Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

12th Judicial Region
Kidapawan City
THE PEOPLE
OF THE PHILIPPINES, Criminal Case No. 16,726-15

-versus- FOR: FALSIFICATION OF

PUBLIC DOCUMENT
LEBRON S. THOMPSON
Accused
x----------------------------x
INFORMATION

The undersigned accuses the above-named accused of the crime of

FALSIFICATION OF PUBLIC DOCUMENT, under Article 172 in relation to
Article 171, paragraph 2 of the Revised Penal Code, committed as follows:

That on or about November 21, 2006, in the City of Kidapawan,

Philippines, and within the jurisdiction of this Honorable Court, the above-
named accused, willfully, unlawfully and feloniously caused to appear that
Elpidio Tuscano have participated in the execution of Deed of Absolute Sale
involving a piece of land identified as Lot No. 36-B-8 (LRC), Psd-118436
covered by Transfer Certificate of Title No. T-34781, a public document,
when in truth and in fact he did not so participate because the latter
already died on May 26, 1986.

CONTRARY TO LAW
Kidapawan City, Philippines, September 7, 2015.

STEVE KERR
City Prosecutor
Roll No. 33,557-April 27, 1985
MCLE Compliance No. I-0019175; No. II-002090909;
No. III-0022806 And No. IV-00221533
Witnesses
1. Ayesha Thompson - 6132 Aguho Street, Luna Subd.,
2. Klay Thompson Davao City
3. And others -do-
PAGE 2
INFORMATION
AYESHA S. THOMPSON AND KLAY S. THOMPSON VS. LEBRON THOMPSON
FOR: FALSIFICATION OF PUBLIC DOCUMENT
X-------------------------------------------------------------------------------------------------------------------------X

CERTIFICATION

I HEREBY CERTIFY that an authorized officer had examined the

complainant and witnesses; that on the basis of the sworn statements and
other evidences submitted before me there is reasonable ground to believe
that a crime had been committed and that the accused was given an
opportunity to know the nature of the complaint and of the evidence
submitted against him/her and that she/he was likewise given the
opportunity to submit controverting evidences.

Kidapawan city, Philippines. September 7, 2015.

STEVE KERR
City Prosecutor
Roll No. 33,557-April 27, 1985
MCLE Compliance No. I-0019175; No. II-002090909;
No. III-0022806 And No. IV-00221533

SUBSCRIBED AND SWORN to before me this 7th day of September

2015 Kidapawan City, Philippines.

ROBIE ANN G. SOLACITO

Associate Prosecution Attorney II

BAILBOND RECOMMENDED:

TWELVE THOUSAND PESOS (Php. 12,000.00)

 REPUBLIC OF THE PHILIPPINES
DEPARTMENT OF JUSTICE
CITY PROSECUTION OFFICE
Kidapawan City

AYESHA S. THOMPSON
AND KLAY S. THOMPSON I.S NO. ____________
COMPLAINANTS NOS. DOC NO. XII-04INV
2051-00063
-versus- -for-

SPOUSES LEBRON S. THOMPSON FALSIFICATION OF

APRIL S. THOMPSON PUBLIC DOCUMENT
Respondents, (ART.172 RPC)
x----------------------------------------x

JUDICIAL AFFIDAVIT COMPLAINT

FALSIFICATION OF PUBLIC DOCUMENT

I, KLAY S. THOMPSON , of legal age, Filipino, married, with

residence and postal address at 613 Aguho St., Luna Subd., Davao City, after
having been duly sworn to in accordance with law, hereby depose and say:

This Judicial Affidavit of KLAY S. THOMPSON is taken in accordance

with Section 3 of A.M. No. 12-8-8-SC;

THE PARTY
Name: KLAY S. THOMPSON
Address: 613 Aguho St., Luna Subd., Davao City
Occupation: Hospital Administrator, Thompson General Hospital
Matalam, Cotabato
Status: Married

NAME OF LAWYER WHO TOOK

THIS JUDICIAL AFFIDAVIT

Name: JUREE B. MUDANZA

Address: Jose Abad, Santos St. Kidapawan City
Place of Examination: Mudanza LAW OFFICE

