Republic of the Philippines

)
City of Cagayan de Oro )S.S.
COMPLAINT-AFFIDAVIT
I, SAUDA A. MUTILAN, of legal age, widow and a resident of
________________, after having duly sworn in accordance with law hereby
depose and say that:
1. I am filing a criminal complaint for violation of Article 183 of the Revised
Penal Code, otherwise known as FALSE TESTIMONY IN OTHER CASES
AND PERJURY IN SOLEMN AFFIRMATION against ADNAN M. DIMAPORO,
of legal age and a resident of 152 Barangay Matampay, Marawi City for
deliberately and knowingly making untruthful statements in his affidavit
filed before this Honorable Office on 13 th day of December,2010 and in
his Motion for Reconsideration (MR) filed on September ___ 2011;
2. ADNAN DIMAPORO deliberately stated in his MR paragraph 2 that he is
an eyewitness to the falsification allegedly committed by me and my
co-respondents
SAPHIA MUTILAN, MOHAMMAD MUTILAN and
MONAWIRA ABUBACAR in IS No. X-06-INV-10-L-2985 filed before this
Honorable Office when in truth and in fact I have never seen nor meet
him;
3. That in the joint-affidavit that ADNAN DIMAPORO filed and executed
before this Honorable Office, he did not mention specifically who among
the respondents imitated the signatures of one Rodolfo Tan. This is
contrary to his statement that he is an eyewitness to the
alleged falsification that I and my co-respondents committed.
Thus, these inconsistent statements made by ADNAN DIMAPORO only
prove that he is making untruthful statements;
4. All the material allegations made in his affidavit are creation of his
imagination as in fact, he cannot even provide the details of what he
personally saw. In the ordinary course of things, a person truthfully
stating a fact about an event can remember even the minute details,
particularly when the event is significant. All his allegations are too
general to be given credence as he really did not see the things alleged
in his MR;

5. I have only known respondent ADNAN DIMAPORO when a case of Estafa

through falsification of public documents was filed against me by
KHADIJAH MUTILAN who happened to be the second wife of my
deceased husband, Dr. Mahid M. Mutilan. And I learned that ADNAN
DIMAPORO is the brother of TUNGKO DIMAPORO, the son of KHADIJAH
MUTILAN from another man. This fact leads only to the conclusion that
ADNAN DIMAPORO offered his false statement to support KHADIJA
MUTILAN and his half-brother TUNGKO DIMAPORO who have a very
strong grudge against me and the rest of the heirs of my late husband;
6. In order to harass me and the other heirs, ADNAN DIMAPORO
deliberately and intentionally wanted to make this Honorable Office
looks like a fool by letting this Honorable Office believe that anything he
says is truthful;
7. That he willfully and deliberately affirmed his affidavits before this
Honorable Office knowing fully-well that all the contents thereof are
false with the sole intent of harassing me and my family;
8. On __________, this Honorable Office dismissed the criminal complaints
filed by ADNAN DIMAPORO et al against me for lack of probable of
cause, hence, this Honorable Office find ADNAN DIMAPOROs affidavit
FALSE AND UNTRUTHFUL when this Honorable Office did not find his
statements credible in accordance with logic and human nature;
9. That his action of executing false affidavits should not be tolerated by
this Honorable Office;
10. That I am executing this affidavit to attest the truth of the foregoing
statements to prosecute ADNAN DIMAPORO for the crime of False
Testimony in other cases and perjury in solemn affirmation under Article
183 of the Revised Penal Code.
IN WITNESS WHEREOF, I have hereunto affixed my signature this ___ of
October, 2011 at Cagayan de Oro City.

SAUDA MUTILAN
Complainant

SUBSCRIBED AND SWORN to before me this __ day of October, 2011 at

Cagayan de Oro City.