Republic of the Philippines}

Municipality of Jose Abad Santos,) S.S

Province of Davao Occidental).
x-------------------------------x
REPLY AFFIDAVIT

I, PEDRO SANTOS., of legal age, married, and a resident of Brgy. Molmol, Jose
Abad Santos, Davao Occidental after being sworn to in accordance with law do hereby
depose and say that:
:
1. On July 28 2016 I filed an Affidavit-Compliant for Qualified Theft and other
deceits under 310 of the Revised Penal Code against TEBAN ESCUDERO,
GOLIATH ESCUDERO, ANDRES ESCUDERO, MANUEL MABINI and GABRIELA
MABINI
1. Respondents have filed thus their Counter-Affidavit albeit studded with
inconsistencies and erroneous allegations.
2. Hence this Reply-Affidavit.
3. Paragraph 4 of the Counter Affidavit denies the allegations in Paragraph 11 of
the Affidavit Complaint and makes use of an

defense that the testimony of

Mario Masangkay as evidenced by his Affidavit of Testimony is motivated by by

hate, anger and done through hidden grudges with due to the fact that he was
a former employee of the said rice mill and was caught in the act of stealing
spare parts from our motor vehicles by security guards on duty namely MANUEL
MABINI AND GABRIELA MABINI which resulted to his termination.
4. Paragraph 5 of the Counter Affidavit denies claims that Defendants no
knowledge of the allegations in paragraph 12 of the complainants affidavit
complaint on the said day when a typhoon hit the municipality of Jose Abad
Santos. We were in our homes tending to our respective families.
5.

While the Defendants deny their absence of on the said place

the CCTV

footage taken on March 2, 2016 provides otherwise.

6. That in the case at bench there is palpable evidence of grave abuse of
confidence willful, knowing, witting and malicious acts of qualified theft done by
TEBAN ESCUDERO, GOLIATH ESCUDERO, ANDRES ESCUDERO, MANUEL MABINI
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and GABRIELA MABINI

through the raw CCTV footage captured on March 2,

2016.
7. That there is a patent manifest act of

theft done by TEBAN ESCUDERO,

GOLIATH ESCUDERO, ANDRES ESCUDERO, MANUEL MABINI and GABRIELA

MABINI

qualified

by grave abuse of confidence

that the acts

of the

aforementioned individuals is contrary to law and good customs. That the said
acts and series of acts should be punished to serve as a lesson and a deterrent
for the public itself,
1.

I AM EXECUTING THIS AFFIDAVIT TO ATTEST TO THE

TRUTHFULNESS AND VERACITY of the foregoing statements, as my Reply to the
Counter Affidavit of Respondents TEBAN ESCUDERO, GOLIATH ESCUDERO,
ANDRES ESCUDERO, MANUEL MABINI and GABRIELA MABINI

2.

FURTHER that I am executing this affidavit to reiterate

complaint against Respondents and to inform the proper authorities concerned
of the matter and for such other legal purpose/s this may serve.

IN WITNESS WHEREOF, I hereunto set my hand on ______________,

in the

Municipality of Jose Abad Santos, Province of Davao Occidental Philippines.

PEDRO SANTOS.
Affiant
SUBSCRIBED and SWORN to before me this ____th day of __________ 20___, at
Davao City, Philippines. I hereby certify that I have examined the affiant and I am
satisfied that he understood the contents of his affidavit and that he voluntarily and
freely executed the same.

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