PROSECUTOR

Republic of the Philippines

Department of Justice
OFFICE OF THE CITY PROSECUTOR
Pasay City

PEOPLE OF THE PHILIPPINES, Crim. Case No. 2017-0909064

Complainant, NPS Doc No. NCR-04-INQ-17090908

- versus -
For: Rape
ZALDY PEREZ
Respondent.

INFORMATION

The undersigned Associate City Prosecutor, upon sworn complaint originally filed
by the offended party accuses ZALDY PEREZ of the crime of RAPE, defined and
penalized under Article 266-A, par. 1(a), of the Revised Penal Code, as amended,
committed as follows:

That on or about the 7th day of February 2017, in the City of Pasay,
Philippines,and within the jurisdiction of this Honorable Court, the above-named
accused while the victim was on her way to school, she was waylaid by the accused
wearing a make shift ski mask and armed with a sharp-pointed bolo locally known as
sundang and brought her to an isolated hut where she was alone and ordered her to
undress and forced her to lie down and by means of force and intimidation did then and
there willfully, unlawfully and feloniously succeed in having carnal knowledge with
SHERRYL WYNE BATION, a 19-year-old girl without her consent and against her will.

Contrary to law.

Pasay City. September 15, 2017

ATTY NILA MITRA MEDRANO

Assistant City Prosecutor

Subscribed and sworn to before me this 15th day of September

2017, in the City of Pasay, Philippines.

WITNESSES:

CRIZZA LYN COZ – Barangay 20 Pasay City

SPO4 JOY ANNE PASCUAL– Pasay City Police Station

NO BAIL RECOMMENDED.

Address of the Accused: No. 5678 Barangay 245, Pasay City

Approved:

ATTY. OLIVA CECIL A. CARITOS

City Prosecutor
 Republic of the Philippines
Department of Justice
OFFICE OF THE CITY PROSECUTOR
Pasay City

PEOPLE OF THE PHILIPPINES, Crim. Case No. 2017-0909064

Complainant, NPS Doc No. NCR-04-INQ-17090908

- versus -
For: Rape
ZALDY PEREZ
Respondent.

x----------------------------------------------x

COMPLAINT AFFIDAVIT

I, SHERRYL WYNN BATION, 19 years old, single, a college student,

and residing at No. 2345 Barangay 20, Pasay City, after having been duly
sworn in accordance with law, hereby depose and state that :

1. This complaint affidavit is being filed to charge PEREZ ZALDY,

Filipino, of legal age, and with residence at No. 2345 Barangay 245,
Pasay City, of the crime of Rape under Article 266-A of the Revised
Penal Code (RPC), committed as follows:

a. On February 7, 2017, at around 5:00 a.m., I was accompanied

by mother, CRIZZA LYN COZ, going to the feeder road of
Barangay 20, Pasay City. She left me when we arrived at the
waiting shed. I am waiting for a jeepney to take a ride to school
when herein Respondent PEREZ wearing a makeshift ski mask
and armed with a swiss knife, suddenly grabbed my hair;

b. ZALDY PEREZ then poked the sundang on my side and pulled

me towards a grassy area;

c. I tried to free myself and pleaded for mercy, but to no avail, he

continued to drag me until we reached a nearby stream then
shoved me towards an uninhabited house with the knife;

d. Alegre then told me to undress but I did not obey and asked
him to remove his mask so I could identify him, he then
acceded and removed his mask. Then, he ordered me again to
remove my dress;
 e. When I refused to remove my dress, he grabbed my skirt and
forcibly removed the buttons to open my skirt. Then he pushed
me to the floor where he removed my panty. He immediately
placed himself on top of me, then he made a push and pulls
motion and inserted his penis inside my vagina;

f. After he made a sexual intercourse, he let me put on my dress.

