Counter Affidavit - Drugs

Republic of the Philippines Department of Justice NATIONAL PROSECUTION SERVICE OFFICE OF THE CITY PROSECUTOR Pasay City PEOPLE OF THE PHILIPPINES, Complainant, -versus-

I.S. No. __________ For: Violation of Sec. 5 Article 2 of RA 9165 (Selling of Dangerous Drugs

HAROUN AL-RASHID A. PANDAPATAN, Respondent. x----------------------------------------------------x

COUNTER-AFFIDAVIT

I, HAROUN AL-RASHID A. PANDAPATAN, Filipino, of legal age, and with residence at 32 F. Victor St. Brgy. 62, Pasay City, after having been duly sworn in accordance with law, hereby depose and state that: 1. I was charged by SPO4 KAREN PEARL CUE for violation of Sec. 5 Article 2 of RA 9165 (Selling of Dangerous Drugs); 2.

I did not sell drugs and I vehemently deny all the allegations that she has stated on her complaint- affidavit. There is no truth to the charges being leveled at me. The statements of the complainant and the witnesses are full of lies and were meant to extort money from me;

3.

The facts on the complaint affidavit that she has made against me were merely fabricated stories because I refused to give in to her demand of giving twenty thousand pesos (P 20,000.00);

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4. On 8 August 2015 at around 10:30 P.M, I was at my friend ANVARI F. ARGUELLES house in Emma St. Brgy. 57, Pasay City watching basketball in the television. ARGUELLES asked me to buy a pack of cigarette in the store. 5.

While I was walking along Delas Alas St. to buy a pack of cigarette, I was approached by P03 ANGELIQUE BIEN TIONGSON. At the time she was wearing civilian clothing and was posing as seller of cigarettes in the streets;

6.

TIONGSON asked me if I wanted to buy cigarettes from her. Since there is no nearby sari-sari store, I decided to just buy cigarettes from her instead;

7.

Upon giving TIONGSON the money, she placed something inside my right pocket. I took it out and saw plastic sachet containing shabu;

8.

It was at that moment when CUE appeared and informed me that this is a entrapment operation;

9.

CUE demanded twenty thousand pesos (P20,000.00)from me or else they will arrest me for selling drugs;

10.

When I refused to pay the said amount, CUE placed handcuffs on me and brought me to the police station;

11.

I strongly believe that CUE filed the complaint to extort money from me and to harass me;

12.

I am voluntarily executing this affidavit to attest to the truthfulness of the foregoing facts and to support the outright dismissal of the complaint filed against me.

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AFFIANT FURTHER SAYETH NAUGHT. IN WITNESS WHEREOF, I have hereunto set my hand this 12 th day of August 2015, in Pasay City.

HAROUN AL-RASHID A. PANDAPATAN Accused/Affiant

SUBSCRIBED AND SWORN TO before me, this 13th day of August 2015 in Pasay City.

SUBSCRIBED AND SWORN to before me this 13 th day of August 2015 in the city of Pasay. I further certify that I have personally examined the Affiant and I am satisfied that he/she voluntarily executed and understood his/her statement.

CARYL JANE VILLANOZA Administering Officer Doc. No. _____; Page No. _____; Book No. _____; Series of 2015.

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