People of the Philippines) Criminal Case No.

12345
Province of Laguna ) For: Murder
City of San Pablo ) S.S.

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COUNTER-AFFIDAVIT
I, Jose B. Sison, of legal age, married, Filipino, and a resident of Boomtown St., San Pablo
City, Laguna, Philippines, after having been sworn in accordance with the law, respectfully states
that:

1. That I am the accused in Criminal Case No. 1234 for the crime of Murder under
Article 248 of the Revised Penal Code;

2. That paragraph 3 of the Sworn Statement of Wilfredo A. Hernandez dated xx is

denied. The truth of the matter are as follows: That in the afternoon of December 3,
2019, at exactly 4 o’clock, I was with my friend (Drinking Buddy’s name) drinking in
their house to celebrate his birthday. Present during that time were my buddy’s wife
and son. I was with him drinking up until 8 o’clock in the evening and was able to
finish 2 bottle of brandy and directly went home. That when I reached home, because
of the effect of the alcohol, I already slept. Living in the same house is my wife who
will be able to testify the same.

3. That the allegations in the Complaint-Affidavit are false as it was physically

impossible for me to commit the crime charged because I was already sleeping in our
house when the crime happened.

4. That the deceased, Alberto A. Hernandez, instead of being a murder victim, could
have committed suicide. Aside from the fact a gun was found near Alberto’s right hand
and the cause of Alfredo’s death is a single shot to the head, three (3) months ago,
Alberto was caught by his brother, Wilfredo, attempting to commit suicide in their
backyard. A suicide note was also found pinned at their house. That such facts were
made known to almost all of the residents of our town as many have helped Wilfredo
convinced Alfredo not to commit suicide.

5. That I am executing this Counter-Affidavit freely and voluntarily for the purpose of
attesting the truth of the foregoing statements, to inform the proper authorities of the
above facts, to support my prayer for the dropping or dismissal of the instant case
against me and for whatever purpose this may serve best.

IN WITNESS THEREOF, I have hereunto set my hand this ___ day of _______, 2020 at
San Pablo City, Laguna.

JOSE B. SISON
Accused Party

SUBSCRIBED AND SWORN to before me this ___ of ______, 2020 at San Pablo City,
Laguna, Philippines and I further certify that I have personally examined the affiant and I am
satisfied that he has read and personally understood the contents of his forgoing Counter-Affidavit.

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