Republic of the Philippines

REGIONAL TRIAL COURT

9th Judicial Region
Branch 16
Zamboanga City

PEOPLE OF THE PHILIPPINES

Complainant,

-versus- CRIM. CASE NO. 98765

FOR: HOMICIDE

ISKO M. MORENO
Accused,

x--------------------------------------x

JUDICIAL AFFIDAVIT OF POLICE CORPORAL JONATHAN B.

PARREÑO

I, JONATHAN B. PARREÑO, of legal age, married, with address at

Brgy. Tetuan, Zamboanga City, after having been duly sworn to in accor-
dance with law, depose and state, that:

This examination is conducted and supervised by Prosecutor Nadiah

L. Kadu, at Zamboanga City Hall of Justice, Lustre, Zamboanga City,
Philippines;

I am answering the questions asked in this judicial affidavit, fully con-

scious that I am doing so under oath and that I may face criminal liability for
false testimony or perjury;

PURPOSE: This affidavit/testimony of expert witness JONATHAN B.

PARREÑO, is being offered in evidence to prove the following facts:

1. That he is the Investigator-On-Case (OIC) Duty Investigator in the

above-captioned case;

2. On January 5, 2025, around 3:00am, in response to his police duty to

investigate a shooting incident at the residence of the accused ISKO
M. MORENO, he found the victim VERANO V. CRUZ deceased on
the kitchen floor of the accused;
 3. That on the same date, the victim was later pronounced dead on ar-
rival at the Zamboanga City Medical Center;

4. He will identify the death certificate stating the death and cause of
death of the victim;

5. He will identify the firearm, a Glock-19 9mm caliber pistol bearing

serial no. 123456 recovered from the crime scene;

6. He will identify acknowledgment receipt by the PNP Crime Labora-

tory for the submission of the recovered firearm from the crime
scene;

7. He will identify the photocopy of his investigation notebook;

8. He will identify the acknowledgment receipt issued by the PNP

Crime Laboratory for the submission of the recovered two (2) bullet
casings from the crime scene;

9. He will identify the ballistics test request for the cross-matching on

the subject firearm and two (2) bullet shell casings from the PNP
Crime Laboratory;

10. He will identify the certified copy of LTOPF issued under the name
of the accused ISKO M. MORENO;

11. He will identify the paraffin test request to the PNP Crime Labora-
tory conducted on the accused Isko M. Moreno;

12. He will identify his judicial affidavit and his signature therein;

13. He will identify the accused ISKO M. MORENO in this case;

14. He will also testify on other matters which are material, relevant and
germane for which his testimony is being offered.

The questions asked and my corresponding answers thereto are as follows:

Q1: Please state your name, age, address and other personal circumstances
for the record.
A1: I am Pcpl Jonathan B. Parreño, 44 years of age, married and currently
residing at Brgy. Tetuan, Zamboanga City. I am the duty investigator who
responded to the scene of the crime on January 5, 2025 at 3:00am.

Q2: From which station did you receive the information about the incident
which took place on the day of?
A2: It was in Police Station 11, Ma’am where I was on duty as a police in-
vestigator.

Q3: Where did the shooting incident occur?

A3: It was in the residence of one Isko M. Moreno at Brgy. Baliwasan,
Your Honor.

Q4: From whom did you receive the report?

A4: From the first responder police officer, my colleague, police corporal
Patrick Jane.

Q5: What was reported by the first responder?

A5: He required the assistance of the Duty Investigator in the investigation
of the incident.

Q6: What happened next if any?

A6: I proceeded to the crime scene in which the first responder turned over
the crime scene to me.

Q7: What happened next if any?

A7: I then started to conduct our crime scene investigation as per proce-
dure.

Q8: And what does this procedure entail, Officer?

A8: I conducted a thorough assessment of the crime scene employing our
search procedures on the crime scene and interviewing possible witnesses.

Q9: What was the result of your assessment?

A9: I found the victim unresponsive on the kitchen floor of the accused.

Q10: Who was the victim?

A10: A certain Verano V. Cruz.

Q11: Who was this victim to the accused?

A11: Based on my inquiry from the Spouses Moreno, he is the employed
driver of the Spouses Moreno, ISKO and LANA.

Q12: What happened next, if any?

A12: The body of the victim was carted away in an ambulance to be
brought to the Zamboanga City Medical Center.

Q13: What happened next, if any?

A13: I later received report that the victim was dead upon arrival at the hos-
pital.

Q14: What report is this?

A14: I received the death certificate of the victim from the hospital.

Q15: If I will show you a death certificate stating the death of the victim,
would you be able to identify it??
A15: Yes, your honor.

