Republic of the Philippines

Province of Cavite S.S

COUNTER AFFIDAVIT

I, HAZEL M. QUIAMBAO. Filipino, of legal age, single and resident of San

Rafael 1, Noveleta, Cavite, after having been duly sworn to in accordance with
the law do hereby depose and say:
1. That I am accused for the crime of Libel in relation to Cyber Crime
Prevention Act of 2002, now pending before the Provincial Prosecution
Office of Cavite;

2. That I vehemently deny the allegations in the complaint filed against me

for being false, fabricated and malicious, the truth being that;

a) I met the complainant last December 2015 at a party held at the

house of our common friend who introduced the complainant to me
as a Businessman. A day after, I opened my Facebook account to
check a message from my Father who is working abroad. To my
surprise, I saw a message from the complainant as hereby quoted:

Hi Zel, kamusta? Pwede bang makipag friends? Ang ganda mo kasi.

Ako pala yung na-meet mo kagabi. Emil 

I ignored his message because I am not fond of spending too much

time on Facebook. I also ignored his Friend request. I again opened
my Facebook account on December 31, 2015 to greet my father a
“Happy New Year”. Again, I saw messages from the complainant
saying that he likes me and asking me to be his girlfriend. I got
annoyed so I bluntly said “No, stop sending messages. Di ako
interesado”. Immediately, I received a reply from him saying that I
would regret rejecting him. But I ignored it.

b) In the morning of February 1, 2016, I was at the Market

accompanying my Mother and that there was no Wifi in the said
premise and I was not subscribed to any internet promos.
Therefore, there are no means provided for me to be able to
access on the internet and check my facebook.

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 c) When we got home, there was an electricity black out in Noveleta
until February 3, 2016.
d) That my Facebook Account name is not Hazel M. Quiambao but Zel
Mercado during the said date and up until now.
e) That I do not know how the Complainant knew of my real name
since my friends call me Zel.
f) My Facebook account is set as “Private” and my posts cannot be
viewed on the newsfeeds of Facebook users who are not included
in my Facebook friend’s list.
g) I just know that he is a Businessman but I do not know back then
that his business is an On line shop since I did not bother to view
his Facebook profile
h) I have not had any transactions with the complainant regarding his
online business and that he is not one of my Facebook friends.

3. That I was extremely surprised when I received a subpoena

4. That I am executing this counter affidavit to attest to the truth of the

foregoing statement and to support for the dismissal of the case filed
against me.

IN WITNESS WHEREOF, I hereby affix my signature this 11th day of

March 2016 in the city of Noveleta, Cavite, Philippines.

Hazel M. Quiambao
Affiant

SUBSCRIBED AND SWORN TO before me this 11th day of March 2016, in

the City of Noveleta, Cavite, Philippines and I further certify that I have
personally examined the affiant and I am convinced and satisfied that he
voluntarily executed the foregoing Counter Affidavit and understood all
the contents hereof and that they are true and correct as to his own
personal knowledge.

DHIN CHAVEZ
Notary Public