That the witness is examined by counsel fully conscious that she does
so under pain of perjury in case of falsehood;
1. Q. Please state your name, age, qualification, and residence and other
personal circumstances;
1. I am KLAY S. THOMPSON, of legal age, Filipino, married and
appointed Hospital Administrator of the Thompson General Hospital,
Matalam, Cotabato and a resident 613 of Aguho St., Luna Subd.,
Davao City;
2. Q. Do you know LEBRON S. THOMPSON and APRIL THOMPSON?
A. Yes, he is my elder brother and APRIL THOMPSON is his wife;
3. Q. Are your parents still alive?
A. No sir, my father Dr. STEPHEN THOMPSON died on May 31, 2011 and
my mother HILDA THOMPSON died on October 1, 2006;
4. Q. Do you still have another sibling?
A. Yes Sir, she is AYESHA S. THOMPSON, married but her marriage was
annulled. She is the eldest among us;
5. Q. What is your complaint against your brother LEBRON S. THOMPSON
and his wife?
A. Actually Sir we filed a case for Reconveyance/Partition of Real
Property, Damages, Accountingg, Attorneys Fee, with prayer for
Temporary Restraining Order and on injuction at the Regional Trial
Court, Kabacan, Cotabato;
6. Q. What is your status of this case?
A. It was just filed in court;
7. Q. Do you have the copy of that complaint?
A. Yes Sir;
8. Q. Would you allow this representation to mark the copy of that
complaint?
A. Yes Sir;
9. Q. We are marking this complaint as Annex “A” to “A-6”
A. Yes Sir;
10. Q. What is this complaint which you intend to file?
A. My brother LEBRON S. THOMPSON and his wofe committed
Falsification of Public Transaction in Violation of Article 172 of the
Revised Penal Code;
11. Q. How did he commit such criminal act and what is the effect hereof as
far as you are concerned?
A. He falsified the signature of the vendors Elpidio Tuscano and Leonila
tuscano in a Deed of Absolute Sale making it appear that said
spouses sold to him such land embraced in TCT T-34781 for the sum
of ONE HUNDRED THOUSAND PESOS (Php100,000.00) Philippine
Currency, despite the fact that both vendors died already, evidence
by the death certificate attached hereto. The sale is identified as Doc.
No. 44;
 Page No.88; Book No.191; Series of 2006; of the Notarial Register of
Leonardo S. Cousins. Copy of the death certificate is marked Annex
“B” hereof and the sale as Annex “C”;
12. Q. What is the legal effect of such falsification?
A. He was able to successfully cancel TCT T-34781 and transfer to his
name and his wife which now T.C.T NO. T-112551 where Thompson
General Hospital is located;
13. Q. Do you have a copy of the title in the name of LEBRON S.
THOMPSON and APRIL S. THOMPSON
A. Yes Sir;
14. Q. Would you allow us to mark this as Annex “D”
A. Yes Sir;
15. Q. Now what is your prayer with respect to this transaction?
A. I ray unto the City or Provincial Prosecutor to file a case of
Falsification of Public Document against LEBRON S. THOMPSON and
APRIL S. THOMPSON by forgering the signature of Elpidio Tuscano
and his wife which lead to the cancellation of T.C.T. NO. T-34781 and
the issuance of T.C.T. NO. T-112551 to their name. copy of the
cancelled T.C.T. NO. T-34781 is marked Annex “E” hereof;
16. Q. Are you not willing to settle this case with them considering that you
are siblings?
A. We did but he refused and as a matter of fact LEBRON S. THOMPSON
even told my sister AYESHA S. THOMPSON to go to the court;
17. Q. Do you have any knowledge in relation to the land subject of this
case?
1. I understand that the land subject of this Falsification has long been
purchased by our parents Dr. Samuel Thompson and Naida S.
Thompson however, apparently LEBRON S. THOMPSON wanted to
own solely this land where our hospital-General Hospital is now
operating and as a matter of fact he is now in total control of its
coffers together with his wife;
18.Q. Do you still have something to say?
A. No more Sir;

IN WITNESS WHEREOF, I have hereunto set my hand this MAR 05

2015 at Kidapawan City.
Conformity:

AYESHA S. THOMPSON KLAY S. THOMPSON

(COMPLAINANT) (COMPLAINANT)
Driver’s license # L02-95-105891
REPUBLIC OF THE PHILIPPINES }
CITY OF KIDAPAWAN }S.S.