Q16: I am showing you a death certificate bearing the name of one Verano
V. Cruz as the deceased, what is this in relation to the death certificate you
mentioned earlier?
A16: This is the same death certificate.

Manifestation – Your Honor, may we request that this death certifi-

cate be admitted into evidence as exhibit A.

Q17: What happened next after the victim was removed from the crime
scene?
A17: I did my vicinity search of the scene for any evidence we may gather.

Q18: And what evidence did you find, if any?

A18: I found two (2) bullet shell casings in the kitchen of the accused.

Q19: What happened next if any?

A19: I proceeded to gather these shell casings into an evidence bag, and
signed the plastic evidence bag with my initials JBP, date of 01/05/2025 and
my signature.

Q20: And what did you do after with these bullet shell casings?
A20: I turned these over to the PNP Crime Laboratory for the conduct of
ballistics test.

Q21: What happened next, if any?

A21: I was given an acknowledgment receipt for these.

Q22: If I will show you an Acknowledgement Receipt, would you be able to

identify it?
A22: Yes, your Honor. I have my signature there.

Q23: I have here the Acknowledgment Receipt from the PNP Crime Lab,
what is this in relation to the AR you mentioned earlier?
A23: This is the same AR, your Honor.

Q24: And whose signature is this at the bottom of the AR?

A24: It is my signature, Your Honor.
Manifestation – Your Honor, may we request the court to admit
this document/AR as exhibit B? May we also request that the signature
found at the bottom of this AR be admitted as exhibit B-1?

Q25: What else did you recover from the crime scene?
A25: I also found a firearm with no live bullets, in the cabinet under the
kitchen sink of the accused.

Q26: What happened next, if any,

A26: As per SOP, I first took a photographic capture of the firearm.

Q27: If I will show you a picture of this firearm, would be able to identify
the said picture of it.
A27: Yes.

Q28: How?
A28: Before taking a picture, I placed my police ID beside the firearm.

Q29: I have here a picture of a firearm, what is this in relation to the picture
you mentioned?
A29: This is the same picture. My ID is here captured in the photograph.

Manifestation - Your Honor, may we request the court to admit this docu-
ment as exhibit C?

Q30: Mr. Witness, can you tell us more about this firearm you recovered?
A30: Yes, your honor. Upon closer inspection, it was a Glock-19 9mm cal-
iber pistol bearing the serial number 123456, black in color with ridges on
the handle. There is also a silver finish on the bullet shell exit on top of the
firearm.

Q31: What did you do with this pistol?

A31: I marked/carved the bottom of the grip handle of the pistol with the let-
ter “X” using my Swiss pocket knife and thereafter placed the firearm in an
evidence plastic bag. I sealed the bag and marked the bag with the initial
JBP 01/05/2025 and signed the bag with my signature. I then noted this in
my investigation notebookbook.

Q32: If I will show you a photocopy of this investigation notebook page,

would you be able to identify it?
A32: Yes, your honor.

Q33: How, Mr. Witness?

A33: By my signature on the page.

Q34: I have here a photocopy of the investigation notebook page, what is

this in relation to the notebook page you mention?
A34: This is the same page. My signature is here.
Manifestation - Your Honor, may we request the court to admit this docu-
ment as exhibit D?

Q35: About this firearm you found in the kitchen of the accused on January
5, 2025, what was it again?
A35: A Glock-19 9mm caliber pistol.

Q36: If shown to you, would you be able to recognize the gun?

A36: I would be able to recognize it, your honor.

Q37: I would like to show you this gun. Will you please examine it? What
relationship does this gun have to the gun you said you found on the ac-
cused’s kitchen cabinet?
A37: It is the very same gun, your honor.

Q38: How are you able to recognize this as the very same gun?
A38: It has the same characteristics as the gun I found in the crime scene.
The serial number is the same 123456. It also has the same mark of “X” on
the bottom of the handgrip. It is the same serial number and the markings on
the evidence bag as I wrote in my investigation notebook.

Manifestation – Your Honor, may we request the court to admit

this gun/object evidence as exhibit E?

Q39: What happened next, if any?

A39: I turned over this gun to our PNP Crime Laboratory for the ballistics
examination and I was given a request receipt.

Q40: If I will show you a request receipt, how will you be able to identify it?
A40: By my signature therein.

Q41: I have here the RR, what is this in relation to the RR you mentioned
earlier?
A41: This is the same RR.

Manifestation – Your Honor, may we request the court to admit

this document/RR as exhibit F?

Q42: And whose signature is this at the bottom of the document?

A42: This is my signature

Manifestation - May we also request that the signature found at the bottom
of this RR be admitted as exhibit F-1?

