Republic of the Philippines
Department of Justice
National Prosecution Service
Ermita, Manila
LEVIE-LAINE MAUHAY y CURA,
Complainant,
NPS DOCKET No. XVI-INV-19L-00464
-versus- For: Violation of Art. 267 (Kidnapping)
of the RPC; and RA10883 (New
Anti-Carnapping Law)
PCPT JOHN CARLOS ORNALES
y Vilale; PCAPT LLEWELYN REYES
y Asuncion; PCpl JOHNDY DUYA
y Quillon; PCpl DINNO LAURENTE
SERRANO y De Leon; and several
John Does,
Respondents.
x---------------------------------------------------x
EX-PARTE MANIFESTATION OF COMPLIANCE
To this Honorable Office, now comes PCPT LLEWELYN A
REYES, assisted by counsel and respectfully avers that:
1. On August 14, 2020, he received a copy of the ORDER
dated 20 July 2020. The Order directed the Respondents to
submit their Rejoinder-Affidavit within ten (10) days from
receipt thereof;
2. Thus, PCPT LLEWELYN A REYES, has until August
24, 2020 to comply and the submission of his compliance
on or before said date would be timely;
3. Anent the supporting documents, PCPT LLEWELYN A
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REYES respectfully begs leave to manifest that his exhibits
1
had already been submitted to this Honorable Office and
attached his Counter-Affidavit and he honestly believes that to
submit them again might be a surplusage.
4. With regards to the duly subscribed Affidavit of his witness
PSSG GABBY MARUDO CASTILLO the same was already
submitted before this Honorable Office when he submitted his
Counter-Affidavit and was attached thereto as his Annex “1”-
Reyes;
5. Additionally, the duly subscribed Affidavit of his witnesses
PMSG GLORIOUS GOMER CALDO CAMACHO the same
was likewise submitted before this Honorable Office and
attached to his Counter-Affidavit as his Annex “2”-Reyes;
6. His proof that he was not in Pampanga on October 15, 2018
is a Certification dated January 9, 2020 issued by the Batangas
Provincial Office and signed by Police Major RODEL S BAN-
O (Chief PIB), Police Major JOHN G RELLIAN (Chief,
PPHRDB) and Police Colonel EDWIN A QUILATES
(Provincial Director) and attached to his Counter-Affidavit as
his Annex “3”-Reyes;
7. His other proof that he was not in Pampanga on October 15,
2018 is a Certification dated January 22, 2020 issued by the
Batangas Provincial Office and signed by Police Major
RODEL S BAN-O (Chief PIB), which he had also attached to
his Counter-Affidavit as his Annex “4”-Reyes;
8. Annex “4” certified that the Police Operation on October 15,
2018 was duly and properly recorded in the Police Blotter of
the Batangas Police Intelligence Branch Office on page 28 of
the Police Blotter under Entry Nos. 157 and 158 dated October
15, 2018 was likewise already attached to his Counter-
Affidavit as his Annex “5”-Reyes;
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9. Annex “6”-Reyes was likewise already attached to his
Counter-Affidavit. This is the After-operations Report dated
October 17, 2018 which confirms that the following day,
October 16, 2018, PCPT LLEWELYN A REYES was with
the Provincial Intelligence Team led by PSI ALDRIN JAY B.
BAYSA, Deputy Chief, PIB/ Chief PDEU which successfully
arrested one Fernando Dimaandal y Ebora @Tado in a buy-
bust operation;
10. All the pieces of evidence including the CCTV, GPS and
VIDEO recording and testimonies of witnesses, positively point
to and directly pinpoint the respondents PCAPT JOHN
CARLOS V ORNALES, Pssg Dinno Laurente D. Serrano, PCpl
Jhondy Q. Duya as the ones who kidnapped Barry Mauhay
and carnapped the car of Levi-laine;
Respectfully submitted.
Silang, Cavite for the City of Manila.
August 19, 2020.
