REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
Office of the City Prosecutor – Paranaque City

RICHELLE SIASON,
Complainant,
NPS Docket No. ____________
-versus- For: Violation of Article ___ of the Revised
Penal Code (Perjury)
EDWIN SIASON and JOSEPHINE
OLLERES-CAMPOS,
Respondents.
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COMPLAINT AFFIDAVIT

I, RICHELLE SIASON, Filipino, married, of legal age, with office address at

__________, after having been sworn to in accordance with law, hereby depose and state:

1. I am filing a formal complaint for violation of Article 183 of the Revised Penal
Code or otherwise known as “False Testimony in Other Cases and Perjury in Solemn
Affirmation” against Respondents EDWIN SIASON and JOSEPHINE OLLERES-
CAMPOS;

2. I personally know Respondent EDWIN SIASON due to the fact that he is my

husband and had known him since 1997 when we both took Associate in Computer
Technology at Malabon Community College;

3. Last October 15, 2019, I filed a complaint against Respondent EDWIN

SIASON for Violation of Section 3 (a) (d) of Republic Act 9262, or otherwise known as “Anti
Violence Against Women and their Children Act of 2004” and for both Respondent EDWIN
SIASON and JOSEPHINE OLLERES-CAMPOS for violation of Article 334 of the Revised
Penal Code or otherwise known as “Concubinage”. Attached hereto and made an integral
part hereof is a copy of the Investigation Data Form with Docket No. XV-12-INV-19J3005
as ANNEX “A” and the corresponding Complaint Affidavit as ANNEX “A-1”;

4. On paragraph 14 of my Complaint Affidavit, I accused Respondent EDWIN

SIASON of fathering a child together with Respondent JOSEPHINE OLLERES-CAMPOS
named PRECIOUS ELISHA SIASON, who was born last September 14, 2018;

5. Unfortunately, as the time of the filing of the aforesaid complaint, I had yet to
secure a copy of the Philippine Statistics Authority Certificate of Live Birth of the said minor,
hence, I was not able to include the same as part of the annexes to the complaint that I filed
against the Respondents;

6. However, I was only able to secure a copy the Certificate of Live Birth of
PRECIOUS ELISHA SIASON at around 12 pm of November 26, 2019. Attached hereto
and made an integral part hereof is a copy of the Certificate of Live Birth of minor PRECIOUS
ELISHA SIASON as ANNEX “B” and the corresponding Affidavit of
Paternity/Acknowledgement as ANNEX “B-1”;
 7. On November 26, 2019, Respondents EDWIN SIASON and JOSEPHINE
OLLERES-CAMPOS filed their respective Counter Affidavits to answer the allegations
against them. Their Counter Affidavits was subscribed and sworn to before Assistant City
Prosecutor ALAN MICHAEL MONDRAGON of the Paranaque City Prosecutor’s Office.
Attached hereto and made an integral part hereof is copy of Respondent EDWIN SIASON’s
Counter Affidavit as ANNEX “C” and the signature of Assistant City Prosecutor Alan
Michael Mondragon as the Administering Officer as ANNEX “C-1” and a copy of
Respondent JOSEPHINE OLLERES-CAMPOS’ Counter Affidavit as ANNEX “D” and the
signature of Assistance City Prosecutor Alan Michael Mondragon as the Administering Officer
as Annex “D-1”;

8. On page 1, paragraph 2 of the Counter Affidavit filed by Respondent EDWIN

SIASON, he stated that:
xxx
“2. That I hereby vehemently deny having committed the felony of concubinage and economic abuse,
contrary to the assertion of the Complainant;

xxx

9. Furthermore, on page 3, paragraph 19 of the Counter Affidavit, Respondent

EDWIN SIASON further emphasized that:

xxx

“19. That with respect to the charge of concubinage, I had a brief relationship with Josephine Olleres-
Campos sometime in 2017 but it was as mentioned earlier, a very brief acquaintance and when
Josephine Olleres-Campos came to learn that I am a married man, she avoided me thereby terminating
whatever communication we had to each other;

xxx

10. On the other hand, on page 2, paragraph 9 of the Counter Affidavit submitted
by Respondent JOSEPHINE OLLERES-CAMPOS, she issued a blanket denial of the
accusation I had made that she and Respondent EDWIN SIASON both had a child named
PRECIOUS ELISHA SIASON, who was born last September 14, 2018, to wit:

