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MOTION TO ADMIT ATTACHED

REJOINDER TO AFFIDAVIT

Complainant in his own behalf respectfully submits:


1. That he is submitting the attached REJOINDER for the
consideration of the honorable office of the Provincial
Prosecutor;

Respectfully Submitted,

EDGARDO TEROL
Respondent

REJOINDER TO REPLY AFFIDAVIT


Respondent in his own behalf and unto this honorable office respectfully
submits;
1. That complainant Charmaine B. Algarin has no legal an factual cases
to accused herein respondent for relation of the Republic Act 7610;
2. That no reiterates that the factual scenario that truly happened on
February 22, 2010 was the one respondent advanced in his counter
affidavit. Complainant is peddling lies to the point of stating the
opposite. Now, she is submitting the affidavits of two witnesses
namely; Bernardo R. Lorenzo Jr. and Eva Fermin These two rehearsed
and doubtful witnesses dont know what they signed considering that
they never saw the incident that had happened on February 22, 2010.
As to why they have the temerity to perpetuate falsehood is really
puzzling. It is truly disheartening that these two witnesses who are our
neighbors sided with complainant, when in truth and in fact, they were
never present at that time when respondent had a verbal altercation.
And that verbal altercation was not exactly those two witnesses
pictured them to be as it was the complainant who ridiculed and hurled
unsavory language against respondent. It was merely a case of
respondent being more elderly persuaded complainant to behave. If it
has come to a point that respondent displayed a little outburst, which
is understandable considering that he was insulted personally by
complainant. In the same situation, who would not be mad and furious
if you are accused of being idiot and illiterate! Isnt it natural to display
emotional outburst if insulted and degraded? It was complainant who is
distorting facts and in truth it was she that is notoriously known in our
Barangay as a lady tough and disrespecting our very own parents.
3. That if there is semblance of truth to the wild accusation of the
complainant then why is it, that she did not lodged at first her
complain in the Barangay? Complainant and respondent came from the
same locality and as such pursuant to the Katarungang Pambarangay
Law, this kind of conflict falls squarely within the jurisdictions of our
Barangay. The injuries allegedly sustained by complain requires a
heating period of less than ten days and the penalty imposed for this
injury is merely a month or arresto menor. Truly, the Barangay has
jurisdiction even assuming that the accusation was for violation of R.A
7610. Nowhere in the provision of R.A. 7610 will you find that the
Barangay has no jurisdiction. The law on Katarungang Pambarangay
should know be reconciled with R.A 7610 so that a less costly and
efficient administration of justice is achieved.
4. In fact, in the subpoena issued by the office of the Provincial Prosecutor
it is obviously stated; Hindi biro o negosyo ang pagdedemanda!
Makibaka para sa malinis na pamamalakad ng Hustisya. Hindi
Laruan ang Hustisya. Complainant is obviously toying around with
justice. She is burdening this office with malicious complain intended to

harass respondent. The honorable investigating prosecutor would


closely scrutinized the complain, the same would not merit
consideration in as much as several accusations are being bombarded
against the respondent. Respondent was accused of Physical Injury in
relation to R. A 7610, Physical Injury in relation to R.A. 9262, Grave
Oral Defamation in relation to R.A. 7610, Grave Threat in violation to
R.A. 7610 and Verbal Abuse in relation to R.A. 7610. This kilometric
accusation is a very strong indicia that they were merely intended to
harass and intimidate the respondent. If complainant is sure enough
she would surely concentrate on one accusation and not on several
which are merely pure inventions. If complainant is on her right senses,
she would not bother this office with this ridiculous accusation. Again,
Hindi Laruan ang Hustisya. This has been the battle cry of the
Prosecutors Office. Respondent just hope and pray the office of The
Provincial Prosecutor would not fall in to this snake pit.
5. To recapitulate, respondent is not guilty of any offense and he
committed no violence or abuse to the person of Charmaine B. Algarin.
The Office of The Provincial Prosecutor should be using of this complain
because it smacks the very motto of its office which respondents
reiterates Hindi Laruan ang Hustisya . If complainant wants to play,
she should go to our Barangay and engage the respondent to a sports
match she fools, she is superior.

WHEREFORE, it is most respectfully beseeched with this office that the


above entitled case be dismissed with prejudice for lack of probable cause
and prima-facie guidance.

Respectfully submitted this 21st day of June 2010.

EDGARDO TEROL
Respondent

Subscribe and Sworn to before me this 21st day of June 2010.

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