Then he told me that he would kill me if I tell anyone about what
happened. Then he let me walk towards the waiting shed but
he was still behind following me;

g. When I saw many people on the road, I shouted for help but he
immediately stabbed me at my back, then I fell to the ground
and he immediately ran away;

h. I was brought to the Pasay General Hospital and was confined

for nine (9) days;

2. On the afternoon of February 7, 2017, I was interviewed by SPO4

JOY ANNE PASCUAL and told him that I was stabbed by a man,
whom later identified as ZALDY PEREZ who had tattoos on his right
shoulder and in between his thumb and index finger;

3. Because I was so afraid that time to tell the truth, I only told SPO4
Revilla that ZALDY PEREZ only touched me in my private parts;

4. On the evening of February 11, 2017, SPO4 Revilla brought ZALDY

PEREZ to the hospital and because I was still afraid that time, I only
identified ZALDY PEREZ as the one who stabbed me;

5. It took me few days before I was able to overcome my fear and on my

sixth day of confinement, I told my mother what happened to me;

6. Thus I was examined by Dra. LALIE ANN RAMOS, Medical Officer

IV of Pasay General Hospital;

7. After I was discharged from the hospital, my mother and I went to the
police station to report the crime committed by ZALDY PEREZ and to
file the appropriate charges;

8. I am executing this Complaint Affidavit to attest to the truth of the

foregoing facts, to apprise the proper authorities concerned and to
constitute the same as basis in the filing of a Criminal Information
against ZALDY PEREZ for the crime of RAPE.
 IN WITNESS WHEREOF, I have signed this Affidavit this 20th day of
February, 2017 in Pasay City, Philippines.

SHERRYL WYNE BATION

Affiant

CERTIFICATION

SUBSCRIBED AND SWORN TO before me this, 20th day of February

2017 in Pasay City, Philippines, I hereby certify that I have examined
Affiant and I am satisfied that she voluntarily executed and understood the
contents of her Complaint- Affidavit.

Atty. Nila Mitra Medrano

Assistant City Prosecutor
Republic of the Philippines)
CITY of PASAY ) S.S.

AFFIDAVIT

I, CRIZZA LYN CO, of legal age, and residing at No. 2345 Barangay 20,
Pasay City, Philippines, after having been sworn in accordance with law, do hereby
depose and state that:

1. I am the mother of SHERRYL WYNE BATION, 19 years old, single and

a college student;

2. That on February 7, 2017, at around 5:00 a.m., I accompanied my daughter

going to the feeder road of Barangay 20, Pasay City. I left her when we
arrived at the waiting shed, where she usually waits for a jeepney to take a
rideto school.

3. That on the same day, after hearing that my daughter was stabbed and was
brought to the Pasay General Hospital and confined therein, I immediately
went to the said hospital;

4. That I asked my daughter what happened but she merely cried and did not
answer my question;

5. That on the sixth day of my daughter’s confinement, she told me that she
was raped by ZALDY PEREZ;

6. That after the discharged of my daughter from the hospital, we went to the
police station to report the crime committed and to file the appropriate
charges against ZALDY PEREZ;

7. That I am executing this Affidavit to attest to the truth of the foregoing facts
and that the highest interest of justice will be served.

In WITNESS WHEREOF, I have hereunto affixed my signature this 20 th

day of February 2017 in Pasay City, Philippines.

CRIZZA LYN COZ

Affiant
 CERTIFICATION

SUBSRIBED AND SWORN TO before me, this 20th day of February 2017
in Pasay City, Philippines. I hereby certify that I have examined Affiant and I am
satisfied that she voluntarily executed and understood the contents of her Affidavit.

Atty. Nila Mitra Medrano

Assistant City Prosecutor

Republic of the Philippines

 National Police Commission
Philippine National Police
SOUTHERN POLICE DISTRICT
PASAY POLICE STATION
Andrews Ave., Pasay City

MEMORANDUM

FOR :

FROM : The Chief NPDCLO

Pasay City Police Station

SUBJECT : Investigation Report on the Request for Semen Analysis

DATE : February 14, 2017

I AUTHORITY

1. Memo from that Office dated February 14, 2017 re-investigation report
on the above subject.

2. Inherent

II MATTERS TO BE INVESTIGATED

3. To determine the surrounding circumstances of the rape of the said

police officer.