PCPT LLEWELYN ASUNCION REYES
Affiant
BEFORE ME, a Notary Public for and in the Province of Cavite,
this 19th day of August, 2020, appeared the person of PCPT LLEWELYN A
REYES with his Philippine National Police (PNP) ID No. 17L070278, valid
until October 20, 2020, presenting the above document, personally known to
me and identified by me through competent evidence of identity as defined by
the Notarial Rules as the person who signs the document and in my presence
taken an oath or affirmation before me as to such document. WITNESS MY
HAND AND SEAL ON THE DATE AND PLACE FIRST ABOVE-
WRITTEN.
Doc. No. 85; Atty. IRINEO A. ANARNA
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Page No. 18; Notary Public
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Book No. 294; Commission No. TG-18-016 til 12-31-2020
Series of 2020 PTR No. 3033460/1-02-20/TMC
Roll No. 32080, May 10, 1982
IBP Lifetime Member No. 001666,
March 25, 1997
No. 4 Madlansacay St., Brgy. Poblacion II,
Silang, Cavite
REJOINDER-AFFIDAVIT
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of PCAPT LLEWELYN A REYES
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I, PCPT LLEWELYN A REYES, Filipino, of legal age, single
and residing at Barangay Munting Ilog, Silang, Cavite, after being duly
sworn in accordance to law, hereby depose and state that:
1. In her Reply-Affidavit, Private Complainant argues that:
“29. It is unlikely that a police officer,
who is supposed to be abreast with law, will
immediately trust another person without
inquiring anything regarding a vehicle which is
being passed on to his possession. Surely, PCPT
Reyes would not reach his current rank without
knowing the law on Anti-Fencing.” (emphasis, ours)
2. If it were just another person, there is no dispute that it is
really unlikely that I will immediately trust him. The circumstances in
this case are different. PCpt. Ornales is not just another person. He
is my classmate and a mistah;
3. As cadets in our MANDILAAB CLASS at the Philippine
National Police Academy (PNPA), I and PCpt Ornales were always
required to recite the following HONOR CODE:
a) “On my honor, I will uphold the truth in words and
in deeds at all times”;
b) We the cadets do not lie, cheat, steal nor tolerate
among us those who do”
4. On my honor, I will uphold the truth in words and in
deeds at all times. I was abiding with this honor code and on my
honor, upholding the truth when I revealed the truth that it was PCpt.
Ornales who delivered that car in my police station in Malvar, Batangas
and left it there
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5. We the cadets do not lie, cheat, steal nor tolerate among
us those who do. I allowed PCpt. Ornales to leave the car and I
believed that he also abides with the honor code that he does not LIE,
CHEAT or STEAL;
6. We cops should live by the Honor Code. Time and
again, this Honor Code has been repeatedly inculcated in our minds
by the Philippine National Police Academy and even after we graduate
and dispatched to our respective assignments. This was again
reiterated by the Regional Training Center in Bicol last August 1, 2019
that the Honor Code constitute the PNP’s pledge, that we the cadets
“Do not lie, cheat, steal and do not tolerate among the policemen who do
so.”1
“With the police’s mandate “to serve and protect,” the Regional
Training Center in Bicol challenges the Philippine National Police
(PNP) personnel to live by the Honor Code.
The Honor Code constitute the PNP’s pledge, “Do not lie, cheat,
steal and do not tolerate among the policemen who do so.”
RTC-5 provides training and human resource development
programs for the police cadets and PNP uniformed personnel so
they may possess the knowledge, skills, attitudes and values
necessary in the exercise of their profession.
“They should develop their character competency, their values,
attitudes and the good manner and right conduct through our
Honor Code,” Police Senior Master Sergeant (PSMS) Ryan P.
Llenaresas, Chief Public Information Officer of RTC-5, said.
He added that aside from the skills, the police cadets and police
officers should instill good character for their suppression and
prevention of crimes.
