REPUBLIC OF THE PGILIPPINES )
PROVINCE OF ZAMBOANGA ) S.S
CITY OF ZAMBOANGA )
COUNTER-AFFIDAVIT
I, ROBERT AYADE MABASA, of legal age, Filipino, married, and a resident of Zambowood,
Zamboanga City, after having been sworn to in accordance with law, do hereby depose and state the
following, to wit:
1. I am the accused in criminal case no. 56401 for Grave Threats, now pending before the Municipal Trial
Court in Cities, Branch 01, Zamboanga City:
2. The case against me was filed by Samuel Ordaniza Resol, private complainant;
3. I vehemently deny the accusations contained in his Judicial Affidavit as well as those written in the
affidavits of his witnesses for being false, untrue, and fabricated;
4. The truth of the matter is as follows:
a. I used to work as a security guard, but decided to quit the same on 22 February 2021. On the
same day, and after discussing the matter with my immediate supervisor, I went home to the
make-shift house which I constructed in the lot allotted for security guards of Mega Plywood
Company:
b. At around 09:00 in the morning of the same day, I decided to demolish said house so that other
guards who will be later employed by our company will have a vacant lot where they can also
build their own make-shift house. After demolishing the said house, I, together with my wife,
Michelle, and 4-year old son, Johndeb proceeded to our personal house, which is about 60
meters from the make-shift house;
c. Later in the afternoon of same day, I went to the house of my friend, Angging. We had a couple
of drinks together. Molina and Yayang were also present in our drinking spree. A few minutes
later, we noticed that complainant Resol was glaring at us. However, we did not pay any
attention to him;
d. After some time, I decided to go home. Suddenly, I heard someone yelling from the outside of
our house. I was surprised to see Samuel Resol. He was actually the one who shouted invectives
at my person. He was the one who scared my wife and most especially, my 4-year old son. He
also threatened to put me to jail if I will not leave the lot where we are staying;
5. I never threatened Samuel Resol. He was in fact, the one who threatened me and the one who
shouted malicious words against me. I never even bothered to shout back at him so that my wife and
son would not be disturbed any longer. What I did was that I waited for him to leave our place, which he
did, after a few minutes of yelling;
6. That I am thus executing this counter-affidavit to attest to the truthfulness of the foregoing narration
of facts surrounding the case subject of this case and in compliance with the Order issued by the
Honorable Court;
IN WITNESS WHEREOF, I have hereunto affixed my signature this 24h day of January, 2022 at
Zamboanga City, Philippines.
ROBERT AYADE MABASA
Affiant
SUBSCRIBED AND SWORN TO before me this 24 day of January, 2022 at Zamboanga City,
Philippines and I FURTHER CERTIFY that I have personally examined the herein affiant and that I am fully
satisfied that he voluntarily executed this affidavit and understood the same.
Doc. No. 42
Page No.2
Book No.3
Series of 2022
ATTY. JOSE MANALO
Notary Public