tahimik! She also even
clawed my neck and chest;
d. While the incident was on-going, my co-respondents RAQUEL A. BASABAS
and JOHANNA A. VILORIA tried stopped complainant LOVELY ANNE JOY
LAZO from her violent acts and pacified them;
e. However, complainant MIRELA VERZOSA likewise grabbed the hair of
respondents RAQUEL BASABAS and JOHANNA VILORIA to remove them
from the incident and started shouting “Hoy! Duwa nga pu-p*ta haan yo
pagtin-nulungan ni sisterets ko! Pudno met a nalas-lasbang suna ngem deta
pabebe nga gayyem yo nga ni Aryan!”
f. The customers and other people in the shops even went out to see what the
commotion all about was. It was the offensive acts and words complainant
LOVELY ANNE JOY LAZO that prompted respondent ARYAN CESAR
MANGLAPUS to punch the latter to her face;
g. The punch of respondent ARYAN CESAR MANGLAPUS did not deter
complainant LOVELY ANNE JOY LAZO instead continued to scream
slanderous remarks to the former;
h. While the commotion was going on, the alarmed public who witnessed the
incessant fighting, particularly KAYANA ATHENA LINDA TEJANO
immediately went to the Plaza Maestro Security Office (PMSO) to report the
same. Attached is the Affidavit of Witness/Sworn Statement of Ms. Tejano
as Annex “1;”
i. After due notice to the PMSO, Chief Security Officer JULIUS CESAR
BLANDO ran to the place of incident, interceded to the dispute and
successfully halted the dispute. Attached is the Affidavit of Witness/Sworn
Statement of CSO Blando as Annex “2;”
j. When the tiff was successfully ceased, it was not the respondents who ran
from the incident but it was the complainants LOVELY ANNE JOY LAZO and
MIRELA VERSOZA who escaped towards the other direction because of the
fast – approaching security officers called by CSO Blando witnessed by one
of our schoolmates, JIE-YANNAH MARYL SINGSON. Attached is the
Affidavit of Witness/Sworn Statement of Ms. Singson as Annex “3;”
k. While complainants LOVELY ANNE JOY LAZO and MIRELA VERSOZA
evaded the group of security officers, they endlessly yelled “Addanto aldaw
yo kanyami nga tallo a la-laad! La-la-laad! Sa-sayet! Pu-p*ta!.”
l. After the incident have finally ended, respondent ARYAN CESAR
MANGLAPUS was rushed to the nearest hospital, the TWO BROTHERS
TERTIARY HOSPITAL for timely medical attention;
m. As per diagnosis of DR. CHRISMA JEAN NELVIS, respondent ARYAN
CESAR MANGLAPUS seriously sustained abrasions and lacerations
needing more or less two-weeks for its healing. Attached is Affidavit of
Witness/Sworn Statement of Dr. Nelvis and Medico-Legal as Annex “4”
and “5” respectively;
3. Complainants’ unrefined remarks and acts have injured our name, reputation and
character before the public and other people who knew us. By reason of the
foregoing, we suffered sleepless nights, wounded feelings, besmirched
reputation, moral and social embarrassments which complainants should
compensate by way of the following damages
a. MORAL DAMAGES -
b. EXEMPLARY DAMAGES -
c. NOMINAL DAMAGES -
d. TEMPERATE DAMAGES -
e. ACTUAL DAMAGES -
f. LIQUIDATED DAMAGES -
TOTAL
4. We are executing this counter affidavit in order to attest to the truth and veracity
of the foregoing statements and to refute the allegations of LOVELY ANNE JOY
LAZO and MIRELA VERZOSA in their complaint affidavit and more specifically,
for the purpose of filing a criminal complaint for ORAL DEFAMATION AND
LESS SERIOUS PHYSICAL INJURIES against LOVELY ANNE JOY LAZO and
ORAL DEFAMATION against MIRELA VERSOZA, both legal age, single,
Filipinos and residents of 123 Bayubay Sur, San Vicente and 456 Salindeg,
Vigan City, Ilocos Sur respectively and for any legal purpose.
FURTHER AFFIATH SAYETH NONE
IN WITNESS WHEREOF, We have hereunto set my hands this _____ day of
_______ in the City of Vigan, Province of Ilocos Sur, Philippines.
ARYAN CESAR J. MANGLAPUS
Affiant
RAQUEL A. BASABAS JOHANNA A. VILORIA
Affiant Affiant
SUBSCRIBED AND SWORN TO before me this _________________ in the City
of Vigan, Province of Ilocos Sur,Philippines. I certify further that I have personally
examined herein affiant and I am satisfied that they understood the contents of their
counter affidavit and voluntarily executed the same.
Copy furnished:
1. Lovely Anne Joy C. Lazo
123 Bayubay Sur, San Vicente, Ilocos Sur
2. Mirela A. Verzosa
456 Salindeg, Vigan City, Ilocos Sur
