Defense

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Republic of the Philippines
OFFICE OF THE OMBUDSMAN
OFFICE OF THE DEPUTY OMBUDSMAN FOR THE MILITARY
AND OTHER LAW ENFORCEMENT OFFICES
3rd Floor, Ombudsman Building, Agham Road
Diliman, Quezon City (1104)

NELSON A. CALLEJA,
Complainant,

-versus-

PO ABE ESCIO, ET AL.,
Respondent.
x------------------------------------x

REPUBLIC OF THE PHILIPPINES

COUNTER-AFFIDAVIT

I, ABE BARRERA ESCIO, Filipino, of legal age, a resident of NO. 351 Mayon Street, San Isidro Labrador, Quezon City, after having been sworn to in accordance with law, hereby depose and state: THAT –

1. I am the respondent in the above-entitled case and I am filing the instant Counter-Affidavit in compliance with the Order of this Honorable Office dated September 27, 2010 directing me to submit my Counter-Affidavit and the Affidavit of my witnesses, if any and such other controverting evidence in defense of the charge of complainant Nelson Abrenica Calleja (“complainant”), a Barangay Public Safety Officer (BPSO) of Barangay Lourders, Quezon City, against me for Less Serious Physical Injuries.

2. I am a Senior Police Officer III (Salary Grade 18). Attached hereto as Annex “1” is a photocopy of my Form No. 33 issued by the Philippine National Police (PNP) – Police Security and Protection Group and submitted with the Civil Service Commission (CSC) anent to my appointment as such.

3. In a nutshell, complainant alleged that I assaulted and beat complainant thus inflicting injuries on him while he and his fellow BPSO, Arnold Gajelloma Quibete were allegedly manning the traffic at Simoun corner Perez Streets, Barangay Lourdes, Quezon City on March 10, 2009; hence, the charge for the crime of Less Physical Injuries against me.

4.

-----------------------

OMB-P-C-09-0304-D
For: Less Serious Physical Injuries

S.S.
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