Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
Branch 15
Cebu City

THE PEOPLE OF THE PHILIPPINES, Crim. Case No. 19834

Plaintiff, For:
VIOLATION OF
-versus- REPUBLIC ACT.9208,
SECTION 4(A), ACTS
THAT PROMOTE
SECTION 5(F)

Marvin Reyes,
Accused.
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - /

JUDICIAL COUNTER AFFIDAVIT

I, MARVIN REYES, Filipino, 22 years old, single and a resident of Brgy.

Labangon, Cebu city, Philippines, after having been duly sworn to in
accordance with law, hereby depose and say:

1. That I am an accused in the above-entitled case filed by ZHIAN

MAPALO;

2. That this Counter Affidavit is taken upon examination of ATTY. YAP

BRIONES at his law office at BRIONES & ASSOCIATES LAW OFFICE,
Melgo Bldg., Sanciangko Street, Cebu City, Philippines, where my
statements were taken;

3. That I am answering the questions asked of me, fully conscious that I

am doing this under oath and that I may face criminal liability for false
testimony or perjury if I state a falsehood in my testimony. The whole
process has been done in Visayan which language/dialect is understood by
me, and translated into English and explained to me;

4. That the following are the questions asked of me and answers that I
gave to the questions:

Pangutana 1 : Unsa ang imong apil-kalabot niining maong kaso?

Tubag 1 : Ako ang akusado niining maong kaso.

[Question 1 : What is your participation in this instant case?

Answer 1 : I am the accused in this present case].
P2: Nakaila ba ka sa reklamante?
T2: Oo sir, kay classmate mi pagelementary .

[Q2: Do you know the accused?

A2: Yes sir, because we are classmate when we are elementary].

P3: Pila naman na katuig nimo nga kaila si ZHIAN MAPALO?

T3: Nakaila ko ni ZHIAN MAPALO mga 14 ka tuig na.

[Q3: How many years have you known ZHIAN MAPALO?

A3: I know ZHIAN MAPALO for about 14 years already.

P4: Masulti ba nimo nganung inosente man ka ani nga kaso?.

T4: Oo, kay ako usa ka boutan nga taw, dili nako na mabuhat niya ug sa
laing taw. Ako pa gani siya gitabangan pagpangita og trabaho didto sa
London.

[Q4: Can you tell why are you innocent in this case?
A4: Yes, because I am a good person, I cannot do that to her or to
any person. In fact, I helped her to get a job in London].

P5: Unsa man ang mga nahitabo pagka Oktobre 08, 2022 sa alas 10 sa
buntag?
T5: Pagka Oktubre 08, 2022 sa alas 10 sa buntag kauban nako akong amego
kay amo apason iyang asawa para eh surpresa kay maka larga na kini sa
London ug naka huna huna kami nga eh prank siya pina agi sa pag ilad nga
ako siya gi baligya sakong amego.

[Q5: What happen on October 08, 2022 around 10:00 am?

A5: .] On October 08, 2022 about 10:00 am I was driving my car
together with my best friend we will pick up his wife and surprise
her because she can now go to London for work but we decided to
prank her by telling her that I sell her to my other friends.

P6: Unsa may sunod nga panghitabo?

T6; Pag tion nako sa duwaan nga pusil ni Joan Sarco ug gi sultian nako siya
nga sakay aris kotse kay ako kang gibaligya sa akong amego pirti na niyang
hilak ug pag sulod niya sa kotse didto na nag pakita iyang bana ug gi sultian
nga prank ra to.

[Q6: What happened next?

A6: As I point the toy gun to Joan Sarco and tell her that I sold
her to my friend and let her in to the car she stared crying. When
she is inside the car her husband tell her that it is all just a prank.

P7: Ug kato tanan kay buhat-buhat ni Zhian Mapalo, unsa man ang rason
nganu buhaton na niya?
T7: Kay kana si Zhian Mapalo naay pag suko kanako kay ni adtong ni aging
tuig wala nako natabangan iyang asawa sa pag panarbahu sa abroad kay
iyang asawa daghan ug kuwang nga dokumento. Gusto niya pangitaan nakog
paagi nga naka larga siya pero wako buhata kay maka daot nas akong
pangan ug dakog posibilidad nga ma preso ko.