4. To possibly identify the suspects that will led to their apprehension and
possible prosecution

III FACTS OF THE CASE

5. On February 7, 2017, at around 7:30 a.m., while SHERRYL WYNN

BATION, 19 years old, single, a college student, and residing at No.
2345, Barangay 20, Pasay City, was walking on the feeder road of
Barangay 20, Pasay City, going to the waiting shed to take a ride to
school, herein suspect ZALDY PEREZ, wearing a makeshift ski mask
and armed with a bladed weapon known as swiss knife, suddenly
grabbed the victim’s hair. The suspect poked the knife on the victim’s
side and pulled the victim towards a grassy area. The victim tried to
free herself and pleaded for mercy, but to no avail, the suspect
continued to drag the victim until they reached a nearby stream then
shoved the towards an uninhabited house with the knife; then told me
to undress but I did not obey and asked him to remove his mask so I
could identify him, he then acceded and removed his mask. Then, he
ordered me again to remove my dress. The victim refused to remove
her dress; the suspect grabbed her skirt and forcibly removed the
buttons to open the victim’s skirt. Then the suspect pushed the victim
to the floor where her panty was removed. The suspect immediately
placed himself on top of the victim, and then suspect made a push and
pulls motion and inserted his penis inside the victim’s vagina. After the
sexual intercourse, the suspect let the victim to put on the dress. Then
told the victim that he would kill her if she would tell anyone about what
happened. Then he let the victim to walk towards the waiting shed but
 he was still behind following the victim. When the victim saw many
people on the road, she shouted for help but the suspect immediately
stabbed the back of the victim, then she fell to the ground and the
suspect immediately ran away. The victim was brought to the Pasay
General Hospital and was confined for nine (9) days.

6. ZALDY PEREZ, of legal age, and with residence at No. 5678,

Barangay 245, Pasay City vehemently denied raping SHERRYL
WYNN BATION. He alleged that he was at his house the entire day of
February 7, 2017, gathering coconuts. Around 5:00 a.m. on the said
date, he cooked breakfast then rested. At around 6:00 a.m., he started
gathering coconut in his yard and finished in the afternoon. The next
day, he husked the coconuts he had gathered, cut them in halves and
placed them in the kiln. On February 9, 2017, he smoked the coconuts,
separated the cooked coconut meat from their shells and placed them
in a sack. Then, on the morning of February 11, 2017, appellant, his
father and Domingo Basijan, the owner of the coconuts, sold the copra.
On the afternoon of December 10, 2016, while playing basketball at
the public plaza, his cousin LLEWELLYN MANJARES invited him to
the formers house in Barangay 245, Pasay City to help MANJARES’s
family prepare food for a celebration of a death anniversary. It was
while he was in MANJARES’s house that he was arrested by a certain
police officer Cabrera, who arrived together with another policeman
and a barangay tanod. Cabrera allegedly tied his hands. When he
asked them what his fault was, Cabrera replied that there was a
complaint against him and that he was bringing him to SHERRYL
WYNN BATION. Aboard a garbage truck, appellant, together with
Dominick and his nephew, Anthony Amor, was brought to the Pasay
General Hospital and presented before SHERRYL WYNN BATION.

7. SHERRYL WYNN BATION allegedly failed to pinpoint him as the

culprit, but he and his two (2) relatives were nonetheless incarcerated
at the Pasay City Municipal Jail. Appellant added that his two (2)
relatives were released from jail the following morning. While he was in
jail, Cabrera brought in two (2) women victims to identify him if he was
the one (1) who waylaid them. The women, however, declared he was
not the one (1) who assaulted them. Cabrera has ill feelings towards
him because he defied Cabreras order to stop cutting trees. He
explained that cutting trees is his only source of livelihood.