xxx

“9. Thirdly, Complainant further hinges her accusation against me for the crime of concubinage by
mentioning the birth of a child. But Complainant’s self-serving statement on this matter was only
based on an information coming from a third person (see par. 14 of Complaint Affidavit). No other
documentary evidence such as birth certificate of the child was attached to prove Complainant’s claim
on this regard. Hence, the same cannot be given weight or any probative value in finding prima facie
case for concubinage;

xxx

11. Furthermore, on page 3, paragraph 10 of Respondent JOSEPHINE

OLLERES-CAMPOS’ Counter Affidavit, she further elaborated the impossibility of
cohabitation, which is quoted hereunder, to wit:

xxx
 “10. Finally, I am working as an OFW, for which reason I have been out of the country on a regular
basis. Thus, the impossibility of cohabitation. By way of example, I have attached hereto copies of my
departures and arrivals in year 2017 as Annex “A” and “B” respectively;

xxx

12. It is very clear that Respondent EDWIN SIASON committed the act of perjury
as can be gleamed on page 3, paragraph 9 of his Complaint Affidavit. His attestation that he
had terminated a “brief” relationship with Respondent JOSEPHINE OLLERES-CAMPOS
is belied by the fact that a child was born out of their affair last September 2018;

13. Given the preceding circumstance, it is a foregone conclusion that their affair
lasted for more than two (2) years, which, for all intents and purposes is not brief nor had
concluded back in 2017;

14. It is also noteworthy that Respondent JOSEPHINE OLLERES-CAMPOS lied

in her Complaint Affidavit, more specifically on paragraph 10, whereby she had raised the
“…impossibility of cohabitation”;

15. As may be gathered from the foregoing, it is very clear that Respondents
EDWIN SIASON and JOSEPHINE OLLERES-CAMPOS, committed acts contrary to law,
more specifically Article 183 of the Revised Penal Code, which is quoted hereunder:

Art. 183. False testimony in other cases and perjury in solemn affirmation. — The penalty of arresto
mayor in its maximum period to prision correccional in its minimum period shall be imposed upon any
person, who knowingly makes untruthful statements and not being included in the provisions of the
next preceding articles, shall testify under oath, or make an affidavit, upon any material matter before
a competent person authorized to administer an oath in cases in which the law so requires.

16. On an equally important note, both Respondents EDWIN SIASON and

JOSEPHINE OLLERES-CAMPOS, committed the following acts: (1) They made a
statement under oath thru their respective Counter Affidavits, (2) They made the statement
before a competent officer, in this case Assistant City Prosecutor ALAN MICHAEL
MONDRAGON, (3) That both Respondents made a willful and deliberate assertion of a
falsehood and (4) That their Sworn Counter Affidavit was for the purpose of answering the
allegations against the case I file against them before the Office of City Prosecutor of
Paranaque;

17. Notwithstanding, the acts committed by Respondents EDWIN SIASON and

JOSEPHINE OLLERES-CAMPOS meets the jurisprudential elements of Article 183 of the
Revised Penal Code, to wit:

“The elements of perjury under Art 183 are:

(a) That the accused made a statement under oath or executed an affidavit upon a material matter.

(b) That the statement or affidavit was made before a competent officer, authorized to receive and
administer oath.

(c) That in the statement or affidavit, the accused made a willful and deliberate assertion of a falsehood.
 (d) That the sworn statement or affidavit containing the falsity is required by law or made for a legal
purpose.” – Union Bank of the Philippines versus People of the Philippines, G.R. No. 192565,
dated February 28, 2012

18. I am executing this Complaint-Affidavit in support of the filing criminal charge

for violation of Article 183 of the Revised Penal Code against EDWIN SIASON and
JOSEPHINE OLLERES-CAMPOS and for whatever legal purpose this document may
serve;

19. Respondent EDWIN SIASON can be served with summons and other
processes of this Honorable Office at his last known address at 356 Rajah Tupas Steet, Danng
Hari, Navotas City while Respondent JOSEPHINE OLLERES-CAMPOS may be served
with summons and other processes of this Honorable Office at 213 E. Tuazon St. San Jose,
Navotas City.

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

December, 2019 at _________________________________, Philippines.

RICHELLE SIASON
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, this ___ day of December,

2019 at Paranaque City, Metro Manila, Philippines

ASSISTANT CITY PROSECUTOR

CERTIFICATION

I hereby certify that I have personally examined the affiant and I certify further that he
voluntarily executed the foregoing complaint affidavit and all the statements and allegations
made therein were understood by her.

ASSISTANT CITY PROSECUTOR