1
Republic of the Philippines )
Province of Negros Oriental)S.S.
Dumaguete City )
COUNTER – AFFIDAVIT
I, GEORGIA A. CONCEPCION, Filipino citizen, of legal age, widow and a
resident of Barangay Bogo, Dumaguete City, Negros Oriental, Philippines, subscribing
under oath, hereby depose and say that:
1. I am the respondent in the criminal case filed against me by ROWENA B.
GHIO for SWINDLING/ESTAFA of the Revised Penal Code.
2. That I vehemently denied all the accusations against me. The truth of the
matter was that I disclosed all the information of such property and give all the papers in
my possession for her to check it before she decided to buy such property. I never hide
any information regarding such lot.
3. That days before the execution of Absolute Deed of Sale, Mrs. LEZEL T.
ROJO handed to her the documents of such property such as Deed of Absolute Sale in
favor of Georgia Concepcion, the Certified True Copy of Title with annotation on the
adverse claim of Georgia A. Concepcion, the Order of the Court withdrawing the
Petition of Adverse Claim and Survey of Lot 5468-A and 5468-B. These are the
documents I gave to Mrs. Rojo since I collateralized such property on the loan she
extended to me.
4. That such Lot was offered only P300,000.00 because the title of such lot was
not clean and needs a lot of processing and may even need court litigation. I sold it so
that I can pay off the loan with Mrs. Rojo in the amount of P250,000.00 and the
P50,000.00 goes to me. That is why one check of P250,000.00 goes to MS. ROJO and
the other check goes to me for P50,000.00.
5. That the complainant was accompanied by Mr. Medardo R. Quebral III who
was connected or liason of the Notary Public, ATTY. NATHAN JOSEPH P. RAMACHO
and he was the one who assessed my documents. And they are the ones who adviced
the complainant to pursue with the sale.
6.This Answer is voluntarily and freely executed in compliance with the subpoena
of this Honorable Office and to move for the dismissal of the complaint, outright or after
due hearing.
IN WITNESS WHEREOF, I have hereunto affixed my signature this
___________ in Dumaguete City, Negros Oriental, Philippines.
GEORGIA A. CONCEPCION
Affiant
SUBSCRIBED AND SWORN to before me this_____________ in Dumaguete
City, Negros Oriental, Philippines, affiant personally appearing before me; presenting to
me his Counter-Affidavit; exhibiting to me her Senior Citizen ID No. 11493. I HEREBY
CERTIFY that I have personally examined the above-named affiant-complainant and I
am convinced that he has read and understood the contents of her foregoing Counter-
Affidavit and that the same is her free and voluntary act and deed.
1
2