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Office of The City Prosecutor

Efrin Salcedo is responding to a complaint filed against him by Jay Lozo for reckless imprudence resulting in slight injuries and damage to property from an alleged traffic accident on June 19, 2020. Salcedo denies being involved in an accident and provides evidence that he was elsewhere at the time. He submits documents showing his route and purpose for travel that day did not match the details in Lozo's complaint. Salcedo argues the timing and lack of vehicle damage indicate Lozo falsely accused him.

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William Santos
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35 views3 pages

Office of The City Prosecutor

Efrin Salcedo is responding to a complaint filed against him by Jay Lozo for reckless imprudence resulting in slight injuries and damage to property from an alleged traffic accident on June 19, 2020. Salcedo denies being involved in an accident and provides evidence that he was elsewhere at the time. He submits documents showing his route and purpose for travel that day did not match the details in Lozo's complaint. Salcedo argues the timing and lack of vehicle damage indicate Lozo falsely accused him.

Uploaded by

William Santos
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
QUEZON CITY

JAY LOZO,
Complainant,
I.S. No. 13-08212
-versus-

EFRIN SALCEDO,
Respondent.
x----------------------------------------------x

COUNTER-AFFIDAVIT

I, EFRIN SALCEDO, of legal age, with address at 56 Nicanor


Reyes St., Loyola Heights, Quezon City, after having been sworn to
according to law, hereby depose and state:

1. I am the respondent in I.S. No. 13-08212 for Reckless


Imprudence Resulting in Slight Physical Injuries and Damage to
Property filed by a certain Jay Lozo (“Lozo”).

2. I am also the owner of a silver Toyota Innova with plate no.


XYZ-897 and I am being charged herein for allegedly traversing
Katipunan St. from Commonwealth on 19 June 2020 at 6:40 a.m.
where I am being imputed to have suddenly turned right at Rosa
Alvero St. and in the process caused damage to Lozo and his driven
motorcycle.

3. There is no basis for such a Complaint against me.


4. As stated earlier, I live at 56 Nicanor Reyes St., Loyola
Heights, Q.C. Attached herein as Annex “1” is a street map showing
the proximity of Nicanor Reyes St. to Rosa Alvero and Katipunan Sts.

5. On said date, I left my residence, to go to Medical City in


Ortigas Avenue due to the fact that I had to visit a friend who was
about to undergo an operation at 7:00a.m., as attested by the Medical
City Department of Surgery, a copy of which is attached herewith as
Annex “2”.

6. Due to the usual heavy traffic along Katipunan Ave., the


route that I took on 19 June 2020 was from my residence at Nicanor
Reyes St., then I turned right at C. Salvador St. until I reached Rosa
Alvero St. where I turned left bound for Katipunan. This route is
highlighted in Annex “1”.

7. So, the allegation that I was driving along from


Commonwealth is completely not true and therefore I could not have
turned from Katipunan to Rosa Alvero St..

8. According to Lozo’s allegations, my car should have


markings, dents or scratches on the right side. I did not notice any
motorcycle, in particular the one driven by Lozo which he claims I hit
with my driven vehicle, collide with my Toyota Innova. Attached
herewith as Annexes “3” and “4” are pictures of the right side of my
Toyota Innova which show that there are no markings dents or
scratches of any kind whatsoever and this is the same condition from
19 June 2020 up to the present.

9. In order to show a complete picture to the Honorable


Prosecutor, attached herewith as Annexes “5” and “6” are pictures of
the left side of my Toyota Innova which also show that there are no
markings, dents or scratches of any kind whatsoever and this is the
same condition from 19 June 2020 up to the present.

10. To put things in perspective, it is contrary to natural order


of things that the Complaint with the Vehicle Traffic Investigation
Unit of Q.C. was filed by Lozo only at 5:45p.m. when he claims that
the alleged accident occurred at 6:40a.m.. Shortly put, this actuation
of Lozo renders his charges against me highly suspect considering
that It was a school day on 19 June 2020 and there are MMDA and
other traffic enforcers as well as policemen and Barangay Tanods all
around the area and therefore, he should have instantly reported this
alleged accident immediately after it happened at 6:45 a.m. of 19 June
2020, if indeed it really happened at all, on that time and day
involving my driven vehicle considering that the same involves
physical injuries and damage to property as claimed by Lozo.

11. These circumstances will certainly lend credence to this


Counter-Affidavit that Lozo was maliciously finger pointing an
innocent man by stating that it was my vehicle which caused the
alleged accident because from the above-narration, it is crystal clear
that it was not my vehicle which hit and damaged his motorcycle as
my vehicle was nowhere near him at the time and he even recognize
me as the driver of the vehicle.

I am executing this Counter-Affidavit to attest to the truth of


the foregoing and to belie the Complaint of jay Lozo against me for
Reckless Imprudence Resulting in Slight Physical Injuries and
Damage to Property.

EFRIN SALCEDO
Affiant

SUBSCRIBED AND SWORN TO before me this 18 th day of


August, 2020 at Quezon City. I hereby certify that I have personally
examined the affiant and that I am fully satisfied that he voluntarily
executed and understood his counter-affidavit.

JOSH NAPIZA
Assistant City Prosecutor

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