REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
QUEZON CITY

BERNADETH S. BOLA
Complainant.
Vs. I.S. No. ______________________
For: Illegal Trespass to Dwelling;
Falsification and Use of Falsified
Documents and Usurpation of Public
Office

OLIVER T. GALAN
ANALIE BALMOCENA-GALAN
MITCHELLE L. LOAYON
JOCELYN RODRIGUEZ
Respondents
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JOINT COUNTER-AFFIDAVIT

The undersigned Respondents unto this honorable office, most respectfully submit
this joint counter-affidavit in response to the instant complaint dated August 28, 2020, thus
further aver for the following:

1. As to all allegations in the subject-complaint, the only thing that Respondents can
admit is the statement on their postal addresses – and the rest are specifically
denied for being baseless and utter lack of merit;

2. This case is a retaliatory scheme to dissuade the Respondents, particularly Oliver

3. Such charges were recommended by NBI in their letter address to the Office of the
Provincial Prosecutor of Cavite dated September 21, 2020 1

4. As of date, the undersigned are just waiting for the Resolution which will start the
formal indictment of the Complainant – the latter, despite being given the chance to
refute the pressed issues against her, did not participate in the preliminary
investigation. This case is docketed as IV-03-INV-20 I – 2827 2 pending with the OPP
– Imus, Cavite with joint Complaint-Affidavit dated July 28, 2020 3 executed by
Respondents O. Galan and Loayon;

1
Annex 1 – NBI’s Recommendation for Prosecution dated September 21, 2020
2
Annex 2 – Investigation Date Form dated September 21, 2020
3
Annex 3 – Complaint-Affidavit of Galan and Loayon dated July 28, 2020

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 5. The truth of the matter is stated thereat – both in Complaint-Affidavit and NBI Initial
Investigation Report/Recommendation, thus, pray that the allegations therein are
adapted in resolving the instant case;

6. Aside from the narratives pleaded thereat, the instant complaint deserves to be
dismissed outright for lack of basis and for being utterly against the normal course of
human behavior;

7. Respondents-O. Galan and Loayon are religious leaders and their respective
ministries, thus, reserve the right to file further charges for perjurious and malicious
filing of this case;

8. On May 26, 2020, contrary to the allegation of the Complainant, the Respondents
were just visiting the former to remind her about the P1,500,000.00 investment made
by the latter (O. Galan and Loayon) in her Blessed World Foundation. The purpose
of the visit is to require the Complainant to return the investment and/or execute a
contractual agreement concerning the same. In fact, a picture 4 of the Complainant
and Respondent-A. Galan seated in the former’s living room;

9. In said picture, plain perusal of the same will show that they are seated comfortably
and have been received in Complainant’s house, thus, trespass to dwelling is a
desperate attempt to retaliate and divert from the investment scam of the
Complainant;

10. The allegation of usurpation of public office by Respondent-Loayon is another

11. Also, said harassment and pretension of PSG and NBI operatives were not duly
reported to the barangay and police which, in the normal course of things, had to be
undertaken if ever such coercion happened;

12. Contrary to the allegation of force in executing the promissory note dated May 26,
2020 – Annex A of herein Complaint, the same was voluntarily executed, as
requested, to prove the investment as the best substitute at that time, of a
contractual agreement for the P1.5 million investment. Said promissory note was
entirely written and signed by the Complainant as witnessed by her lying witness –
Darryl Mahinay and Respondent-A. Galan;

13. To support the allegation of Complainant’s attempt to twist facts concerning the
promissory note, her witness-Mahinay failed to state the same in his Affidavit (Annex
E) dated August 28, 2020. Perjury case is also reserved to be filed against said
witness and Alicia Bravo who also executed a perjurious narratives. Also, this
alleged criminal incident was not reported to the barangay and to the local police,
4
Annex 4 – Picture of Complainant and Respondent A. Galan while in a Meeting on May 26, 2020

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 thus, is baseless as in truth and in fact, it is a product of Complainant’s sinister and
imaginative machinations;

14. The Complainant also denied being indebted to the Respondents. This is lying at its
highest degree because, as mentioned in the Respondents complaint, it was clear as
water that on February 3, 2020, they were lured to invest P1.5 million in exchange of
hefty return as evidence by the initial interest payment represented by the
dishonored Chinabank Check amounting to P500,000.00 dated June 30, 2020;

15. Respondent-Rodriguez, categorically states that the claim that she is the true debtor
of her fellow Respondents is simply not true and baseless as well;

16. Complainant’s daughter was said to have witnessed the coercive behavior of
Respondents in compelling the Complainant to pay or return the investment, but the
same, being unnamed, did not have an affidavit in support of the Complainant’s
allegation because it simply did not happen;

17. The allegation that the Complainant was coerced in receiving demand letter (Annex
B) is again a desperate attempt to be congruent to the allegation of usurpation of NBI
office as they are not true as there is nothing illegal in tendering a demand letter and
nothing illegal per se in NBI’s issuance of subpoena;

18. The complaint of falsification is preposterous claim. Her check (Annex D) was issued
as a guaranty for interest payment by virtue of P1.5 million investment. It is dated
and signed by the Complainant and her attempt to implicate Respondent Rodriguez
is her version of extortion. No evidence was also presented to corroborate this
allegation to prove that said check was formerly endorsed to her;

19. The Complainant, also known as Lilian Pioquinto, together with her husband
Augusto Bola have numerous pending criminal cases with standing warrants for their
arrests. Photocopies (Annex 5-___) of the same are attached for the consideration of
this honorable office to further prove the propensity of the Complainant to
misrepresent as to this case as she has already been indicted several times.

IN WITNESS WHEREOF, we have hereunto affix our hands this 14 th of October 2020 in
Quezon City.

Copy furnished:
Bernadeth S. Bola
Lot 16 Blk 68 Franc Street
North Fairview, Quezon City

OLIVER T. GALAN

ANALIE BALMOCENA-GALAN

MITCHELLE L. LOAYON

JOCELYN RODRIGUEZ

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 Subscribed and sworn to before me this 14 th October 2020 in the Quezon City, by
the affiants, who has satisfactorily proven their Identities to me, that they are the same
person who executed the foregoing joint counter-affidavit before me and acknowledged that
they executed the same voluntarily. I hereby attest that the affiants have fully understood
their affidavit.
Investigating Prosecutor