[Q7: If all of those accusations are fabricated by Zhian Mapalo,

what is his reason on doing such things?
A7: Because Zhian Mapalo is angry to me because last year I did
not help her wife to work to abroad beacause his wife is lacking of
documents. But he said that I will find a way to let his wife go to
abroad but I didn’t do it because it can affect my reputation and
it maybe cost to go to jail.]

P8 : Kaila baka sa nagpusas nimo?

T8 : Pag una wala pa , pero nag paila na siya sa pag basa niya sa Miranda
rights na siya si PCpl. Matt J. Bato.

[Q8 : Do you know the person who handcuffed you?

A8 : In first I don’t know him but he introduced himself as
PCpl. Matt J. Bato by informing me my Miranda rights.

P9 : Nangutana baka unsay sala nimo sa nagdakop kanimo?

T9 : Oo. Ni sulti sya nga akong nabuhat kay Trafficking in person.

[Q9: Do you ask why did they arrest you ?

A9 : Yes, they say that I committed a crime Trafficking in person.

P10 : Sa unsa nga pinulungan gihimo ang pag-susi o pagpangutana sa

piskal kalabot sa hitabo diin ikaw ang biktima?
T10 : Pinulungang Bisaya.

[Q10 : In what language were you asked by the fiscal in relation

to the incident where you are the victim?
A10 : In the Visayan language].

P11 : Kining imong affidavit o salaysay sinuwat sa English, nakasabot ba

ikaw niini?
T11 : Ang piskal misulti kanako nga ilang hubaron sa pinulungan English
ug unsay akong naestorya kanila panahon sa imbestigasyon unya ila akong
gipapirma tungod kay dinalian ang pagfile dinhi sa Cebu City.

[Q11: You affidavit is in English, did you understand it?

A11 : The fiscal told me that they translated what I said to
English and let me sign the affidavit which I signed because it
would be filed here in Cebu City.]
P12: Ang mga pamahayag ba nga nasuwat niing maong affidavit o
pamahayag tinuod ug sakto kini?
T12 : Oo, Sakto kini

[Q12: Are the statements contained in the affidavit true and correct?
A12 : Yes, It is correct.

P13 : Akong isukip kining imong affidavit nga imong gipirmahan

atubangan sa Piskal sa Cebu City, isip ANNEX “A”, uyon ba ikaw sa akong
buhaton?
T13 : Oo, uyon ako.

[Q13 : I wish to attach your affidavit signed before the Fiscal of

Cebu City, as ANNEX “A” to your judicial affidavit, will
you conform to my action?
A13 : Yes, I conform.

P14 : Pagkakaron, wala na akoy ipangutana nimo, naa pa ba kay ikadungag?

T14 : Wala na, gawas kong aduna pay laing mga pangutana,

[Q14 : As of now, I have no more questions to ask, do you still wish to add
more?
A14 : No more, except if there are still questions.

IN WITNESS WHEREOF, I have hereunto set my hand this day of 15th of

October 2022, at Cebu City, Philippines

MARVIN REYES
AFFIANT

SUBSCRIBED AND SWORN to before me this 15 th day of October 2022,

at Cebu City, Philippines

ATTESTATION

I, Attorney Shane Phillip Ballesteros., after having been sworn to in

accordance with the law, do hereby depose and say, thus:
1. That I have faithfully recorded or caused to be recorded the questions I
asked and the corresponding answers that the accused Marvin Reyes gave;
2. That I, nor any other person present or assisting, coached the witness
regarding the witness’ answers; and
3. That I fully understand that any false attestation shall subject me to
disciplinary action, including disbarment.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 19th

day of September 2021, at Cebu city, Philippines.

Atty. SHANE PHILLIP BALLESTEROS

Counsel of the State

SUBSCRIBED AND SWORN to before me this 15th day of October 2021,

at Cebu City, Philippines
 ANNEX “A”
Republic of the Philippines)
Cebu City ) S.S.

COUNTER AFFIDAVIT

I, Marvin Reyes, Filipino, 22 years old, single and a resident of Brgy.