Q43: What happened next, if any?

A43: I also coordinated with the FEO/Firearms and Explosive Office of the
PNP, which is the repository of all registered licensed firearms, through an
endorsement letter for the cross-matching of the firearm discovered at the
scene.

Q44: If I will show you the endorsement letter request, how will you be able
to identify it?
A44: I placed my name and signature as the requesting officer, your honor.

Q45: I have here the endorsement request letter, what is this in relation to the
ERL you mentioned?
A45: This is the same ERL.

Manifestation - Your honor, may we request that this ERL be admitted as

exhibit G, and his signature as G-1.

Q46: What happened next, if any?

A46: The result of the cross-matching on the gun found at the scene be-
longed to the herein accused, ISKO M. MORENO, based on the certified
copy of the LTOPF/License to own and possess firearm issued by the FOE
of the PNP.

Q47: If I will show you a certified copy of the LTOPF, will you be able to
identify it.
A47: Yes, the certified copy has my name as the requesting investigator.

Q48: I have here the certified copy of the LTOPF, what relation does this
have to the LTOPF you mentioned?
A48: It is the same, as my name is here.

Manifestation - Your honor, may we request that this LTOPF be admitted

as exhibit H.

Q49: After recovering the gun, what happened next, if any?

Q49: I proceeded to question the Spouses Moreno, Isko and Lana as to what
happened.

Q50: What happened next, if any?

A50: They refused to answer any of my searching questions.

Q51: What happened next, if any?

A51: I invited them to come with us to the police station for further investi -
gation.

Q52: What happened next?

A52: At the police station, I asked Mr. Isko Moreno if he was willing to sub-
mit himself for the conduct of a paraffin test on his person.

Q53: What happened next?

A53: He agreed to our request.
Q54: What happened next, if any?
A54: I prepared the paraffin test request and submitted it to the PNP Crime
Lab.

Q55: What happened next, if any?

A55: I brought the accused to our station’s crime lab where he submitted
himself to a paraffin test.

Q56: What happened next, if any?

A56: I was given a request receipt for the paraffin test.

Q57: If I will show you a request receipt, how will you be able to identify it?
A57: By my signature therein.

Q58: I have here the RR, what is this in relation to the RR you mentioned
earlier?
A58: This is the same RR.

Manifestation – Your Honor, may we request the court to admit

this document/RR as exhibit I?

Q59: And whose signature is this at the bottom of the document?

A59: This is my signature.

Manifestation- May we also request that the signature found at the bottom of
this AR be admitted as exhibit I-1

Q60: Mr. Officer, do you remember executing a judicial affidavit?

A60: Yes, your Honor.

Q61: And if shown to you would you be able to identify it?

A61: Yes, Your Honor. I placed my signature therein.

Q62: I have here a judicial affidavit executed by one Jonathan B. Parreño,

what is this in relation to the JA you mentioned earlier.
A62: This is the same JA.

Manifestation – Your Honor, may we request the court to admit

this JA as exhibit J?

And his signature found at the bottom of this JA as exhibit J-1.

Q63: Would you like to add anything?

A63: No, Your Honor.
IN WITNESS WHEREOF, I have hereunto set my hand this February 1,
2024.

Jonathan B. PArreño
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME this March 24, 2025 at

the City of Zamboanga, Philippines, affiant having exhibited to me his
Driver’s License bearing No. V02-09-479626, duly issued by the Land
Transportation Office, at Zamboanga City.

NADIAH L. KADU
City Prosecutor of Zamboanga City

Republic of the Philippines)

City of Zamboanga )s.s.
X-----------------------------------X

ATTESTATION CLAUSE

I, JONATHAN B. PARREÑO, of legal age, single, Filipino citizen, and

with an office address at Hall of Justice, Zamboanga City, Philippines, do
hereby depose and state, that:

1. I faithfully recorded or caused to be recorded the questions asked

and the corresponding answers that the witness gave in accordance
with Section 4 of A.M. No. 12-8-8-SC otherwise known as the Ju-
dicial Affidavit Rule.

2. Neither I nor any other person then present or assisting with the
above-stated Judicial Affidavit coached the witness regarding the
answers given by the latter.

3. I am executing this Affidavit to attest to the authenticity, genuine-

ness, and veracity of the facts laid down in the above Judicial Affi-
davit of the petitioner for whatever legal purpose it may serve
within the boundaries set forth by law.
IN WITNESS WHEREOF, I have hereunto affixed my signature this March
24, 2025 in the City of Zamboanga, Philippines.

NADIAH L. KADU
City Prosecutor of Zamboanga City
Roll No. 694201 – 3/22/2022