Republic of the Philippines

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
QUEZON CITY

GINALYN ALOLOR BARROGA,

Complainant,
-versus- XV-03-INV
For: Violation of R.A. 9262 (VAWC)

JOSE ALDRIN S. BARROGA,

Respondent.
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COUNTER-AFFIDAVIT

I, JOSE ALDRIN S. BARROGA, of legal age, Filipino, married and with

residence and postal address at No. 44B 19th Avenue, Murphy, Cubao, Quezon City,
after having been duly sworn to in accordance with law, do hereby state under oath,
that:

1. I am the same person who is the respondent in the instant complaint;

2. Paragraph 1, 2, 3, and 4 of the affidavit of Ginalyn Alolor Barroga are

ADMITTED.

3. As regards paragraph 5, 6, 7, and 8 are DENIED. While it was true that we

had many disagreement in the past, but they were only minor arguments and
there was no moment I threw hurtful words nor laid my hands to inflict harm
against the complainant;

4. The injuries as shown in the copies of medical certificate and photos attached
in her complaint were self-inflicted and/or the certificates attached therein
were fabricated and were not properly notarized.

5. There were numerous previous complaints, i.e., concubinage, petition for

compulsory confinement/rehabilitation of drug dependent, and falsification of
public document, filed by the complainant against me, moreso, if the
allegations of physical and verbal abuse were true, she should have been
reported immediately the incident of abuse to our Barangay considering that
our Barangay Hall is just one block away from our house; and if I am truly an
abusive husband to the complainant, our children could easily be convinced
by her and would testify to vouch her allegation, which our children never did;

6. But the instant complaint she filed was only part of many harassment suits
she filed against me that all were baseless complaint but were only motivated
by her extreme jealousy and resentment without concrete basis due to her
immaturity and insecurities.
 7. In the other complaint, i.e., the alleged Falsification of Public Document,
where she alleges that I sold our conjugal real property without her consent,
this was already controverted and belied by our children in their pinag-
samang sinumpaang salaysay ng pagtestigo, as herein attached as Annex “1”
and “2” forms part hereof, which can only shows that complainant was not
telling the truth;

8. The fact that complainant still living with me in our conjugal dwelling as of this
date while even the instant complaint, as well as the other criminal complaint,
subject for preliminary investigation is still pending for resolution, spending
quality family time1, as if we are not opposing parties in the complaint she
have filed, all the imputed acts alleged in her affidavit cannot be relied on.

9. Because of complainant’s actuations, even my parents and siblings had

already encouraged me to leave the complainant and to end our relationship,
but I kept insisted to them that I will maintain our relationship despite
complainant’s acts just for the sake of the welfare of our children that four of
them are graduating in their studies.

10. With respect to the allegations that I am a drug dependent, maintaining a

mistress and sired three children from her. To this, are completely lies and
purely concocted by complainant. It was true that she filed cases involving
the issues but under the pain of being redundant, these were already
dismissed and had no bearing in the instant case (see attached order of
dismissal of the Petition for Confinement/ Rehabilitation of Drug Dependent
as Annex “4”.

11. The allegation of the complainant that I have no steady job was not true, in
fact, our children, including the complainant herself, have been benefitting
from the 15 apartments that parents tasked me to manage and maintain its
operation and undertakings, to which I never failed in providing all their
financial needs.

12. Again, it is most respectfully prayed unto the Honorable Office of the City
Prosecutor that the complaint for violation of RA 9262 filed by the complainant
against me be dismissed for lack of basis as all the allegations made were
purely fabricated and made up thing by the complainant merely to harass my
person.

13. I am executing this Affidavit to attest to the truth of our foregoing statements,
in support of my Counter Affidavit and to rebut the allegations against me in
the Complaint and Reply. Other matters alleged by the complainant in her
complaint and reply that failed to deny or to controvert in this counter-affidavit
are respectfully deemed denied and controverted.

IN WITNESS WHEREOF, I have hereunto set my hand this 20th day of March
2019 at Quezon City.
1
See attached photo taken during Christmas rush hour and my birthday celebration dated 19 March 2019 as
Annex “3”, Annex “3-1” and Annex “3-2”.
 JOSE ALDRIN S. BARROGA
affiant

SUBSCRIBED AND SWORN to before me this 20th day of March 2019 in

Quezon City, Philippines.

CERTIFICATION

I hereby certify that I have personally examined the affiant and I am fully
convinced that he voluntarily and freely executed the foregoing Rejoinder-Affidavit and
he understood the contents thereof.

ASSISTANT CITY PROSECUTOR

Copy furnished:

GINALYN ALOLOR BARROGA

Complainant