Labangon, Cebu city, Philippines, after having been duly sworn to in
accordance with law, hereby depose and say:

1.That I am an accused in the above-entitled case filed by Zhian Mapalo;

2. I vehemently deny under oath the Complaint Affidavit of Zhian

Mapalo for being false and fabricated. The truths of the matter is hereby
stated hereunder;

3. That on October 08, 2022 about 10:00 am I was driving my car

together with my best friend we will pick up his wife and surprise her
because she can now go to London for work but we decided to prank her by
telling her that I sell her to my other friends;

4. As I point the toy gun to Joan Sarco and tell her that I sold her to my
friend and let her in to the car she stared crying. When she is inside the car
her husband tell her that it is all just a prank.

5. Because Zhian Mapalo is angry to me because last year I did not help
her wife to work to abroad beacause his wife is lacking of documents. But he
said that I will find a way to let his wife go to abroad but I didn’t do it
because it can affect my reputation and it maybe cost to go to jail.

6. Furthermost, the complaint is uncorroborated and clearly fabricated for

it is not corresponded to the facts that really exist;

7. The complaint was brought only for the purpose of shamming,

harassing, degrading and humiliating me;

8. That I execute this affidavit to attest to the truth of the foregoing case.

IN WITNESS WHEREOF, I have hereunto set my hand this day of 15th of

October 2022, at Cebu City, Philippines

Marvin Reyes
 AFFIANT

SUBSCRIBED AND SWORN to before me this 15 th day of October 2022,

at Cebu City, Philippines

ATTESTATION

I, Attorney Shane Phillip Ballesteros, after having been sworn to in

accordance with the law, do hereby depose and say, thus:
1. That I have faithfully recorded or caused to be recorded the questions I
asked and the corresponding answers that the accused Zhian Mapalo gave;
2. That I, nor any other person present or assisting, coached the witness
regarding the witness’ answers; and
3. That I fully understand that any false attestation shall subject me to
disciplinary action, including disbarment.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 15th

of October 2022, at Cebu city, Philippines.

SHANE PHILLIP BALLESTEROS

Counsel of the State

SUBSCRIBED AND SWORN to before me this 15th of October 2022, at

Cebu City, Philippines
 Republic of the Philippines
REGIONAL TRIAL COURT
7th Judicial Region
Branch 15
Cebu City

THE PEOPLE OF THE PHILIPPINES, Crim. Case No. 19834

Plaintiff, For:
VIOLATION OF
-versus- REPUBLIC ACT.9208,
SECTION 4(A), ACTS
THAT PROMOTE
SECTION 5(F)

MARVIN REYES,
Accused.
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - /

JUDICIAL COUNTER AFFIDAVIT

I, PAUL ENAD, 22 years old, single, resident of Brgy. Labangon, Cebu

city Philippines, friend of the accused, after having been sworn to according
to law hereby depose and say:

1.That I declare that the allegations of Zhian Mapalo in his affidavit

particularly the statements charging Marvin Reyes for the crime of human
trafficking are false and fabricated; That the truth of the matter is hereby
stated hereunder;

2.That this Judicial Affidavit is taken upon examination of ATTY.

YAP BRIONES at his law office at BRIONES & ASSOCIATES LAW
OFFICE, Melgo Bldg., Sanciangko Street, Cebu City, Philippines, where my
statements were taken;

3.That I am answering the questions asked of me, fully conscious that

I am doing this under oath and that I may face criminal liability for false
testimony or perjury if I state a falsehood in my testimony. The whole
process has been done in Visayan which language is understood by me, and
translated into English and explained to me;

4.That the following are the questions asked of me and answers that I
gave to the questions:

Pangtuna 1: Unsa ang imong apil-kalabot niining maong kaso?

Tubag 1: usa ako sa naka saksi sa panghitabo ani nga kaso.
 [Question 1: What is your participation in this instant case?
Answer 1: I am one of the witnesses of the happening in this case].

P2: Nakaila ba ka sa akusado aning maong kaso?

T2: Oo sir, kay ako kauban niya atong adlawa ug orasa

[Q2: Do you know the accused t this case?

A2: Yes Sir, because I’m with him in that exact day and time

P3: Nakaila ba ka sa reklamante?

T3: Naka ila ako kay mao kini ag bana sa babae nga wala tabangi nga maka
abroad sa akong amego nga si Marvin ug schoolmate pud mi sauna

[Q3: Do you know the complainant?

A3: Yes, because he is the husband of the girl that my friend
Marvin didn’t help her to work abroad and hes is also my
schoolmate

P4: Pila naman na katuig nimo nga kaila si Zhian Mapalo?

T4: Mga 10 years na

[Q4: How many years have you known Zhian Mapalo?

A4: I think it is almost 10 years.

P5: Masulti ba nimo nganung inosente man si Marvin Reyes.

T5: Oo, kay kadto iyang gi buhat sa ahung asawa kay prank raman to amo ra
gi ilad akong asawa nga gi baligya sa lain

[Q5: Can you tell why Marvin Reyes was inosent?

A5: Yes, Because all he did was a prank and it was plan by us to
prank my wife.

P6: Unsa man ang mga nahitabo pag Oktobre 08, 2022 alas 10 sa buntag?
T6: Pag Oktobre 08, 2022 alas 10 sa buntag nag uban mi ni Marvin Reyes
amo sundoun akong asawa ug naka hunahuna kami nga eh prank ug eh
surprise akong asawa kay maka abroad na siya

[Q6: What happen when on October 08, 2022 around 10:00 am?
A6: On October 08, 2022 around 10:00 am we were about to
pickup my wife then we plan to surprise and prank her because
she can go work to abroad.

P7: Unsa may sunod nga panghitabo?

T7: Pag tion ni Marvin Reyes sa duwaan nga pusil ngadto sa akong asawa
ug gi sultian niya nga siya mo sakay aris kotse kay iyang gibaligya akong
asawa sa amego pirti na niyang hilak ug pag sulod niya sa kotse didto na ko
nag pakita ug gi sultian nga prank ra to.
 [Q7: What happened next?
A7: As Marvin Reyes point the toy gun to my wife Joan Sarco and
tell her that he sold her to my friend and let her in to the car she
stared crying. When she is inside the car I showed up and tell her
that it is all just a prank.

P8: Ug kato tanan kay buhat-buhat ni Zhian Mapalo, unsa man ang rason
nganu buhaton na niya?
T8: Kay na estorya na ni Marvin Reyes nako nga kanang asawa ni Zhian
Mapalo wala niya na tabangi sa pag abroad.

[Q8: If all of those accusations are fabricated by Zhian Mapalo,

what is her reason on doing such things?
A8: Because Marvin Reyes once told me that he didn’t help the
wife of Zhian Mapalo to work abroad.

P9 : Sa unsa nga pinulungan gihimo ang pag-susi o pagpangutana sa piskal

kalabot sa hitabo diin ikaw ang biktima?
T9 : Pinulungang Bisaya.

[Q9 : In what language were you asked by the fiscal in relation

to the incident where you are the victim?
A9 : In the Visayan language].

P10 : Kining imong affidavit o salaysay sinuwat sa English, nakasabot ba

ikaw niini?
T10 : Ang piskal misulti kanako nga ilang hubaron sa pinulungan English
ug unsay akong naestorya kanila panahon sa imbestigasyon unya ila akong
gipapirma tungod kay dinalian ang pagfile dinhi sa Cebu City.

[Q10 : Your affidavit is in English, did you understand it?

A10 : The fiscal told me that they translated what I said to
English and let me sign the affidavit which I signed because it
would be filed here in Cebu City.

P11 : Ang mga pamahayag ba nga nasuwat niining maong affidavit o

pamahayag tinuod ug sakto kini?
T11 : Oo, Sakto kini

[Q11 : Are the statements contained in the affidavit true and

correct?
A11 : Yes, It is correct.

P12 : akung isukip kining maong marriage certificate ninyu ni Joan Sarco,
isip Annex “B”, uyon ba ikaw sa akong buhaton?
T12 : Oo, uyon ako.
 [Q11 : I wish to attach your marriage certificate as Annex “B”, will
you conform?
A12 : Yes, I conform].

P12 : Akong isukip kining imong affidavit nga imong gipirmahan

atubangan sa Piskal sa Cebu City, isip ANNEX “C”, uyon ba ikaw sa akong
buhaton?
T12 : Oo, uyon ako.

[Q12 : I wish to attach your affidavit signed before the Fiscal of

Guadalupe, Cebu, as ANNEX “C” to your judicial
affidavit, will you conform to my action?
A12 : Yes, I conform].

P13: Pagkakaron, wala na akoy ipangutana nimo, naa pa ba kay ikadungag?

T13: Wala na, gawas kong aduna pay laing mga pangutana,

[Q13 : As of now, I have no more questions to ask, do you still

wish to add more?
A13 : No more, except if there are still questions.

IN WITNESS WHEREOF, I have hereunto set my hand this day of 15th of

October 2022, at Cebu City, Philippines

PAUL ENAD
AFFIANT

SUBSCRIBED AND SWORN to before me this 15 th day of October 2022,

at Cebu City, Philippines

ATTESTATION

I, Attorney Shane Phillip Ballesteros, after having been sworn to in

accordance with the law, do hereby depose and say, thus:
1. That I have faithfully recorded or caused to be recorded the questions I
asked and the corresponding answers that the accused Marvin Reyes gave;
2. That I, nor any other person present or assisting, coached the witness
regarding the witness’ answers; and
3. That I fully understand that any false attestation shall subject me to
disciplinary action, including disbarment.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 15th
of October 2022, at Cebu city, Philippines.

Atty. SHANE PHILLIP BALLESTEROS

Counsel of the State

SUBSCRIBED AND SWORN to before me this 15th of October 2022, at

Cebu City, Philippines
 ANNEX “C”
Republic of the Philippines)
Cebu City ) S.S.

COUNTER AFFIDAVIT

I, PAUL ENAD, 22 years old, single, resident of Brgy. GUADALUPE,

Cebu city, a closed friend of the accused, after having been sworn to
according to law hereby depose and say:

1. That I declare that the allegations of ZHIAN MAPALO in his affidavit

particularly the statements charging MARVIN REYES for the crime of
human trafficking are false and fabricated; That the truth of the matter is
hereby stated hereunder:

2. That I personally know Marvin Reyes and he is a very good person. He is

a very good friend and a very helping person.

3. That my friend Marvin Reyes didn’t do anything wrong because all we

did is just a prank for my wife Joan Sarco

4. That on On October 08, 2022 around 10:00 am we were about to pickup

my wife then we plan to surprise and prank her because she can go work to
abroad.

5. That Marvin Reyes point the toy gun to my wife Joan Sarco and tell her
that he sold her to my friend and let her in to the car she stared crying. When
she is inside the car I showed up and tell her that it is all just a prank.

6. That she is only making a false story against Marvin Reyes because he
wants revenge for his wife.

7. That I execute this affidavit to attest to the truth of the foregoing case.

IN WITNESS WHEREOF, I have hereunto set my hand this day of 15th of

October 2022, at Cebu City, Philippines

PAUL ENAD
AFFIANT

SUBSCRIBED AND SWORN to before me this 15 th day of October 2022,

at Cebu City, Philippines
 ATTESTATION

I, Attorney Shane Phillip Ballesteros, after having been sworn to in

accordance with the law, do hereby depose and say, thus:
1. That I have faithfully recorded or caused to be recorded the questions I
asked and the corresponding answers that the accused Marvin Reyes gave;
2. That I, nor any other person present or assisting, coached the witness
regarding the witness’ answers; and
3. That I fully understand that any false attestation shall subject me to
disciplinary action, including disbarment.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 15th

of October 2022, at Cebu city, Philippines.

Atty. Shane Phillip Ballesteros

Counsel of the State

SUBSCRIBED AND SWORN to before me this 15th of October 2022, at

Cebu City, Philippines
Annex “B”
 Republic of the Philippines
REGIONAL TRIAL COURT
7th Judicial Region
Branch 15
Cebu City

THE PEOPLE OF THE PHILIPPINES, Crim. Case No. 19834

Plaintiff, For:
VIOLATION OF
-versus- REPUBLIC ACT.9208,
SECTION 4(A), ACTS
THAT PROMOTE
SECTION 5(F)

RAMON D. MONDRAGON,
Accused.
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - /

JUDICIAL COUNTER AFFIDAVIT

I, Joan Sarco, 22 years old, married, resident of Brgy. Guadalupe, Cebu

city, after having been sworn to according to law hereby depose and say:

1. That I declare that the allegations of Zhian Mapalo in his affidavit

particularly the statements charging Marvin Reyes for the crime of human
trafficking are false and fabricated; That the truth of the matter is hereby
stated hereunder;

2.That this Judicial Affidavit is taken upon examination of ATTY.

YAP BRIONES at his law office at BRIONES & ASSOCIATES LAW
OFFICE, Melgo Bldg., Sanciangko Street, Cebu City, Philippines, where my
statements were taken;

3.That I am answering the questions asked of me, fully conscious that

I am doing this under oath and that I may face criminal liability for false
testimony or perjury if I state a falsehood in my testimony. The whole
process has been done in Visayan which language is understood by me, and
translated into English and explained to me;

4.That the following are the questions asked of me and answers that I
gave to the questions:

Pangtuna 1: Unsa ang imong apil-kalabot niining maong kaso?

Tubag 1: Ako ang gi ingun nila nga biktima pero dili kini tinoud kay gi
prank rako

[Question 1: What is your participation in this instant case?

 Answer 1: I am the on that they said as victim but it is not true
because it is all a prank..
P2: Nakaila ba ka sa akusado aning maong kaso?
T2: Oo, kay siya mao ang tag iya sa job recruitment agency nga akong gi
applayan

[Q2: Do you know the accused t this case?

A2: Yesz because he is the owner of the job recruitment agency
that I’m applying.

P3: Nakaila ba ka sa reklamante?

T3: wala sir

[Q3: Do you know the complainant?

A3: No I don’t know him.

P4: Masulti ba nimo nganung inosente man si Marvin Reyes.

T4: Oo, kay prank raman tong ilang gi buhat nako nag sabot sila sa akong
bana nga eh prank ko.

[Q4: Can you tell why Marvin Reyes was inosent?

A4: Of course yes, because it is all a prank and they plan it
together with mu husband.

P5: Unsa man ang mga nahitabo pag Oktobre 08, 2022 sa alas 10:00 sa
buntag?
T5: Pag Oktobre 08, 2022 sa alas 10:00 sa buntag nag paabot kos akong
bana kay iya kung sundoun pero ag ni abot kay si Marvin Reyes unya iya
kung gi tutukan ug pusil unya gi ingnan ko ug ibaligya koa iyang amego ug
gi pasulod kos kotse pero diay duwaan ra ang pusil ug prank ra diay to unya
nag pakita akong asawa ingna ko ug prank ra diay.

[Q6: What happen on October 08, 2022 around 10:00 am?

A6: On October 08,2022 around 10:00 am I was waiting for my

husband to pick me up but instead Marvin Reyes arrived with a
car and point a gun to me and said get in the car because he will
sell me to his friend but after I enter the car my husband showed
up and said it is all just a prank and the gun is just a toy.

P7: Unsa may sunod nga panghitabo?

T7: Ug mao to naay ni abot pulis kay naa diay ni tawag sa kapulisan nga
naay nahitabong trafficking in person pero gi ingna ni Marvin Reyes nga
prank ra pero wala namati ang kapulisan kay diay ang maong pulis amego
kaayu ni Zhian Mapalo.
 [Q7: What happened next?
A7: So the police arrived and arrest Marvin Reyes, but Marvin
Reyes said that it is all a prank but the police did not listen to us
because we know that the arresting Police officer is the best friend
of Zhian Mapalo.

P8 : Sa unsa nga pinulungan gihimo ang pag-susi o pagpangutana sa piskal

kalabot sa hitabo diin ikaw ang biktima?
T8 : Pinulungang Bisaya.

[Q8 : In what language were you asked by the fiscal in relation

to the incident where you are the victim?
A8 : In the Visayan language].

