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Republic of the Philippines

Department of Justice
NATIONAL PROSECUTION SERVICE
Office of the City Prosecutor
Calamba City, Laguna

Rolando Taleon, IV-12-INV-090-00628


Complainant,

-versus- FOR: Adultery

ARACELIE TALEON and


YULITO L. GONZAGA,
Respondents,
x---------------------------------x

JUDICIAL COUNTER-AFFIDAVIT
I, YULITO L. GONZAGA, Filipino, of legal age, married, presently
residing and with postal address at Blk. 4 Lot 2 Andrea Paz, Brgy. Barandal,
Calamba City, after having been sworn according to law, depose and state the
following facts related to the accusation made by complainant Rodolfo Taleon
against the undersigned allegedly for committing Adultery together with his
wife, Aracelie Taleon:

THAT, there is no truth to the accusation made against me;

THAT, complainant’s wife Aracelie Taleon is my dealer since February


2009 and I was in their house at that date and time when her husband arrived
because I was collecting payment of Natasha products taken by her from the
Company under my account, attached are the TRUST AGREEMENT NO. 256675
A, annex “ A”, NO. 317136 A, annex “A-1”, NO. 317135A ANNEX “A-2” and
NO. 256666A annex “A-3”;

THAT, Aracelie Taleon is also my franchise dealer since July 2008


todate;

THAT, when her husband arrived, we were upstairs because she was
showing the items to be returned to Natasha and we were properly dressed, not
nude as alleged by complainant;

THAT, he saw the items to be returned and he did not make any comment
when he left us upstairs;

THAT, I immediately followed him downstairs but was surprised when


he shouted and called for Barangay Tanod;

THAT, he admitted that the main door was open when he arrived
because nothing unsual or immoral has been going on because it was purely a
business call;

THAT, when the Tanod arrived, he made accustion that he saw us naked
and making love upstairs, when the door and the main door are wide open as
dmitted by the complainant, which is not normal if there was an immoral or
adulterous plan to be committed by Cely and myself;

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THAT, I was handcuffed by the Tanod and was brought to the J.P. Rizal
Memorial Hospital and when there was no doctor present, I was brought to the
City Police Station for detention;

THAT, I protested my detention and confronted the husband-complainant


that I have not done anything wrong or immoral to his wife, that is why I was
released the next morning,

THAT, complainant must be hallucinating and in jealous fit, so much so


that he thought we are doing some monkey business upstairs but he saw the
items to be returned and it was purely business, hence he created scene to
cover up for his unfounded thoughts and malicious mental accusations.

THAT, his wife, my co-respondent persuaded with him until he came


back to his senses.

THAT, no evidences was even presented to the police to show that our
panties/jockeys or pants/skirts were retrieved by him to prove his allegations.

THAT, I am planning to file criminal and civil case against him in proper
time to redeem my tarnished honor and human rights as a result of his wanton
and reckless actions not supported by evidences.

IN TRUTH OF THE FOREGOING, I hereby affixed my signature this


11th day of August 2009 at Calamba City.

YULITO L. GONZAGA
Affiant/respondent

SUBSCRIBED AND SWORN TO before me this 11th day of August 2009


at Calamba City. Exhibited his CTC NO. 08337477 issued at Calamba City on
10 August 2009.

-2-
Republic of the Philippines
Department of Justice
NATIONAL PROSECUTION SERVICE
Office of the City Prosecutor
Calamba City, Laguna

Rolando Taleon, IV-12-INV-090-00628


Complainant,

-versus- FOR: Adultery

ARACELIE TALEON and


YULITO L. GONZAGA,
Respondents,
x---------------------------------x

APPEARANCE AS COUNSEL AND EXTENSION


OF TIME TO FILE COUNTER-AFFIDAVIT

UNDERSIGNED, formally enter my appearance as Counsel for


respondent YULITO L. GONZAGA, in the above-entitled case.

Please furnish me all Notices and Summons related to the


above-entitled case for all intent and purposes.

Likewise, please give me fifteen (15) days to formally file


respondent’s counter-affidavit, as my professional services has been
hired just today.

ATTY. GREGORIO E. MAUNAHAN


158 DRJose Rizal St., Calamba City
PTR OR 4177872/1-05-09/Calamba City
ATTY. ROLL NO. 29651/IBP LIFE MEMBER ROLL NO. 01404
MCLE Compliance No. 0705 ON 12 Sept 2008

UPON MY DIRECTION:

YULITO L. GONZAGA
Respondent

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