JOINT COUNTER-AFFIDAVIT

WE, the spouses LEBRON S. THOMPSON and APRIL S. THOMPSON,

both of legal age, Filipinos, married and residents of Blk. 6, Lot 8, Uphill
Drive, Yññ iguez Subdv., Ma-a, Davao City, after haviñg beeñ duly sworñ
iñ accordañce with law, hereby depose añd state that:

1. We are the respondents in NPS Doc. No. XII-04-INV-2015C-00063

entitled AYESHA S. THOMPSON and KLAY S. THOMPSON vs. SPS.
Documents, which is pending before the Office of the City Prosecutor,
Kidapawan City;
2. We personally know both complainants since they are siblings of
LEBRON S. THOMPSON
3. Sometime in 2006, RUBEN BORRES GREGORIO approached, LEBRON
S. THOMPSON about a property for sale in Matalam, Cotabato. He
told LEBRON S. THOMPSON that he personally knew the owner and
the latter wanted to sell that property;
4. The said property was that parcel of land (Lot No. 56-B-8 (LRC), Psd-
118436, located at Matalam, Cotabato, containing an area of 377
square meters, which was registered in the name of Elpedio Tuscano
under Transfer Certificate of Title No. T-34781, which is the subject
matter of this complaint;
5. RUBEN BORRES GREGORIO told, LEBRON S. THOMPSON that if he
decided to purchase the said property, RUBEN BORRES GREGORIO
would process the transfer of the title in the name of LEBRON S.
THOMPSON for a fee;
6. LEBRON S. THOMPSON consequently decided to purchase the said
property and engaged the services of RUBEN BORRES GREGORIO for
the transaction;
7. Thereafter, RUBEN BORRES GREGORIO brought LEBRON S.
THOMPSON the original owner’s duplicate of TCT No. T-34781 as well
as a Deed of Absolute Sale for the said property which was already
signed by Elpidio Tuscano and LEONILA DUBRIA;
8. The Deed of Absolute Sale was notarized before Atty. Leonardo S.
Cousins on November 21, 2006 and recorded as Doc. No. 432, Page
No. 88, Book No. 191, Series of 2006;
9. LEBRON S. THOMPSON then handed the amount of One Hundred
Thousand Pesos (Php100,000.00) to RUBEN BORRES GREGORIO as
 SUBSCRIBED AND SWORN to before me, this MAR 05 2015 at
Kidapawan City.

Doc. No. 119; JUREE B. MUDANZA

Page No. 24; NOTARY PUBLIC
Book No. 339; Until Dec. 31, 2016
Series of 2015; ptr 1256001

ATTESTATION

I faithfully recorded the questions I asked KLAY S. THOMPSON and

the corresponding answers he gave me; and neither I nor any other
person then present coached CHRIS SAMUEL S. BABOL regarding his
answers.

JUREE B. MUDANZA
Affiant

SUBSCRIBED AND SWORN TO before me, this MAR 05 2015 affiant

personally appearing and exhibiting to me his IBP No. 28743.

STEPHEN T. ALAVE, JR
Notary public
Until Dec. 31, 2015
Ptr # 1254355
Tin 188-016-639
Roll # 59959
REPUBLIC OF THE PHILIPPINES }
CITY OF KIDAPAWAN }S.S.

