Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
Tagum City

CECILE F. GARCE, DENNIS KEN LACIA, NPS DOCKET NO.

HAZEL MATE FUENTES, KENNETH M. PALBRICA, XI-09-INV-19F-00254
& CHRISTIAN JON LO URDANETA,
Complainants,
-versus- For: SYNDICATED/LARGE
SCALE ESTAFA
RYAN JOHNSKYLE MAUNES,
ANNABELLE P. LALUNA, FRANCIES ELOISE LALUNA,
MARK MICULOB, CHRISTOPHER PULMONES,
JHUNAIDE UTTO ASARI, CIELO RAMOS, &
GINO MANLA OR MANILA,
Respondents.
x---------------------------------------------------------------------------------------------------------x

COUNTER-AFFIDAVIT

COMES NOW the respondent ANNABELLE P. LALUNA unto the

Honorable Office, most respectfully alleges:
1. That I am the same ANNABELLE P. LALUNA who is one of the
respondents in NPS Docket No. XI-09-INV-19F-00254 for Violation of
ARTICLE 315 in relation to ARTICLE 316 (SYNDICATED/LARGE SCALE ESTAFA),
which is now pending before the office of the City Prosecution, Tagum
City;
2. That in compliance with the notification dated June 28, 2019 and
received by the respondent on July 11, 2019, I hereby respectfully submit
this counter-affidavit;
3. That I vigorously and vehemently deny all the material allegations
contained in the affidavit complaints of CECILE GARCE, DENNIS KEN
LACIA, HAZEL MAYE FUENTES, KENNETH MONTERO PALABRICA, and
CHRISTAN JON LO URDANETA, the same were all product of falsehood and
deserve no consideration but prompt dismissal;
4. That the truth of the matter is that all the allegations contained in
the affidavit of the complainant are baseless. It is however wise to
consider the following facts, to wit:
 In the light of the foregoing, it respectfully prayed that the above
case be dismissed for lack of merit. Such other relief is likewise prayed for.

Kidapawan City, Philippines.

ANNABELLE P. LALUNA
(Affiant)

SUBCRIBED AND SWORN TO BEFORE ME, this

, at Kidapawan City, Philippines. I further certify that I have
personally examined the affiant and that he has read and understand the
contents of his counter-affidavit, executed by him freely by him and
voluntarily.
 Republic of the Philippines
DEPARTMENT OF JUSTICE
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
Tagum City

CECILE F. GARCE, DENNIS KEN LACIA, NPS DOCKET NO.

HAZEL MATE FUENTES, KENNETH M. PALBRICA, XI-09-INV-19F-00254
& CHRISTIAN JON LO URDANETA,
Complainants,
-versus- For: SYNDICATED/LARGE
SCALE ESTAFA
RYAN JOHNSKYLE MAUNES,
ANNABELLE P. LALUNA, FRANCIES ELOISE LALUNA,
MARK MICULOB, CHRISTOPHER PULMONES,
JHUNAIDE UTTO ASARI, CIELO RAMOS, &
GINO MANLA OR MANILA,
Respondents.
x---------------------------------------------------------------------------------------------------------x

COUNTER-AFFIDAVIT

COMES NOW the respondent MARK MICULOB unto the Honorable

Office, most respectfully alleges:
1. That I am the same MARK MICULOB who is one of the respondents
in NPS Docket No. XI-09-INV-19F-00254 for Violation of ARTICLE 315 in
relation to ARTICLE 316 (SYNDICATED/LARGE SCALE ESTAFA), which is now
pending before the office of the City Prosecution, Tagum City;
2. That in compliance with the notification dated June 28, 2019 and
received by the respondent on July 15, 2019, I hereby respectfully submit
this counter-affidavit;
3. That I vigorously and vehemently deny all the material allegations
contained in the affidavit complaints of CECILE GARCE, DENNIS KEN
LACIA, HAZEL MAYE FUENTES, KENNETH MONTERO PALABRICA, and
CHRISTAN JON LO URDANETA, the same were all product of falsehood and
deserve no consideration but prompt dismissal;
4. That the truth of the matter is that all the allegations contained in
the affidavit of the complainant are baseless. It is however wise to
consider the following facts, to wit:
In the light of the foregoing, it respectfully prayed that the above
case be dismissed for lack of merit. Such other relief is likewise prayed for.
 Kidapawan City, Philippines.