8. EMYROSE R. REAS GARIN, on the other hand, testified that on the

morning of FEBRUARY 7, 2017, she was at her house which was
about only 10 meters away from ZALDY PEREZ house. From 6:00
a.m. to 7:00 a.m. of the said day, she saw ZALDY PEREZ and the
latters wife, JEREMIAH, fixing the roof of their house. After eating
breakfast, ZALDY PEREZ went out of his house and started gathering
coconuts near her yard because the coconuts which ZALDY PEREZ
was gathering were located behind her house. She said ZALDY
PEREZ finished gathering coconuts from Nur-Asia Mitmig land at
around 11:00 a.m. She alleged that ZALDY PEREZ never left his
house or the land where he gathered coconuts from 6:00 a.m. to 11:00
a.m. She, however, said that she cannot see the entire coconut
plantation from her house and did not see ZALDY PEREZ at all times
while he was gathering coconuts at the plantation. Vangie added that
she knows Barangay 11,Pasay City, where the crime happened, and
declared that said barangay is about three and a half (3) kilometers
 away from her house in Barangay 187. Motor vehicles also regularly
ply the route from Barangay 11 to Barangay 187.

9. The wife of, ZALDY PEREZ, JEREMIAH QUILANG PEREZ for her
part, testified that ZALDY PEREZ left their house in Brgy. 187
at 6:00 a.m. on December 7, 2016 to gather coconuts at the plantation
of NUR-ASIA MITMUG where he was a tenant. At 8:00 a.m., her
husband returned to their house and they fixed the roof of their house.
At around 9:00 a.m., they finished fixing the roof and his husband
returned to the coconut plantation to gather coconuts anew until 11:00
a.m. Thereafter, she said ZALDY PEREZ went home and rested.
According to her, from 6:00 a.m. to 11:00 a.m., her husband did not go
to any other place except the coconut plantation. During all that time,
she knew that ZALDY PEREZ was in the plantation because she
heard the sound of coconuts dropping to the ground.

IV INVESTIGATION/FINDINGS

10. In this instant case under investigation and bothparties have

respective allegation related with the incident. In the statement of
SHERRYL WYNN BATION while she was walking on the feeder road
of Barangay 11, Pasay City, going to the waiting shed to take a ride to
school, ZALDY PEREZ wearing a makeshift ski mask and armed with
a bladed weapon known as swiss knife, suddenly grabbed my hair; she
was pulled towards grassy area until they reached a nearby stream
and there were the sexual intercourse was made. Then ZALDY
PEREZ let her to get her clothes and let her walk towards the waiting
shed. ZALDY PEREZ was still behind her while they are walking
towards the waiting shed upon seeing many people in the road
SHERRYL WYNN BATION shouted for help but he immediately
stabbed her at the back, then I fell to the ground and he immediately
ran away suspect. On the evening of February 11, 2017, SPO4
Pascual brought ZALDY PEREZ to the hospital and was identified by
SHERRYL WYNN BATION as the one who stabbed her who had
tattoos on his right shoulder and in between his thumb and index
finger.

Ocular Inspection was made by the duty investigators at the

scene of the crime and there the gray boxer was found. The swiss
knife was obtained from the residence of ZALDY PEREZ at No.5678,
Barangay 245, Pasay City. The black panty was obtained from the
possession of the victim SHERRYL WYNN BATION at the Pasay
General Hospital.

V CONCLUSION

11. After careful perusal surrounding this particular case, considering both
allegations of the parties the statement by SHERRYL WYNN BATION
and the medical examination conducted at the Pasay General Hospital
while ZALDY PEREZ vehemently denies the accusation made against
him.

VI RECOMMENDATION/DISPOSITION
12. Wherefore, in view of the foregoing, the undersigned respectfully
recommends that specimens recovered undergo laboratory examination
and the SHERRYL WYNN BATION undergo medical examination and
parties involved file their separate complaint against each other.

JOY CREUS PASCUAL

Senior Police Officer 4
Officers-on-Case
 Republic of the Philippines
National Police Commission
SOUTHERN POLICE DISTRICT
PASAY CITY POLICE STATION
WOMEN AND CHILDREN PROTECTION DESK
Andrews Ave., Pasay City

MEMORANDUM

FROM : The Chief NPDCLO

Pasay City Police Station

SUBJECT : Request for Semen Analysis

DATE : February 14, 2017

1. Request examination to the victim for the purpose of Physical/Genital

Examination

A. Nature of Case: Alleged Rape in relation to R.A. No. 8353

B. Victim: SHERRYL WYNN BATION, 19 years old, single, a

college student, and residing at No. 2345, Barangay 20, Pasay City

C. Suspect: ZALDY PEREZ, of legal age, and with residence at

No. 7789, Barangay 187, Pasay City (Under Custody)