1
PNP training center: Cops should live by the Honor Code
By Casandra E. Balala, Philippine Information Agency, August 1, 2019
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PSMS Llenaresas also explained that there are three phases for
the police training program—the investigation process, patrol
operations, and internal security operations.
Last July 5, 2019, a total of 609 patrol officers have graduated
from the RTC-5 who will proceed for the field training exercise
for five months.
7. As to Private Complainant’s claim that I did not attach any
proof that said vehicle was used by PCpt Jayson Aguilar because PCpt
Ornales allowed him to do so, I swear that before I turned-over the keys
of the car to PCpt Aguilar, I called up PCpt Ornales and informed him
about it and PCpt Ornales permitted me to give it to PCpt Aguilar;
8. This is the same statement I stated in my SINUMPAANG
SALAYSAY dated May 13, 2019. Thus:
“1. Na si PCPT JOHN CARLOS ORNALES at ako ay
mag kaklase sa PNPZ Mandilaab of 2014, at itinuturing ko
siya bilang isang kaibigan;
2. Na noong Pebrero 12, 2019 at PCPT JOHN
CARLOS ORNALES ay personal na nagpunta at dumalaw sa
akin sa Malvar Municipal Police Station, iniwan niya noon
ang isang Toyota Vios, model 2011, kulay itim at sinabi niya
na tulungan ko siya na ito ay maibenta;
3. Na noong buwan ng abril 2019, ang nasabing
sasakyan ay hiniram naman ni PCPT JAYSON CAPARAS
AGUILAR para gamitin pansamantala dahil sa may problema
ang kanyang sasakyan;
4. Na, itinawag ko muna sa aking classmate na
si PCPT JOHN CARLOS ORNALES kung maari bang
pansamantalang gamitin ni PCPT JAYSON CAPARAS
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AGUILAR ang sasakyan iniwan niya (vios), at siya (Ornales)
ay pumayag;
5. Na noong buwan ng Abril 2019 ay ibingay ko
ang susi ng vios kay PCPT JAYSON CAPARAS AGUILAR at ito
ay kanyang ginamit;
6. Na simula noong buwan ng Abril 2019 ay na
kay PCPT JAYSON CAPARAS AGUILAR ang nasabing sasakyan
hanggang sa siya ay nahuli ng CITF kagabi (May 7, 2019);”
9. I was not hiding anything when I executed this
SINUMPAANG SALAYSAY. I was just telling the truth as I must do
and I did not lie. Perhaps, the Private Complainant forgot that when the
car was seized, it was in the possession of PCpt Jayson Aguilar and he
did not have any proof that he borrowed the same;
10. On my honor, I uphold the truth when I executed this
statement that the car was borrowed while it was in my custody in
Malvar, Batangas;
11. PCpt Jayson Aguilar publicly and openly used the car
and it is very logical that like me, he did not know that the car was a
carnapped car, otherwise, he will not be driving the same publicly;
12. The Private Complainant admitted in her Reply-Affidavit
that I was not seen in the CCTV during the kidnap of Barry Mauhay and
carnap of the subject vios vehicle because it is true and also stipulated
among the parties including PCpt Ornales and the other Respondents that
I was not there. Thus the stipulation is hereby quoted:
“on October 15, 2018 all the Respondents
except Respondent PCPT LLEWELYN
A REYES, were seen in the CCTV as the
ones who kidnapped Barry Mauhay and
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carnapped the vios car of Levie-Laine
Mauhay”.