AFFIDAVIT

I, RUBEN BORRES GREGORIO of legal age, Filipino, married and a

resident of 258 National Highway, Poblacion, Matalam, North Cotabato,
after having been duly sworn in accordance with law, hereby depose and
state that
1. I personally know the spouses LEBRON S. THOMPSON and APRIL
S. THOMPSON
2. I also personally knew Elpidio Tuscano, as well as his surviving
children, namely Teresita T. Sabido, Juliet D. Tuscano, Editha T.
Aliwa, Crispin T. Tuscano;
3. Sometime in 2006, I brokered the sale of a parcel of land (Lot No.
56-B-8 (LRC), Psd-118436), located at Matalam, Cotabato,
containing an area of 377 square meters, which was then
registered in the name of Elpidio Tuscano under Transfer
Certificate of Title No. T-34781
4. I offered the property to LEBRON S. THOMPSON who agreed to
buy it;
5. However, at that time, Elpidio Tuscano was already dead, but the
title was not yet transferred in the name of their children or heirs;
6. The heirs of Elpidio Tuscano then informed me that they had no
money to pay for the estate tax and other expenses in order to
transfer the title in their names;
7. The heirs of Elpidio Tuscano asked for my help in finding a way to
facilitate the transaction without them having to pay the estate
tax and other additional expenses for the transfer of the title;
8. I suggested to the heirs of Elpidio Tuscano that we instead
transfer the title directly to Elpidio Tuscano to LEBRON S.
THOMPSON that way they would no longer have to pay the estate
tax;
9. However, I also told the heirs of Elpidio Tuscano that we would
have to forge the signatures of their deceased parents and that all
of the heirs would have to agree to do it in order to avoid any
problems with one heir complaining in the future;
10. All of the heirs of Elpidio Tuscano agreed to do it in order to fast-
track the transaction and save money on taxes and other
additional expenses;
11. I thus thereafter forged the signature of Elpidio Tuscano on the
Deed of Absolute Sale which was notarized before Atty. Leonardo
S. Saniel on November 21, 2006;
12. I did not inform LEBRON S. THOMPSON of the forgery, and the
said persons had no knowledge of the same
 13. I forged the signature of Elpidio Tuscano and LEONILA DUBRIA
only to help their children and heirs, without any intent of
defrauding any other persons and
14. I am executing this affidavit to support the counter-affidavit to
Jeff Samuel S. Babol and Jelly E. Babol in NPS Doc. No. XII-04-INV-
2015C-00063 for Falsification of Public Documents which is
pending before the Office of the City Prosecuter in Kidapawan
City;

IN WITNESS WHEREOF, I have hereunto set my hand this 27th day of

April 2015 in Kidapawan City, Philippines

RUBEN BORRES GREGORIO

Affiant

SUBSCRIBED AND SWORN to before me this 27th day of April 2015 in

Kidapawan City, Philippines. I hereby certify that I have fully examined the
affiant and that I am fully satisfied that he voluntarily executed the same
and that he fully understood the contents thereof.
 REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
12th Judicial Region
Kabacan, Cotabato

KLAY S. THOMPSON and CIVIL CASE NO. 15-05

AYESHA S. THOMPSON
Plaintiffs,
-versus- -for-

SPOUSES LEBRON S. THOMPSON RECONVEYANCE OF REAL

and APRIL B. THOMPSON PROPERTY/ETC.
Defendants
x---------------------------------------------x

SUPPLEMENTAL AFFIDAVIT OF
Ayesha S. Thompson

I AYESHA S. THOMPSON of legal age, Filipino, married but

factually separated with my husband, with residence and postal
address at 613 of Aguho St., Juna Subd., Matina, Davao City, after
having been duly sworn to in accordance with law, hereby depose
and say:

Purpose: To prove that the late Spouses Dr. Samuel Thompson and
Nadia B. Thompson were the owner of the Babol General Hospital which
is located at Matalam, Cotabat. This ownership is evidenced by Exhibit
“A” to “FF” and Series which are duly marked in this Supllemental
Affidavit.

1. Q. MISS THOMPSON can you recall having executed a previous

Judicial Affidavit on November 25, 2015 before Mudaza Law
Office, Kidapawan City?
A. Yes sir;
2. Q. Why are you still executing this Supplemental Affidavit?
A. In order to put on records the complete documentary exhibits
in relation to the ownership of the Thompson General Hospital
3. Q. What documentary exhibits are you referring to?
A. Several exhibits marked Exhibits “A” to “FF” and Series hereof;
4. Q. Would you allow to mark these exhibit one by one?
A. Yes sir;
5. Q. Which documentary exhibits would you like to mark?
A. The following sir, as follows: