Republic of the Philippines)

City of Iloilo
)SS
x------------------------------x
JUDICIAL COMPLAINT AFFIDAVIT
OF STEPHANY P. SANTISTEBAN
I, STEPHANY P. SANTISTEBAN, of legal age, married and a resident
of Brgy. Potatan, Iloilo, Philippines after having been sworn to in accordance
with law, do hereby depose and state:

PRELIMINARY STATEMENT
ATTY. JOSELITO AZARRAGA IV , Private Prosecutor, Room
199 M&J Building, Lapaz, Iloilo City is conducting this direct examination in
his office.
ATTY. JOSELITO AZARRAGA IVis conducting direct examination in
English which he also translates in Hiligaynon, the local dialect understood and
spoken by herein affiant. I, STEPHANY P. SANTISTEBAN answers the
questions in Hiligaynon and my answers are translated by Atty. Mary Joy S.
Dejada in English;
I am answering the questions asked of me by Atty. Azarraga, fully
conscious that I do so under oath. I am also aware that I may face criminal
liability for false testimony or perjury;

(QUESTIONS AND ANSWERS)

QUESTION:

Please state your name, address and other personal

circumstances?

ANSWER:

I am Stephany Santisteban, of legal age, married,

resident of Brgy. Igang, Pototan, Iloilo.

QUESTION:

What is your present occupation madam?

ANSWER:

I am the incumbent municipal mayor of the

Municipality of Pototan.

QUESTION:

How long have you been in public service?

ANSWER:

I was elected as a Board Member of the 3rd District of

Iloilo for three terms and I am presently the Municipal
Mayor of Pototan, Iloilo, so for almost 11 years
already.

QUESTION:

What motivated you to institute this present action for

libel?

ANSWER:

I received a letter last August 9, 2014 which contains

damaging accusations against me.

QUESTION:

Can you elaborate the contents of that letter which

you received?

ANSWER:

It contains false accusations, malicious imputations

which tends to cause dishonour and discredit
pertaining to my person and to my functions. The
letter was so humiliating and malicious since the letter
contains an accusation against me and my
administration that I have authorized the harassment
and murder of street children in the Municipality of
Pototan for which are all untrue and no basis at all.

QUESTION:

From whom did this letter come from?

ANSWER:

Gordon Guillergan sir.

QUESTION:

Do you know this Gordon Guillergan?

ANSWER:

Yes, I do.

QUESTION:

How do you know Mr. Guillergan?

ANSWER:

He is the son of my previous opponent for mayoralty

in the last election for the Municipality of Pototan.

QUESTION:

Have you personally met this person you are referring

to?

ANSWER:

Yes sir.

QUESTION:

May we know the number of times you met Gordon

Guillergan?

ANSWER:

I met him on several occasions before.

QUESTION:

What occasions?

ANSWER:

He was introduced to me during the campaign period

and we bumped into each other afterwards and say our
hellos.

QUESTION:

Did anyone else read this letter?

ANSWER:

Yes sir.

QUESTION:

May we know who else read this letter?

ANSWER:

My Public Affairs Consultant sir.

QUESTION:

Who is this Public affairs consultant madam?

ANSWER:

Her name is Hazel Simpas sir.

QUESTION:

Showing to the letter, is this the same letter you are

referring to?

ANSWER:

Yes sir. ( EXHIBIT A)

QUESTION:

What happened next?

ANSWER:

After one month from the receipt of the malicious

letter, I was again surprised to read in the newspaper
the same malicious and false accusations made by the
same person against me.

QUESTION:

What newspaper are you referring to?

ANSWER:

The Philippine Star.

QUESTION:

May we know what particular page or section of the

newspaper that you are referring to?

ANSWER:

It was contained in page four (4) sir.

QUESTION:

Showing you the newspaper, is this the same

newspaper you are referring to?

ANSWER:

Yes sir. (EXHIBIT B)

QUESTION:

What did you do next?

ANSWER:

I asked my Public Affairs consultant to check the

facebook page that the Municipality of Pototan
maintains and operate.

QUESTION:

What is this facebook page pertaining to?

ANSWER:

It pertains to matters of projects and implementations

thereof and to other pertinent matters in connection
with the Municipality of Pototan.

QUESTION:

What was the purpose of you directing the Public

Affairs consultant to check the facebook page?

ANSWER:

To check the sentiments of the members who are

mostly constituents of Pototan,

QUESTION:

So what did you find out?

ANSWER:

I was shocked and humiliated by the negative

comments and responses by the members against me

because of the publication made by Gordon

Guillergan regarding the untrue, malicious and
baseless accusations which was so damaging to my
reputation.
QUESTION:

Showing you the Facebook page print out, is this the

same print out you are referring to?

ANSWER:

Yes sir. (EXHIBIT C)

QUESTION:

Is there some other forms of malicious imputations

made by Mr. Guillergan?

ANSWER:

Yes sir.

QUESTION:

May we know what else?

ANSWER:

There was also this blog site which my Public Affairs

consultant showed me where the same malicious
imputations were made against me.

QUESTION:

What particular Blog site madam?

ANSWER:

The internet website of RSAP, at http://www.rsap.org/

QUESTION:

May we know the contents of the blog site which you

are referring to?

ANSWER:

It contains almost similar or the same imputations

thus exhibiting personal ill-will, spite and/or malice
with the object of destroying my reputation and
discrediting and ridiculing me as a public official
before the bar of public opinion and contempt

QUESTION:

Showing you the print out of the blog site, is this the
same blog site you are referring to?

ANSWER:

Yes sir. ( EXHIBIT D)

QUESTION:

Do you have any idea what is motivating Gordon in

doing this?

ANSWER:

Yes.

QUESTION:

How so?

ANSWER:

Politically motivated, as his father was my opponent

in the last election where I subsequently won.

QUESTION:

What do you want this Honorable Court to do now?

ANSWER:

I would like this Honorable Court to render judgment

in my favor and for this Honorable Court to award
Moral and exemplary damage in my favour for the
sleepness nights, besmirched reputation and for the
wanton malice in his actions.

QUESTION:

Please read this affidavit madam and please tell me if

you find any errors in your given testimony?

ANSWER:

None sir.

That I am executing this Judicial complaint Affidavit to attest to the

truthfulness of the foregoing facts and for the purpose of filing criminal charges
of LIBEL against GORDON GUILLERGAN, who are of legal age, both are
single and a resident of Brgy. Arguilles Street, Jaro Iloilo City.
IN WITNESS WHEREOF, I have hereinto affixed my signature this ___
day of June 2014 at the City of Iloilo, Philippines.

STEPHANY P. SANTISTEBAN
Affiant
SUBSCRIBED AND SWORN to before me this ____day of June 2014 at
the City of Iloilo, Philippines, I hereby certify that I have personally examined
and fully understood the statements of her Judicial Affidavit.

SWORN ATTESTATION OF LAWYER

I, Atty. Joselito Azarraga IV, am the lawyer who conducted the direct
examination of the witness Kathryn A. Tormon. I faithfully recorded questions I
asked and the corresponding answers that the affiant gave. Neither I nor any
other person then present or assisting me coached Kathryn A. Tormon regarding
her answers.

SUBBSCRIBED AND SWORN to before me this ____ day of June 2014

in the City of Iloilo, Philippines.