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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
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CERTIFICATION
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
BAILBOND RECOMMENDED:
AYESHA S. THOMPSON
AND KLAY S. THOMPSON I.S NO. ____________
COMPLAINANTS NOS. DOC NO. XII-04INV
2051-00063
-versus- -for-
THE PARTY
Name: KLAY S. THOMPSON
Address: 613 Aguho St., Luna Subd., Davao City
Occupation: Hospital Administrator, Thompson General Hospital
Matalam, Cotabato
Status: Married
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;
JOINT COUNTER-AFFIDAVIT
ATTESTATION
JUREE B. MUDANZA
Affiant
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
SUPPLEMENTAL AFFIDAVIT OF
Ayesha S. Thompson
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.