D. TPDO: Between 4:00-6:00 AM February 7, 2017 at Barangay

20, Pasay City

E. Specimen Submitted:

a) one (1) black panty marked as “7-1;

b) one (1) gray boxer marked as “7-2;

2. Further request that this office be furnished a copy of the result.

RAYMOND PANIS
Senior Police Officer 4
OIC, WCPD
DEFENSE
 Republic of the Philippines
Department of Justice
OFFICE OF THE CITY PROSECUTOR
Pasay City

PEOPLE OF THE PHILIPPINES, Crim. Case No. 2017-0909064

Complainant, NPS Doc No. NCR-04-INQ-17090908

- versus -
For: Rape
ZALDY PEREZ
Respondent.

COUNTER-AFFIDAVIT

I, ZALDY PEREZ, of legal age, married, Filipino, and a resident of No.

5678 Barangay 245 Pasay City, after having sworn to in accordance with
law, hereby depose and state that:

1. That I am the respondent in I.S. No. _____________, for the violation of

Article 266-A (a) of Republic Act No. 8353 “An Act Expanding the
Definition of the Crime of Rape”. Filed by SHERRYL WYNN BATION at
the Office of the City Prosecutor, Pasay City;

2. That I am executing this affidavit to vehemently deny the

accusations of SHERRYL WYNN BATION, that I allegedly raped her;

3. That last February 7, 2017, contrary to SHERRYL WYNN BATION

allegations, I was at the factory at Barangay 20 Pasay City, the
whole day doing my job collecting and arranging coconuts as a
worker involved in extracting coconut oil.

4. That my day started at five o’clock in the morning, 5:00 am, in

preparing our family breakfast. At six o’clock in the morning, 6:00
am, I started collecting and arranging the delivered coconut.
Afterwards, I removed the husks for processing. I finished my work
late in the afternoon of the same day.
5. That on February 8, 2017, from early in the morning till late in the
afternoon, I broke the coconuts in half and separated the coconut
meat and placed it in the kiln to extract the oil.

6. That on February 9, 2017, I collected the extracted oil in large tin

cans. I was able to finish this late in the afternoon of the same day.

7. That on the morning of February 10, 2017, I was with my father and
Ms. Nur-Asia Mitmug, owner of the oil factory, since we sold the
extracted coconut oil to another trader also at Barangay 20, Pasay
City.

In the afternoon of the same day while playing basketball, I

was invited by my cousin, Mr. Llewelyn Manjares to help them in
preparing food in their house at Barangay , Pasay City since they
were celebrating a death anniversary.

8. That while I was in the house of my cousin, Llewelyn Manjares ,

Police Officer Cabrera arrived, accompanied by another police

officer and a barangay tanod, to arrest us.

Police Officer Cabrera tied our hands, and when I asked the
reason for our arrest, we were told by Police Officer Cabrera that
there was a complaint against me and he was bringing us to
SHERRYL WYNN BATION.

9. That Police Officer Cabreras, loaded my cousin Llewelyn Majares,

my nephew JOHN DEXTER VALDERAMA and me in a Garbage Truck

and brought us all to Pasay City General Hospital.

At the hospital we were confronted by SHERRYL WYNN BATION

who failed to point to us as her assailant. Even though
 SHERRYL WYNN BATION failed to identify us, Police Officer Cabrera
put us in jail.

10. That on February 11, 2017, Police Officer Cabrera released my

cousin and nephew, while I was left as a lone respondent in jail.

While inside the jail, Police Office Cabrera even sent in two (2)
women victims to identify me, if I was their assailant. I heard the two
(2) women say to Police Officer Cabrera that I was NOT the one
who assaulted them.

11. That the complainant’s averments in his affidavit are concocted

lies, perpetuated by Police Officer Cabrera to harass and pressure
me to stop burning coconut husk and shell, as his per order that I
defied, to my damage and prejudice, since it is my livelihood.

