Republic of the Philippines)
Province of Cagayan ) SS
Tuguegarao City )
COMPLAINT-AFFIDAVIT
I, MARIA COSOLACION BAQUIRAN, of legal age, Filipino,
married, and currently residing at Centro I, Tumauini, Isabela, after having
been duly sworn to in accordance with law, depose and state THAT:
1) I am the spouse of Honorato G. Baquiran, the President & CEO of
HGBaquiran College, Inc., Centro I, Tumauini, Isabela;
2) I personally know a certain MARY JANE ROBLES of Lingaling,
Tumauini, Isabela who is a student of HGBaquiran College, Inc.;
3) I recently arrived from Canada and I came to know of an affidavit
executed by Mary Jane Robles dated February 25, 2006 executed
before Notary Public Francisco Marallag and executed at Ilagan,
Isabela and entered in the Notarial Register of the said Notary Public
as Doc. No. 45; Page No. 10; Book No. 81; and Series of 2006. A
copy of the said Affidavit is hereto attached as Annex “A”;
4) In the said affidavit, Maryjane Robles narrated an alleged incident that
allegedly transpired on February 16, 2006. For reference, Paragraph 2
of the same affidavit reads-
“2. On February 16, 2006, Ma. Consolacion
Baquiran, wife of complainant Honorato G.
Baquiran, and owner of school, and who was the
former school president. Interviewed me and my
fellow students concerning the criminal complaint of
Theft of school documents filed by her husband
against school employees Jaycel Pamittan,
Guidance Counselor, Gretchen Balangat-Student
Affairs Coordinator, and Kristine Mae Sadang-
Science Laboratory Technician, and , after listening
to our answers, that the compliant is a complete
falsehood, Mrs. Baquiran commented in
Tagalog:“Gumagawa na naman ng kwento itong si
Honorato at Dean Navarro”
5) The foregoing narration of facts made by Maryjane Robles under oath
is utter, pure and complete falsehood for the reason that never in one
circumstance on said date that I interviewed Maryjane Robles along
with other students regarding the Theft committed by the Gretchen
Balangat, Jaycel Pamittan and Kristine Mae Sadang;
6) The declaration made under oath made by Maryjane Robles that I
made a comment in Tagalog, to wit: “Gumagawa na naman ng
kwento itong si Honorato at Dean Navarro” on the said date after
interviewing her and other students is also an utter, pure and complete
falsehood for no such interview was made and no such statement was
made by me on the said date or in any other date in the presence of
Maryjane Robles or any other person;
7) The said statement under oath made by Maryjane Robles is being used
and utilized by Gretchen Balangat, Jaycel Pamittan and Kristine Mea
Sadang in the criminal case of Theft against the afore-named which
case is under preliminary investigation by the Provincial Prosecutor’s
Office, Ilagan, Isabela docketed as IS No. 2006-A-140 entitled
Honorato G. Baquiran vs. Jaycel Pamittan, et al.;
8) Likewise, the same statement under oath is being used and utilized by
the same persons in a labor case entitled Gerchen Balangat, et al., vs.
HGBaquiran College, Inc. with RAB Case Nos. 01-23 to 25-06;
9) Gretchen Balangat, Jaycel Pamittan, and Kristine Mae Sadang have
participated in the commission of the act committed by Maryjane
Robles by instigating her to execute the affidavit knowing fully well
that the statements therein made are untrue and perjured;
10) Gretchen Balangat, Jaycel Pamittan, and Kristine Mae Sadang
are using and utilizing the said perjured statement of Mayjane Robles
in pending cases to their gain and advantage knowing fully well that
the same is a perjury;
11) In at least three (3) occasions covering the period of April 2006
and May 2006, Maryjane Robles along with her mother came to me
regarding the affidavit executed by her and she acknowledged the
untruthfulness of her affirmation under oath and revealed further that
she was instigated by Gretchen Balangat, Jaycel Pamittan, and
Kristine Mae Sadang in executing the perjured statement;
12) The act of Marjane Robles and necessary included therein the
act of Gretchen Balangat, Jaycel Pamittan, and Kristine Sadang in
instigating her in the execution a perjured statements, caused
unbearable anxiety, sleepless nights and wounded feeling since the
same involves a statement allegedly made by me against my husband;
13) In fact, I was confronted by my husband aggressively about the
affidavit of Maryjane Robles because he then believed that I actually
made those statements;
14) I am executing this affidavit to attest to the truthfulness of the
foregoing facts and for the purpose of filing criminal case of perjury
against MARYJANE ROBLES, GRETCHEN BALANGAT,
JAYCEL PAMITTAN, and KRISTINE MAE SADANG for
PERJURY.
MARIA COSOLACION BAQUIRAN
SUBSCRIBED AND SWORN to before me this __ day of June 2006
at Tuguegarao City, Cagayan.
CERTIFICATION
I CERTIFY that I have personally examined the affiant and I am
satisfied that the foregoing sworn statement is being executed freely and
voluntarily.
