Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
Branch 24
Hall of Justice
Koronadal City, South Cotabato

PEOPLE OF THE PHILIPPINES,

Plaintiff,

CRIMINAL CASE NO. 8321-24

-for- Versus
ANTHONY REGONIEL DELOS SANTOS
and LETICIA DEQUILLO KONG,
Accused.

VIOLATION OF SEC. 5 OF
ARTICLE 2 OF R.A. 9165

x--------------------------------------x
JUDICIAL AFFIDAVIT OF PSI HONORIO REYES ANI
The person examining me is Atty. Leonard Sagarino Balabat of the
Office of the Provincial Prosecutor, Region 12. The examination is being
undertaken at the same office.
I am fully aware that my answers to my counsels question are made
under the knowledge of the penalty of perjury.
OFFER OF TESTIMONY:
That my testimony is being offered:
1. To corroborate the testimonies of other witnesses on the chain of custody
of the pieces of evidence;
2. To identify the documentary evidence that is material and relevant in
herein case;
3. To testify according to the results of the laboratory tests conducted on the
pieces of evidence submitted before the crime laboratory; and
4. To testify on any other matter relevant to the herein case and for the due
administration of justice.

DIRECT TESTIMONY:
The ensuing questions and answers shall constitute my direct testimonies in
herein proceedings, thus:
1

1.

QUESTION (Q; ATTY. BALABAT): In what dialect would you like to be

asked?
ANSWER: (PSI ANI): In English language, Sir.

2.

Q: Will you please state before this Honorable Court your name and
other pertinent circumstances?
A: I am Police Senior Inspector Honorio Reyes Ani, of legal age, Filipino
citizen, single, and with postal address at #011 National Highway,
Polomolok, South Cotabato. I am a Registered Chemist, Forensic
Chemist of the Regional Crime Laboratory Office 12 in Camp Fermin
Lira, Jr. General Santos City.

3.

Q: How long have you been working as a forensic chemist?

A: 10 years, Sir.

4.

Q: Do you recall receiving pieces of evidence of analysis on

October 16, 2012.
A: Yes, Sir.

5.

Q: How many pieces of evidence did you receive on that day?

A: Only three, Sir. Two small sealed plastics enclosed in 1 larger sealed
plastic and 1 sealed plastic on a larger sealed plastic, Sir.

6.

Q: Who endorsed it to you?

A: It was PO1 Albert Pundogan who endorsed the pieces of evidence.

7.

Q: What are these pieces of evidence?

A: Those were believed to be Methamphetamine Hydrochloride or
shabu, Sir.

8.

Q: How do you describe those pieces of evidence?

A: One tape-sealed transparent plastic bag with signature and attached
with labeling containing two heat-sealed transparent plastic sachets
labeled as JS1 and JS2, each with white crystalline substance.
And, one tape-sealed transparent plastic bag with signature and
labeling containing one heat sealed transparent plastic sachet
labeled as AGL-1 containing white crystalline substance.

9.

Q: What time was it?

A: Around 11:30 in the evening, Sir.

10.

Q: After you received the pieces of evidence, what did you do next?
A: I signed the chain of custody report brought by PO1 Pundogan.
Then, I kept the pieces of evidence on the locker since the testing
officer is not yet on duty. Then, the next day, I turned them over to PO1
Cagumbay for laboratory analysis as he is the one who will conduct the
tests under my supervision, Sir.

11.

Q: At around what time did you turned over the pieces of evidence to
PO1 Cagumbay?

A: At the start of his shift, Sir, around 8:00 in the morning of October 17,
2012.
12.

Q: Why did you have to wait for PO1 Cagumbay to conduct the tests?
A: Because he is the one assigned as the testing officer, Sir. My job is
only to supervise him and that I am his immediate superior. But, we
did the test together, Sir.

13.

Q: What are the series of tests did you and PO1 Cagumbay conducted
on the pieces of evidence?
A: First, we weighed them 1 by 1 using the digital weighing scale.
Then, we did the Presumptive Testing thru Simons Test, Sir.

14.

Q: What are the weights of the items?

A: The JS-1 is 0.0637; JS-2 is 0.0315; and the AGL-1 is 0.0641 gram,
Sir.

15.

Q: How is the testing being done?

A: First, we obtained samples from each sealed plastics and placed
them on three separate containers, Sir. From there, we sealed the
plastics by heating and used the obtained samples in the containers
for our analysis following the procedures prescribed for
SimonsTest,Sir.
Simons Test is similar to a pregnancy test, Sir. The enzymes in the
solution react with methamphetamine and the result is shown as dark
blue solution. The samples Js-1, Js-2 and AGL-1 all indicates the
presence of methamphetamine hydrochloride or shabu, Sir. The test
was repeated three times on each sample and the same positive
results were taken.
Then, we did the next test which is the confirmatory testing also
known as the Thin Layer Chromatography. In this test, we compared
the movement of the liquefied samples taken from the containers
used during the presumptive testing with the absolute samples we
have in the laboratories. The results all lead to the conclusion that the
samples JS-1, JS-2, and AGL-1 contain methamphetamine
hydrochloride, Sir.
Necessary steps were also taken during each test, Sir, in order not to
contaminate the specimens, Sir.

16. Q: After the series of tests, what did you find out?
A: The results were positive and indicated that all of the pieces of
evidence were methamphetamine hydrochloride or also known as
shabu, Sir.
17. Q: What is the extent of the reliability of these tests?
A: These tests are the prescribed tests for the detection and analysis of
methamphetamine used in the PDEA Crime Laboratory as based in
the guidelines issued by the United Nations, Sir.
18. Q: After the tests were conducted, what did you do next?
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A: We sealed the plastics the way they were sealed when we received
them. Then, I turned over them to the evidence custodian and
submitted the reports of the results of the tests to Regional Chief of
Crime Laboratory, PSI Maria Christina Bungay Freyna, MD.
19. Q: Do you have anything to add?
A: Yes, this Judicial Affidavit is knowingly prepared, signed and released
to amend, modify, revoke and repeal all my previous statements that
directly contradict the statements hereof as well as to support and
supplement other statements that may help me to bring justice in the
process.
20. Atty. Balabat: That is all for the witness, Your Honor.

In witness whereof, I have hereunto set my hands this 18th day of October,
2012, at Koronadal City, South Cotabato, Philippines.

PSI HONORIO REYES ANI

Affiant

SUBSCRIBED and sworn to before me in City of Koronadal on 18th of

October, 2012, affiant showing his/her competent proof of identity, to wit:
Comelec VIN 163687213.

Atty. Leonard Sagarino Balabat

Counsel for the Witness
Office of the Provincial Prosecutor
Koronadal City, So.Cotabato
Roll No. 6988
PTR No. 696969.
IBP Lifetime Membership No. 8888
MCLE V-0002305, August 9, 2012.

Doc. No. __
Page No. __
Book No. __
Series of 2012.

EXHIBITS ATTACHED TO THE JUDICIAL AFFIDAVIT

1. Request for Qualitative Analysis for JS-1 and JS-2 as EXH. I;
2. Request for Qualitative Analysis for AGL-1 as EXH. C;
3. Chain of Custody Report for JS-1 and JS-2 as EXH. D;
4. Chain of Custody Report for AGL-1 as EXH. E;
5. Chemistry Report for JS-1 and JS-2 as EXH. G; and
4

6. Chemistry Report for AGL-1 as EXH. F.

Republic of the Philippines

)
Koronadal City, South Catabato ) S.S

SWORN ATTESTATION OF THE LAWYER WHO

SUPERVISED THE EXAMINATION OF THE WITNESS.

CONDUCTED

OR

The undersigned ATTY. LEONARD SAGARINO BALABAT, of legal age,

single, with his office at the Provincial Procecutors Office, Koronadal City, South
Cotabato, under oath, deposes and states:
1.

He is the Legal Counsel for the witness in the above-entitled case;

2.

He faithfully recorded or caused to be recorded the questions he asked

and the corresponding answers that the above-named witness gave;

3.

Neither he nor any other person then present or assisting him coached the
witness regarding the latter's answers; and

4.

He conducted the examination of the witness at his law office located at the
Office of the Provincial Prosecutor, Koronadal City, South Cotabato.

In witness whereof, I hereunto set my hand this 18th day of October, 2012 in
Koronadal City, Province of South Cotabato.

ATTY. LEONARD SAGARINO BALABAT

Affiant

SUBSCRIBED and sworn to before me in Koronadal City on October 18,

2012, affiant showing his/her competent proof of identity, to wit: SSS Member ID
No. 16898144516516988

ATTY. SHIENA LOU B. AMODIA

Notary Public
Roll No. 6989
PTR No. 696968
5

IBP Lifetime Membership No. 8881

MCLE V-0002306, August 9, 2012.

Doc. No. ___

Page No. ___
Book No. ___
Series of 2012.

COPY FURNISHED:

LUMINDAS AND ASSOCIATES Law Offices

Counsel for the accused ANTHONY REGONIEL DELOS SANTOS and
LETICIA DEQUILLO KONG
# 69 Mansanitas St,
General Santos City, Philippines

EXPLANATION
A copy of this Judicial Affidavit is served on the Court, the Counsel for the
Accused ANTHONY REGONIEL DELOS SANTOS and LETICIA DEQUILLO
KONGvia LBC Express Corp./registered mail due to the great distances of their
respective addresses, due to the urgency of filing the same, and due to the lack
of field personnel of the undersigned counsel at this time.

ATTY. LEONARD SAGARINO BALABAT

Public Prosecutor II