12. That I am executing this affidavit to express and show the whole
truth and I humbly pray that the instant case be dismissed;

IN WITNESS WHEREOF, I hereunto affixed my signature this 7th day of

February, 2017 at Pasay City.

ZALDY PEREZ
Affiant

CERTIFICATION
 SUBSRIBED AND SWORN TO before me, this 7th day of February 2017
in Pasay City, Philippines. I hereby certify that I have examined Affiant and I am
satisfied that she voluntarily executed and understood the contents of her Affidavit.

Atty. Nila Mitra Medrano

Assistant City Prosecutor
Republic of the Philippines)
CITY of PASAY ) S.S.

AFFIDAVIT

I, ARLENE CASTILLO, of legal age, and residing at No. 5683 Barangay

245, Pasay City, Philippines, after having been sworn in accordance with law, do
hereby depose and state that:

1. I am the sister-in-law of ZALDY PEREZ, 32 years old and married;

2. That on February 07, 2017, I was at my house that was about only 10 meters
away from the coconut factory at Barangay 245, Pasay City where ZALDY
PEREZ works. On that same day, from 5:00am to 6:00am, I saw ZALDY
PEREZ started gathering coconuts from the coconut factory which is just
near my yard;

3. That I saw ZALDY PEREZ finished gathering coconuts at around 11:00 am

of February 07, 2016 and that whenever he left the land where he gathered
coconuts from 5:00am to 11:00am;

4. That I know the feeder road of Barangay 20, Pasay City, where the crime
happened, which is 3 kilometers away from my house where motor vehicles
also regularly ply the route from Barangay 20 Pasay City to Brangay 21,
Pasay City; and

5. That I am executing this Affidavit to attest to the truth of the foregoing facts
and that the highest interest of justice will be served.

In WITNESS WHEREOF, I have hereunto affixed my signature this 5th day

of February 2017 in Pasay City, Philippines.

APRIL POBAR
Affiant
 CERTIFICATION

SUBSRIBED AND SWORN TO before me, this 25th day of February 2017
in Pasay City, Philippines. I hereby certify that I have examined Affiant and I am
satisfied that she voluntarily executed and understood the contents of her Affidavit.

Atty. Nila Mitra Medrano

Assistant City Prosecutor
Republic of the Philippines)
CITY of PASAY ) S.S.

AFFIDAVIT

I, JEREMIAH QUILANG ALEGRE, of legal age, Filipino, and residing

at Barangay 11, Pasay City, Philippines, after having been sworn in accordance
with law, do hereby depose and state that:

1. I am the wife of RAINIER ALEGRE, 35 years old and married;

2. On February 07, 2017, my husband RAINIER ALEGRE woke up at

around five o’clock in the morning and started to prepare our meal since I
was sick that time and cannot prepare for our family breakfast. After we ate,
at around six o’clock, he left our house and went to the coconut plantation to
start collecting and arranging the delivered coconut;

3. He returned to our house late in the afternoon on that same day. During all
the time that he was not in our house, I knew that he never left the coconut
plantation because I heard the sound of coconuts dropping to the ground;

4. On February 11, 2016, I was surprised when I learned that my husband

RAINIER ALEGRE has been arrested for allegedly raping a college
student. My husband can never do that, he is always been a good husband
and father to our child; and

5. I am executing this Affidavit to attest to the truth of the foregoing facts and
that the highest interest of justice will be served.

In WITNESS WHEREOF, I have hereunto affixed my signature this 25th

day of February 2017 in Pasay City, Philippines.

JEREMIAH QUILANG ALEGRE

Affiant

CERTIFICATION

SUBSRIBED AND SWORN TO before me, this 25th day of February 2017
in Pasay City, Philippines. I hereby certify that I have examined Affiant and I am
satisfied that she voluntarily executed and understood the contents of her Affidavit.