MARK MICULOB
(Affiant)

SUBCRIBED AND SWORN TO BEFORE ME, this

, at Kidapawan City, Philippines. I further certify that I have
personally examined the affiant and that he has read and understand the
contents of his counter-affidavit, executed by him freely by him and
voluntarily.
 Republic of the Philippines
DEPARTMENT OF JUSTICE
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
Tagum City

CECILE F. GARCE, DENNIS KEN LACIA, NPS DOCKET NO.

HAZEL MATE FUENTES, KENNETH M. PALBRICA, XI-09-INV-19F-00254
& CHRISTIAN JON LO URDANETA,
Complainants,
-versus- For: SYNDICATED/LARGE
SCALE ESTAFA
RYAN JOHNSKYLE MAUNES,
ANNABELLE P. LALUNA, FRANCIES ELOISE LALUNA,
MARK MICULOB, CHRISTOPHER PULMONES,
JHUNAIDE UTTO ASARI, CIELO RAMOS, &
GINO MANLA OR MANILA,
Respondents.
x---------------------------------------------------------------------------------------------------------x

COUNTER-AFFIDAVIT

COMES NOW the respondent JHUNAIDE UTTO ASARI unto the

Honorable Office, most respectfully alleges:
1. That I am the same JHUNAIDE UTTO ASARI who is one of the
respondents in NPS Docket No. XI-09-INV-19F-00254 for Violation of
ARTICLE 315 in relation to ARTICLE 316 (SYNDICATED/LARGE SCALE ESTAFA),
which is now pending before the office of the City Prosecution, Tagum
City;
2. That in compliance with the notification dated June 28, 2019 and
received by the respondent on July 15, 2019, I hereby respectfully submit
this counter-affidavit;
3. That I vigorously and vehemently deny all the material allegations
contained in the affidavit complaints of CECILE GARCE, DENNIS KEN
LACIA, HAZEL MAYE FUENTES, KENNETH MONTERO PALABRICA, and
CHRISTAN JON LO URDANETA, the same were all product of falsehood and
deserve no consideration but prompt dismissal;
4. That the truth of the matter is that all the allegations contained in
the affidavit of the complainant are baseless. It is however wise to
consider the following facts, to wit:
 In the light of the foregoing, it respectfully prayed that the above
case be dismissed for lack of merit. Such other relief is likewise prayed for.

Kidapawan City, Philippines.

JHUNAIDE UTTO ASARI

(Affiant)

SUBCRIBED AND SWORN TO BEFORE ME, this

, at Kidapawan City, Philippines. I further certify that I have
personally examined the affiant and that he has read and understand the
contents of his counter-affidavit, executed by him freely by him and
voluntarily.
 Republic of the Philippines
DEPARTMENT OF JUSTICE
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
Tagum City

CECILE F. GARCE, DENNIS KEN LACIA, NPS DOCKET NO.

HAZEL MATE FUENTES, KENNETH M. PALBRICA, XI-09-INV-19F-00254
& CHRISTIAN JON LO URDANETA,
Complainants,
-versus- For: SYNDICATED/LARGE
SCALE ESTAFA
RYAN JOHNSKYLE MAUNES,
ANNABELLE P. LALUNA, FRANCIES ELOISE LALUNA,
MARK MICULOB, CHRISTOPHER PULMONES,
JHUNAIDE UTTO ASARI, CIELO RAMOS, &
GINO MANLA OR MANILA,
Respondents.
x---------------------------------------------------------------------------------------------------------x