13. I respectfully reiterate that with the above-quoted
stipulation, there is a ground to drop my name as one of the
Respondents;
14. In the Investigation Data Form, the complainant stated
that the Date and Time of Commission was on October 15, 2018 at about
8:30 pm. Since all the parties admitted that I was not part of the group
who committed the crimes as caught in CCTV, I honestly believe that
there is valid basis to drop my name as one of the Respondents;
15. As to the fantastic allegations in the Counter-Affidavits
of my co-Respondents, while I am not asked to respond on them, I
find their allegations full of lies and not simple but invented lies, which
allegations were NOT mentioned in their Affidavits submitted by them at
the Internal Affairs Service (IAS) in Camp Crame. According to my
lawyer, NECESSITY IS THE MOTHER OF INVENTION. Invented or
fabricated lies are a dire necessity especially if facing prosecution for very
very serious offenses is inevitable;
16. I know that in divulging the truth that it was PCpt
John Carlos V. Ornales who brought the car to Malvar, Batangas and left
it to me, I will lose the esteem and friendship of a classmate and friend.
I may be hated and decried by those who do not know the truth as they
might think that I broke the unwritten rule on BROTHERHOOD and
camaraderie, but I can face everyone with heads up high and look at
them straight in the eye and tell them that as a true cadet of the PNPA,
I stood by the truth and I live by adhering to the Honor Code.
17. I executed this Rejoinder-Affidavit to attest to the
truthfulness and veracity of all the contents herein; to prove that I have
not committed any kidnapping and carnapping and to request the Hon.
Investigating Prosecutor, to drop my name as a Respondent in the above-
entitled case and to dismiss the complaint against me for lack of basis.
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IN WITNESS WHEREOF, I have hereunto signed below.
PCPT LLEWELYN ASUNCION REYES
Affiant
SUBSCRIBED AND SWORN TO BEFORE ME, this ______ day
of March, 2020.
Hon. ALYSSA ANA M. ZAPATA
Investigating Prosecutor
CERTIFICATION
I hereby certify that I have examined the Affiant and am fully
satisfied that he voluntarily executed his Rejoinder-Affidavit.
Hon. ALYSSA ANA M. ZAPATA
Investigating Prosecutor
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I, LLEWELYN A. REYES, Filipino, of legal age, married and a resident of Brgy.
Munting Ilog, Silang, Cavite after having been sworn to in accordance with law
herebyby depose and state, THAT:
18. I am a member of Philippine National Police and was currently
assigned as Deputy Chief of Police of Calaca Municipal Police Station;
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19. I vehemently deny the allegations and charges against me in the
complaint, I never corroborate with PCPT John Carlos Ornales. The
truth of the matter is that on February 12, 2019, when I was the Acting
Chief Of Police of Malvar Municipal Police Station, PCPT John Carlos
Ornales personally appear and visited me in Malvar Police Station and
left the subject motor vehicle (Toyota Vios);
20. PCPT John Carlos Ornales told me that if he could left his car (Toyota
Vios) and also if I could help him to sell it;
21. I trusted PCPT John Carlos Ornales being classmate and considered
him a close friend, hence I did not bother to inquire anything about the
said Toyota Vios and let him to parked it beside the Malvar Police
Station;
22. Under the circumstances, I never took the subject motor vehicle without
consent by means of violence or intimidation of persons, nor force upon
things. As PCPT John Carlos Ornales personally left the subject motor
vehicle. I also have no knowledge nor did I presume that it was hot car.
If I ever had the knowledge I will not let him parked it in Malvar
Municipal Police Station and will make proper report upon things;
23. I re-attest that I have no clue whatsoever of the exact condition of the
subject motor vehicle. Had I known that It was a hot car, I will not
display it in besides the Malvar Police Station;
24. With respect to the charges of Kidnapping and Serious illegal
Detention, I vehemently deny the charges based on the following facts
and circumstances;
25. I have never met and personally don’t know the person who is
abducted;
26. On the time and date of the incident I was in Batangas Provincial Police
Office doing my duty as I was assigned in Provincial Intelligence
Branch.
27. I am executing this counter affidavit to attest to the truthfulness and
veracity of the foregoing statements to deny and disapprove the
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allegations in the charges for violation of the Kidnapping and Serious
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Illegal Detention, New Anti Carnaping Law and Conduct Unbecoming of
a Police Officer.
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