P9 : Kining imong affidavit o salaysay sinuwat sa English, nakasabot ba

ikaw niini?
T9 : Ang piskal misulti kanako nga ilang hubaron sa pinulungan English ug
unsay akong naestorya kanila panahon sa imbestigasyon unya ila akong
gipapirma tungod kay dinalian ang pagfile dinhi sa Cebu City.

[Q9 : Your affidavit is in English, did you understand it?

A9 : The fiscal told me that they translated what I said to
English and let me sign the affidavit which I signed because it
would be filed here in Cebu City.

P10 : Ang mga pamahayag ba nga nasuwat niining maong affidavit o

pamahayag tinuod ug sakto kini?
T10 : Oo, Sakto kini

[Q10 : Are the statements contained in the affidavit true and

correct?
A10 : Yes, It is correct.

P11: Akong isukip kining imong affidavit nga imong gipirmahan atubangan
sa Piskal sa Cebu City, isip ANNEX “C”, uyon ba ikaw sa akong buhaton?
T11 : Oo, uyon ako.

[Q11 : I wish to attach your affidavit signed before the Fiscal of

Cebu city, as ANNEX “C” to your judicial affidavit, will
you conform to my action?
A11 : Yes, I conform].

P12: Pagkakaron, wala na akoy ipangutana nimo, naa pa ba kay ikadungag?

T12: Wala na, gawas kong aduna pay laing mga pangutana,
 [Q12 : As of now, I have no more questions to ask, do you still
wish to add more?
A12 : No more, except if there are still questions.

IN WITNESS WHEREOF, I have hereunto set my hand this day of 15th of

October 2022, at Cebu City, Philippines

JOAN SARCO
AFFIANT

SUBSCRIBED AND SWORN to before me this 15 th day of October 2022,

at Cebu City, Philippines

ATTESTATION

I, Attorney Shane Phillip Ballesteros, after having been sworn to in

accordance with the law, do hereby depose and say, thus:
1. That I have faithfully recorded or caused to be recorded the questions I
asked and the corresponding answers that the witness gaved Joan Sarco
gave;
2. That I, nor any other person present or assisting, coached the witness
regarding the witness’ answers; and
3. That I fully understand that any false attestation shall subject me to
disciplinary action, including disbarment.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 15th

of October 2022, at Cebu city, Philippines.

Atty. SHANE PHILLIP BALLESTEROS

Counsel of the State

SUBSCRIBED AND SWORN to before me this 15th of October 2022, at

Cebu City, Philippines
 ANNEX “C”
Republic of the Philippines)
Cebu City ) S.S.

COUNTER AFFIDAVIT

I, JOAN SARCO, 22 years old, married, resident of Brgy. Labangon, Cebu

city, after having been sworn to according to law hereby depose and say:

1. That I declare that the allegations of Zhian Mapalo in his affidavit

particularly the statements charging Marvin Reyes for the crime of human
trafficking are false and fabricated; That the truth of the matter is hereby
stated hereunder:

2. That Marvin Reyes is just doing a prank when he point a gun ang said to
me that he will sell me to hes friend.

3. Zhian Mapalo was only fabricating the story for he was angry at Marvin
Reyes in refusing to help his wife to work abroad.

4. That I execute this affidavit to attest to the truth of the foregoing case.

IN WITNESS WHEREOF, I have hereunto set my hand this day of 15th of

October 2022, at Cebu City, Philippines

Joan Sarco
AFFIANT

SUBSCRIBED AND SWORN to before me this 15 th day of October 2022,

at Cebu City, Philippines

ATTESTATION

I, Attorney Shane Phillip Ballesteros., after having been sworn to in

accordance with the law, do hereby depose and say, thus:
1. That I have faithfully recorded or caused to be recorded the questions I
asked and the corresponding answers that the accused Marvin Reyes gave;
2. That I, nor any other person present or assisting, coached the witness
regarding the witness’ answers; and
3. That I fully understand that any false attestation shall subject me to
disciplinary action, including disbarment.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 15th
of October 2022, at Cebu city, Philippines.

Atty. SHANE PHILLIP BALLESTEROS

Counsel of the State

SUBSCRIBED AND SWORN to before me this 15th of October 2022, at

Cebu City, Philippines