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REPUBLIC OF THE PHILIPPINES

OFFICE OF THE PROVINCIAL PROSECUTOR


Tagbilaran City, Bohol

SPO2 ANTONETTE JUMAWAN


Complainant,
NPS Case No. 12345
For: Treason
-versus-

EDITHA CAJEGAS
Respondent.
xx----------------------------------------xx

COUNTER AFFIDAVIT

I, EDITHA CAJEGAS, of legal age, Filipino, and a resident of Anislag, Corella, Bohol
after being sworn to in accordance with the law, hereby depose and state that:

1. That I am the person who is charged with Treason before the Office of the Provincial
Prosecutor docketed under NPS Case No. 12345 for the crime of Treason under
Article 114 of the Revised Penal Code;
2. That paragraph 1 of the Complaint Affidavit of the Complainant is false in that there
is no war between the Philippines and the People's Republic of China which
signifies a time of peace and friendly relations between the two countries;
3. The allegations in SPO2 Jumawan's Complaint Affidavit are nothing but
exaggerations and blatant falsehoods:

a) At about 2:45 in the morning on January 29, 2020, I received a call from my
previous employer (I was a nanny) in Beijing, China telling me that my ward
Zulin Keng is in Bohol and was gravely injured after having fought some
robbers in his house in San Isidro, Tagbilaran City;
b) That the said robbery was duly blottered at the Tagbilaran City Police Station
under Exhibit A;
c) That about 3:45 in the morning, Zulin's friends collected me from my home on
their midnight black Range Rover, a vehicle which could easily be mistaken for a
military vehicle, in order for me to look after my ward who was in the hospital;
d) That about 4:45 in the morning, after being discharged from the Out-Patient
Department of Ramiro Community Hospital, as my ward's injury was not grave
as it was thought, my ward and his friends took me home wherein I invited to
them to stay for a day so I can take care of my ward;
e) That SPO2 Jumawan and her team forcefully entered my home with guns
akimbo, which caused everyone present in my home to leave through the back
door in fright of the police;
f) That although my ward is a son of a high-ranking Chinese military, he and his
friends are not in any way military but are rather scientists who have come to
Bohol to take a vacation;

4. That the aid which I extended to Zulin and his friends is not an act which could
weaken the Philippines' security but a show of concern for my ward whom I cared
for nearly five years of my life in China;
5.That the instant complaint for Treason is false, malicious, baseless, unfounded and
unjust fabrication merely contrived to cause public disorder and unrest and damages to
the respondent;
6. And the witness affidavit stated by Mr. Amora was also fabricated and told by a man
with a highly imaginative mind
7. Considering the foregoing, I respectfully pray that that I be acquitted of the crime of
Treason under Article 114 of the Revised Penal Code, wrongfully imputed upon me by
SPO2 Jumawan.

TO THE TRUTH OF THE FOREGOING, I have signed this Counter Affidavit on February 14,
2020.

EDITHA CAJEGAS
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, this 14 th day of February. 2020 at Tagbilaran
City.

CONSEN T. DOR
Prosecutor

CERTIFICATION

I hereby certify that I have personally examined the Affiant and that I am satisfied that he
voluntarily executed and understood his Affidavit.

CONSEN T. DOR
Prosecutor
CERTIFICATION

TO WHOM IT MAY CONCERN:

THIS IS TO CERTIFY that based on the Police Blotter of this Police Station, record of the events mentioned
hereunder was entered in the Log Book Blotter, to wit;

BLOTTER ENTRY No. : 01272020


PAGE NUMBER : 012
NATURE OF CASE, INCIDENT : Robbery
DATE/TIME OF OCCURRENCE : January 29, 2020, 2:30am
PLACE OF OCCURRENCE : Purok 1, San Isidro Dist., Tagbilaran

FACTS OF THE CASE:

That on or about 3 o'clock in the morning of January 29, 2020, this office received a complaint particularly in
Keng's residence. Initial investigation was conducted by PO2 Anna Iroy, revealed that on above-mentioned time, date
and place, while Zulin Keng. 25 years old, single, vacationing in his temporary residence at San Isidro District,
Tagbilaran City together with his friends Lin Hong, 25 years old and Kim Khu, 25 years old, temporarily residing at
aforementioned address. Two unidentified malefactors broke into the victim's residence through an unlocked window
and took his laptop, ipad mini and cash of Php 20,000. Upon hearing a noise outside of his room, Keng inspected the
premises and caught one of the malefactors clutching his laptop. He yelled for his friends but the two malefactors
were already halfway through the window from which they came in. Keng tried to retrieve his laptop but one of the
malefactors got the rake from which they use to hold the window open and beat Keng's right leg with it, resulting to
slight injury. Weakened by his injury, the suspects were able to fled away after the incident to an unidentified
direction.

DISPOSITION : For the record as requested.


ATTENDED BY : SPO1 Joanne Pandan

This certification is being issued upon request of Mr. Zulin Keng in connection with his application for
availment of Protective Security Personnel.

Issued this 29th day of January. 2020, Tagbilaran City, Bohol, Philippines.

For the Station Commander:

JO BUKO
Police Senior Inspector
Chief, SIDM

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