REPUBLIC OF THE PHILIPPINES
OFFICE OF THE PROSECUTOR
Makati City
MELCHOR LYLE C. TAGALOG, I. S. No. 11211
Complainant, For: Theft
-versus-
RAMON A. SANTAMARIA
Respondent,
COUNTER-AFFIDAVIT
I, RAMON A. SANTAMARIA, of legal age, Filipino, with home address at 157 P. Ocampo St.,
Brgy. Washington, Makati City, after being sworn to in accordance with law, hereby depose and state
that:
1. I am the neighbor of MELCHOR LYLE C. TAGALOG who resides at 156 P. Ocampo St., Brgy.
Washington, Makati City;
2. I recently learned that I have been made a respondent in I.S. No. 11211, a charge for THEFT
filed by MELCHOR LYLE C. TAGALOG on September 16, 2020 before the Office of the City
Prosecutor of Quezon City;
3. On May 17, 2008, I received a Subpoena from said Office requiring me to submit a Counter-
Affidavit within ten (10) days from such receipt;
4. The charge is based on the allegation that I sneaked into the house of MELCHOR LYLE C.
TAGALOG on September 12, 2020, 9 p.m., and steal his gold Rolex watch;
5. To rebut the allegations of MELCHOR LYLE C. TAGALOG, I hereby as Annex A respectively, a
plane ticket issued by the Philippine Airlines;
6. The attached plane ticket will indicate that I left for China on September 10, 2020 only to
return on September 13, 2020, it is therefore, impossible for me to commit the acts alleged
by MELCHOR LYLE C. TAGALOG;
7. Considering the foregoing, I respectfully pray that I be acquitted of the crime of THEFT
wrongfully imputed upon me by MELCHOR LYLE C. TAGALOG.
TO THE TRUTH OF THE FOREGOING, I have signed this Counter-Affidavit on May 20, 2020.
RAMON A. SANTAMARIA
Affiant
SUBSCRIBED AND SWORN to before me, this 20th day of September at Makati City, by Melchor
Lyle C. Tagalog, who exhibited to me (his/her) Passport ID No. EC1879016 issued at DFA NCR
NORTHEAST, Philippines on the 20th day of February, 2018.
FRANCO J. ALBINO
Investigating Prosecutor
CERTIFICATION
I hereby certify that I have personally examined the affiant and that I am satisfied that he voluntarily
executed and understood his affidavit.
FRANCO J. ALBINO
Investigating Prosecutor
ANNEX A