Atty. Nila Mitra Medrano

Assistant City Prosecutor
Republic of the Philippines )
Pasay City ) S.S.
X----------------------------------X

AFFIDAVIT OF WITNESS

I, LLEWELLYN MANJARES, 48 years old, single, Filipino Citizen and

residing at Barangay 12 Pasay City, after having been duly sworn to in accordance
with law hereby depose and say:

1. That I am fully conscious, that I am answering the following questions asked

of me under oath, and that I may face criminal liability for false testimony or
perjury;

2. That in the afternoon of February 11, 2017, I was playing basketball with the
accused, ZALDY PEREZ, in the Basketball court of Pasay;

3. That after the basketball game on the same day, I invited accused appellant
to join me in my residence at Barangay 246, Pasay City to celebrate a death
anniversary of a relative, to which the accused accepted the invitation;

4. That sometime during the celebration at my residence, Police Officer

Cabrera arrested me, accused ZALDY PEREZ and nephew JOHN
DEXTER VALDERAMA an unspecified complaint and were made to
board a garbage truck for purpose of transportation;

5. That we were made to alight the garbage truck at the Pasay City General
Hospital for the purpose of identification by private complainant
SHERRYL WYNN BATION;

6. That after being brought before private complainant SHERRYL WYNN

BATION, the latter failed to pinpoint culprit, among the three of us, to her
complaint;

7. That Police Officer Cabrera nonetheless incarcerated the three of us at the

Pasay City Jail;

8. That it was only in the following day, on February 12, 2017 that I and
nephew JOHN DEXTER VALDERAMA were released from detention,
while accused ZALDY PEREZ remained in jail;

9. That being a “kababata” of the accused and having known him ever since
childhood up to the present I am of a strong opinion that it is highly
improbable that the accused, ZALDY PEREZ could commit the crime
charged against him as I have known him since then to be a friendly and
good natured person who has not been convicted of any crime nor charged
of any crime; and
 10.That I executed this affidavit to attest the truthfulness of the foregoing facts
and to support the defense of the respondent, ZALDY PEREZ in relation to
the filing of criminal case of Rape against him.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 11th

day of February 2017, at Pasay City, Philippines.

LLEWELLYN MANJARES
Affiant

CERTIFICATION

SUBSRIBED AND SWORN TO before me, this 11th day of February 2017
in Pasay City, Philippines. I hereby certify that I have examined Affiant and I am
satisfied that she voluntarily executed and understood the contents of her Affidavit.

Atty. Nila Mitra Medrano

Assistant City Prosecutor
REPUBLIC OF THE PHILIPPINES)
PASAY CITY ) S.S.
x-------------------------------------------x

AFFIDAVIT OF WITNESS

I, Nur-Asia Mitmug of legal age, married, Filipino, and a resident of

Barangay II Pasay City, after having been duly sworn in accordance with
law, hereby depose and state:

1. That I am the owner of Organico Coconut Oil Trading, a duly

registered sole proprietorship engaged in the production, marketing
and supply of virgin coconut oil in the Philippines.

2. That I personally know the respondent ZALDY PEREZ, who has

been working with me as a senior factory worker for almost five years
now, as hardworking, responsible and respectful employee.

3. That in the morning of February 7, 2017 around 7:00 am, while doing
a routine inspection in the factory, I saw the respondent in the
manufacture area removing the coconut husks for processing, and
even greeted me “Good morning Sir.”

4. That around 10: 00 am of the same day, the respondent made a

report in my office on the status of our target production which is
bound for delivery on February 12, 2017.

5. That I noticed no unusual or strange behavior exhibited by the

respondent on that day.

6. That I executed this affidavit to attest the truthfulness of the foregoing

facts and to support the defense of the respondent, ZALDY PEREZ
in relation to the filing of criminal case of Rape against him.

IN WITNESS WHEREOF, I have signed this Affidavit this 11th day of

February, 2017 in Pasay City, Philippines.

Amor Rutherford
Affiant
 CERTIFICATION

SUBSRIBED AND SWORN TO before me, this 11th day of February 2017
in Pasay City, Philippines. I hereby certify that I have examined Affiant and I am
satisfied that she voluntarily executed and understood the contents of her Affidavit.

Atty. Nila Mitra Medrano

Assistant City Prosecutor