You are on page 1of 3

Republic of the Philippines

Department of Justice
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
Pasay City
PEOPLE OF THE PHILIPPINES,
Complainant,
-versus-

I.S. No. __________


For: Violation of Sec. 5
Article 2 of RA 9165 (Selling
of Dangerous Drugs

HAROUN AL-RASHID A. PANDAPATAN,


Respondent.
x----------------------------------------------------x

COUNTER-AFFIDAVIT

I, HAROUN AL-RASHID A. PANDAPATAN, Filipino, of legal


age, and with residence at 32 F. Victor St. Brgy. 62, Pasay City, after
having been duly sworn in accordance with law, hereby depose and
state that:
1. I was charged by SPO4 KAREN PEARL CUE for violation of
Sec. 5 Article 2 of RA 9165 (Selling of Dangerous Drugs);
2.

I did not sell drugs and I vehemently deny all the allegations that
she has stated on her complaint- affidavit. There is no truth to the
charges being leveled at me. The statements of the complainant
and the witnesses are full of lies and were meant to extort money
from me;

3.

The facts on the complaint affidavit that she has made against me
were merely fabricated stories because I refused to give in to her
demand of giving twenty thousand pesos (P 20,000.00);

4. On 8 August 2015 at around 10:30 P.M, I was at my friend


ANVARI F. ARGUELLES house in Emma St. Brgy. 57, Pasay
City watching basketball in the television. ARGUELLES asked
me to buy a pack of cigarette in the store.
5.

While I was walking along Delas Alas St. to buy a pack of cigarette, I
was approached by P03 ANGELIQUE BIEN TIONGSON. At the time
she was wearing civilian clothing and was posing as seller of
cigarettes in the streets;

6.

TIONGSON asked me if I wanted to buy cigarettes from her. Since


there is no nearby sari-sari store, I decided to just buy cigarettes
from her instead;

7.

Upon giving TIONGSON the money, she placed something inside


my right pocket. I took it out and saw plastic sachet containing
shabu;

8.

It was at that moment when CUE appeared and informed me that


this is a entrapment operation;

9.

CUE demanded twenty thousand pesos (P20,000.00)from me or else


they will arrest me for selling drugs;

10.

When I refused to pay the said amount, CUE placed handcuffs on


me and brought me to the police station;

11.

I strongly believe that CUE filed the complaint to extort money from
me and to harass me;

12.

I am voluntarily executing this affidavit to attest to the truthfulness


of the foregoing facts and to support the outright dismissal of the
complaint filed against me.

AFFIANT FURTHER SAYETH NAUGHT.


IN WITNESS WHEREOF, I have hereunto set my hand this 12 th
day of August 2015, in Pasay City.

HAROUN AL-RASHID A. PANDAPATAN


Accused/Affiant

SUBSCRIBED AND SWORN TO before me, this 13th day of


August 2015 in Pasay City.

SUBSCRIBED AND SWORN to before me this 13 th day of August


2015 in the city of Pasay. I further certify that I have personally
examined the Affiant and I am satisfied that he/she voluntarily
executed and understood his/her statement.

CARYL JANE VILLANOZA


Administering Officer
Doc. No. _____;
Page No. _____;
Book No. _____;
Series of 2015.

You might also like