COUNTER-AFFIDAVIT

COMES NOW the respondent CIELO RAMOS unto the Honorable

Office, most respectfully alleges:
1. That I am the same CIELO RAMOS who is one of the respondents
in NPS Docket No. XI-09-INV-19F-00254 for Violation of ARTICLE 315 in
relation to ARTICLE 316 (SYNDICATED/LARGE SCALE ESTAFA), which is now
pending before the office of the City Prosecution, Tagum City;
2. That in compliance with the notification dated June 28, 2019 and
received by the respondent on July 15, 2019, I hereby respectfully submit
this counter-affidavit;
3. That I vigorously and vehemently deny all the material allegations
contained in the affidavit complaints of CECILE GARCE, DENNIS KEN
LACIA, HAZEL MAYE FUENTES, KENNETH MONTERO PALABRICA, and
CHRISTAN JON LO URDANETA, the same were all product of falsehood and
deserve no consideration but prompt dismissal;
4. That the truth of the matter is that all the allegations contained in
the affidavit of the complainant are baseless. It is however wise to
consider the following facts, to wit:
In the light of the foregoing, it respectfully prayed that the above
case be dismissed for lack of merit. Such other relief is likewise prayed for.
 Kidapawan City, Philippines.

CIELO RAMOS
(Affiant)

SUBCRIBED AND SWORN TO BEFORE ME, this

, at Kidapawan City, Philippines. I further certify that I have
personally examined the affiant and that he has read and understand the
contents of his counter-affidavit, executed by him freely by him and
voluntarily.
 Republic of the Philippines
DEPARTMENT OF JUSTICE
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
Tagum City

CECILE F. GARCE, DENNIS KEN LACIA, NPS DOCKET NO.

HAZEL MATE FUENTES, KENNETH M. PALBRICA, XI-09-INV-19F-00254
& CHRISTIAN JON LO URDANETA,
Complainants,
-versus- For: SYNDICATED/LARGE
SCALE ESTAFA
RYAN JOHNSKYLE MAUNES,
ANNABELLE P. LALUNA, FRANCIES ELOISE LALUNA,
MARK MICULOB, CHRISTOPHER PULMONES,
JHUNAIDE UTTO ASARI, CIELO RAMOS, &
GINO MANLA OR MANILA,
Respondents.
x---------------------------------------------------------------------------------------------------------x

COUNTER-AFFIDAVIT

COMES NOW the respondent FRANCIS ELOISE LALUNA unto the

Honorable Office, most respectfully alleges:
1. That I am the same FRANCIS ELOISE LALUNA who is one of the
respondents in NPS Docket No. XI-09-INV-19F-00254 for Violation of
ARTICLE 315 in relation to ARTICLE 316 (SYNDICATED/LARGE SCALE ESTAFA),
which is now pending before the office of the City Prosecution, Tagum
City;
2. That in compliance with the notification dated June 28, 2019 and
received by the respondent on July 15, 2019, I hereby respectfully submit
this counter-affidavit;
3. That I vigorously and vehemently deny all the material allegations
contained in the affidavit complaints of CECILE GARCE, DENNIS KEN
LACIA, HAZEL MAYE FUENTES, KENNETH MONTERO PALABRICA, and
CHRISTAN JON LO URDANETA, the same were all product of falsehood and
deserve no consideration but prompt dismissal;
4. That the truth of the matter is that all the allegations contained in
the affidavit of the complainant are baseless. It is however wise to
consider the following facts, to wit:
 In the light of the foregoing, it respectfully prayed that the above
case be dismissed for lack of merit. Such other relief is likewise prayed for.

Kidapawan City, Philippines.

FRANCIS ELOISE LALUNA

(Affiant)

SUBCRIBED AND SWORN TO BEFORE ME, this

, at Kidapawan City, Philippines. I further certify that I have
personally examined the affiant and that he has read and understand the
contents of his counter-affidavit, executed by him freely by him and
voluntarily.