Republic of the Philippines
DEPARTMENT OF JUSTICE
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
Caloocan City
KATIE P NPS Docket No: VII-07-17C-02002-F
Complainant,
-versus-
PAPA P For: Violation of Sec. 5(i) of RA 9262
Respondent. Violence Against Women and their
Children Act of 2004.
x-----------------------------------x
COUNTER AFFIDAVIT
I, PAPA P, of legal age, Filipino, single, and a resident of Blk. 7,
Lot 13, Matapang St., Barangay Masinloc, Caloocan City, under oath
hereby depose and state that:
1. I am the respondent in NPS NO. VII-07-17C-02002-F, filed
against me by herein complainant, KATIE P, on the charge of
Violation of Section 5(i) of RA 9262 or Violence Against Women
and their Children Act of 2004;
2. That herein complainant KATIE P, is my common-law partner for
almost ten (10) years now;
3. That I vehemently deny the charges and allegations against me
by the complainant;
4. That I contradict the allegations of herein complainant under
paragraph 3 of the complaint affidavit. I strongly contradict the
allegation of being abusive to herein complainant for being my
common-law partner for ten (10) years now whom I love the most.
I can never abuse her in any aspect or manner in her life;
5. That I repudiate the allegation made by herein respondent under
paragraph 4 of the complaint affidavit. I cannot ever recall calling
her the "stupid," "worthless," and "crazy," but rather, I always
motivate her, cheer her up, and always lifting her spirit every time
we are encountering problems and challenges in our
relationship;
6. That I oppose herein complainant’s statement under paragraph
5 of the complaint affidavit. I may call her out during family
gatherings or any social events, but it is not my intention to
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shame her or to cause her emotional distress or humiliation. I
always talk to her in a lower tone and relaxed manner;
7. That I contest the allegation of herein complainant under
paragraph 6 of the complaint affidavit. I never criticized her in our
ten (10) years of being together, especially her physical
appearance, the taste of the food she cooks, or her personal
opinions in life. I always appreciate everything she do for our
relationship as we build our family;
8. That I strongly disagree with the allegation under paragraph 7 of
the complaint affidavit. I never became jealous with her to
anyone nor became possessive. I cannot recall that I accused
her with anything without any proof or basis, it might just a simple
misunderstanding between us;
9. That I am innocent of the crime charged against me. The charges
against me are purely baseless and untrue;
10. I am executing this affidavit in order to attest to all the foregoing
facts and for whatever legal purpose it may best serve.
PRAYER
WHEREFORE, premises considered, it is respectfully prayed
that the instant criminal complaint be DISMISSED for lack of merit.
Further, the respondent respectfully prays for such, and other
reliefs as may be deemed just and equitable in the premises.
IN WITNESS WHEREOF, I have hereunto set my hand this 3rd
day of May 2025 in Caloocan City, Philippines.
Papa P
Affiant
SUBSCRIBED AND SWORN to before me this 3rd day of May
2025 in Caloocan City, Philippines and I further certify that I have
personally examined the affiant exhibiting to me his Philippine
Passport No. P9172013B, and I am satisfied that he has read and
personally understood the contents of her foregoing “Counter
Affidavit.”
NOTARY PUBLIC
Doc. No. 6;
Page No. 13;
Book No. 17;
Series of 2025.
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