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Republic of the Philippines

Ninth Judicial Region


REGIONAL TRIAL COURT
Zamboanga City, Branch 3
PEOPLE OF THE
PHILIPPINES,
Plaintiff,
-versus-

Crim. Case. No. 12-345 and 12-346


FOR: Violations of Sec. 5 and 11 of
R.A. 9165

JOSE BEBE DELA CRUZ,


Accused.
x-----------------------------------------x
JUDICIAL AFFIDAVIT OF THE WITNESS
GREG LEDESMA
This Judicial Affidavit of the accused, Greg Ledesma, is executed to
serve as his direct testimony in the instant case. This Judicial Affidavit is
offered to prove that no buy-bust operation was actually conducted; instead,
the accused was forced to place his finger prints in the allegedly recovered
sachet of shabu and the marked FIVE HUNDRED PESO BILL;
QUESTIONS were propounded by plaintiffs counsel, Atty. Varellie
Vargas in English, which the affiant fully understands, while the ANSWERS
were given by the witness GREG LEDESMA in Tagalog, and the
corresponding translation of his Answers is provided after each question.
1. Do you swear to tell the truth, the whole truth and nothing but the
truth?
Answer: I do.
2. Are you aware that you may face criminal liability for false
testimony or perjury if you will not tell the truth?
Answer: I am.
3. Please state your name, age, address and occupation.
Answer: I am GREG LEDESMA, Filipino, 30 years old and a
resident of PO box 200, Camanchile Drive, Zone 3, Zamboanga
City. I am currently unemployed.
4. Please tell me how you are related to the accused.

Answer: I am his next-door neighbor.


5. Where were you at the time of the alleged sale of prohibited drugs?
Answer: I was with Jose Bebe Dela Cruz in their house watching
television when the alleged sale happened.
6. Can you describe what happened during the day of the alleged
sale?
Answer: Yes. We were watching television when a man knocked
on the gate of Bebes house. We both went to the gate. Bebe
slightly opened the gate and asked the person to identify himself.
That person said that he was a policeman. Bebe let him in. He then
asked Bebe to hold a small plastic bag which Bebe held after being
taunted with a gun. He then gave Bebe Five Hundred Pesos for
holding the bag. After a few minutes, more policemen barged in
and arrested Bebe. I tried to stop the policemen, but they easily
outnumbered me, forcefully pushing me away while holding guns
against my face.
7. How far were you from Bebe and the police officer?
Answer: Not far. I was just a foot or two away from them. I can
clearly see the commotion and hear what they were saying.
8. What did the police officer tell Bebe before handing the plastic
bag?
Answer: He said pakihawakan muna to while handing Bebe the
small plastic bag. When Bebe refused, he raised his voice, waved
his gun threateningly and said, hawakan mo to kung ayaw mo ng
problema.
9. When handing the Five Hundred Peso bill, what did the policeman
say?
Answer: He handed Bebe the Five Hundred Peso bill, took the
plastic bag, and said, salamat sa kooperasyon. After about two
minutes, other policemen barged into the scene.
10. Aside from you, Bebe and the police officer, were there other
people inside the house?
Answer: None.

IN WITNESS WHEREOF, I have hereunto set my hand this 14th


day of January 2015 at Zamboanga City.
GREG LEDESMA
AFFIANT
SUBSRIBED AND SWORN to before me this 14th day of January
2015 at Zamboanga City.
VARELLIE C. VARGAS
COUNSEL FOR THE ACCUSED
2nd Floor BGIDC Building
Gov. Lim Avenue, Zamboanga City
Roll No. 123456 / 5-2-12
IBP No. 891011 / 12-29-14
PTR No. 654321 / 12-29-14
MCLE Compliance No. 110198 / 01-05-2015
Doc No: 13
Page No: 29
Book No: VIII
Series of 2015.
I, ATTY. VARELLIE VARGAS, of legal age, Filipino, with postal
address 2nd Floor BGIDC Building Gov. Lim Avenue, Zamboanga City,
after being duly sworn depose and say that:
1. I was the one who conducted the examination of witness Greg
Ledesma at my aforementioned office 2nd Floor BGIDC Building
Gov. Lim Avenue, Zamboanga City;
2. I have faithfully recorded or caused to be recorded the questions I
asked and the corresponding answer that the witness gave; and,
3. I or any other person then present or assisting me did not coach the
witness regarding her answers.
IN WITNESS WHEREOF, I have hereunto set my hand this 14th day
of January 2015 at Zamboanga City Philippines.

ATTY. VARELLIE VARGAS


AFFIANT

SUBSCRIBED AND SWORN to before me this 14th day of January


2015 at Zamboanga City, Philippines, affiant exhibiting her IBP ID No.
891011 issued at Zamboanga City on December 06, 2014.

ATTY. BENSAUD O. DEGUSMAN


NOTARY PUBLIC
Commission Serial Number: 123221
Notary Public for Zamboanga City
Until December 31, 2015
Nunez St. Zamboanga City
Roll No: 99821
IBP Lifetime Roll No: 22314, 1/2/12; Zamboanga City
Professional Tax Receipt No: 23142; 12/2/15; Zamboanga City
MCLE Compliance Certificate No.: 214142; 12/2/15.
Doc No: 53
Page No: 26
Book No: XIX
Series of 2015.