Republic of the Philippines

OFFICE OF THE EXECUTIVE JUDGE

Regional Trial Court
Makati city

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus - SW NO: _________________________

FOR: Violation of R.A. 10591
(Comprehensive Firearms and Ammunitions
Regulation Act]

TOO CHWAN JIE

Unit 716 Jazz Residences Tower 3
N. Garcia St, Barangay Bel-Air
Makati City
Respondent,
x-------------------------------------------x

Republic of the Philippines)

City of Makati ) S.S
x - - - - - - - - - - - - - - - - - x)

AFFIDAVIT

I, PMAJ GIDEON T INES JR, of legal age, married, active member of the
Philippine National Police and presently designated as Chief, Station Investigation and
Detective Management Section, Makati City Police Station, Southern Police District,
NCRPO located at Ayala Avenue Ext., corner Yakal St., Makati City, after having been
duly sworn to, in accordance with the law do hereby depose and state;

1. On June 2, 2019 at about 1:30 pm, Romulo Ventura Najito, 71 years old, former
enlisted personnel of the AFP, and presently residing at 504 Valentine St., Palar Village,
Taguig City personally appeared to this police station and reported the alleged illegal
possession of firearm and some unlawful activities of Too Chwan Jie, Malaysian national,
33 years old, and a residence of Unit 716 Jazz Residences Tower 3, located at N. Garcia
St., Barangay Bel-Air, Makati City. Since Romulo Najito is known for me as former
enlisted personnel of the AFP and sometimes utilized by the SIDMS as an asset in
Barangay Palar, Taguig City and some barangays in Makati City, his information given
to the undersigned was subjected for scrutiny to determine its veracity.

2. The undersigned subjected Romulo Najito for investigation wherein he

revealed the name of Too Chwan Jie, alleging that he possessed unlicensed caliber 45
firearm. He revealed that Too Chwan Jie, have in his possession and control one (1)
caliber 45 pistol and several ammunitions of the same caliber inside his condominium
unit and his private vehicles parked within the premises of the condominium.

3. Wherefore, with this information given by Romulo Najito supported by Summary

of Information (SOI) of the suspect, pictures and sketch of the location of the place where
the subject firearm was being kept, among others, has reason to believe that suspect
Too Chwan Jie, residing at Unit 716 Jazz Residences Tower 3, located at N. Garcia St.,
Barangay Bel-Air, Makati City, had in his possession and control the above-described
firearm, that is contrary to law;
4. That I am executing this Affidavit to attest to the veracity of the facts taken
above and for the purpose of supporting the application of Search Warrant;
 AFFIANT FURTHER SAYETH NAUGHT:

IN WITNESS WHEREOF, I have hereunto set my hand this ____ day of June
2019 at Makati City.

PMAJ GIDEON TANGAN INES JR

Affiant

SUBSCRIBED AND SWORN TO before me this _____ day of June 2019 here
at Makati City, Philippines.

__________________________________
Executive Judge

.
 Republic of the Philippines
OFFICE OF THE EXECUTIVE JUDGE
Regional Trial Court
Makati city

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus - SW NO: _________________________

FOR : Violation of RA 10591
[Comprehensive Firearms and
Ammunitions Regulation Act]

TOO CHWAN JIE

Unit 716 Jazz Residences, Tower C.,
Nicanor Garcia St., Brgy Bel-Air, Makati City
Respondent,
x-----------------------------------------x

DEPOSITION OF WITNESS

Ako si, Romulo Najito y Ventura, 71 taong gulang, dating sundalo at

kasalukuyang nakatira sa 504 Valentine St., Palar Village, Taguig City ay sumumpa ayon
sa ating saligang batas na magsasabi ng mga sumusunod:

TANONG1 : Sabihin mong muli ang iyong pangalan?

SAGOT1 : Ako si Romulo Ventura Najito

T2 : Kilala mo ba si PMAJ GIDEON T INES JR? ang aplikante ng Search

Warrant na ito?
S2 : Oo sir, siya ang hepe ng CID ng Makati City Police Station na matatagpuan
sa Ayala Avenue Ext., cor. Yakal St., Makati City;

T3 : Alam mo ba ang lugar na Unit 716 Jazz Residences Tower 3, Nicanor

Garcia St., Barangay Bel-Air, Makati City?
S3 : Oo sir, yan po isang condominium.

T4 : Kilala mo ba kung sino ang nagmamay-ari ng nasabing bahay sa address

nayan?
S4 : Oo sir, bahay ni Too Chwan Jie na dati kong kaibigan at katrabaho.

T5 : Mayroon ka bang personal na kaalaman na si Too Chwan Jie ay nag

iingat ng mga baril?
S5 : Oo sir.

T6 : Alam mo ba kung anong klaseng baril ang itinatago ni Too Chwan Jie sa
kanyang condo?
S6 : Isang pong colt caliber 45.

T7 : Paano mo natiyak na caliber 45 ang baril ni Too Chwan Jie?

S7 : Kasi alam ko lahat ang ibat-ibang uri ng baril at alam ko din kung ano ang
mga brand dahil isa akong retiradong sundalo.
T8 : Paano mo natiyak na may itinatagong baril si Too Chwan Jie at saan
Nakalagay ito?
S8 : Nakita ko po mismo doon sa loob ng condo ni Chwan ang nasabing
baril na nakalagay sa isang closet sa loob ng kanyang condo at minsan
dala-dala niya ito sa loob ng kanyang sasakyan na Toyota Vios color gray
na may plakang NDG 1022 at Mazda na kulay asul na may plakang
006303.

T9 : Papaano mo naman nalaman na ang iyong binanggit na mga baril ay

pinag- iingatan ni Too Chwan Jie?
S9 : Ganito po, palagi akong pumupunta sa condo nila Too Chwan Jie dahil ito
ay matagal ko nang kakilala at kasama sa trabaho at sa akin niya ito
pinapatago kapag siya ay lumalabas ng bansa. Nakikita ko na inilalabas ni
Too Chwan Jie ang kanyang baril kapag bumibisita ako sa kanyang condo
at minsan ito ay dinadala niya kapag siya ay umaalis ng condo. Matagal
ko nang kakilala si Too Chwan Jie kaya alam na alam kong may baril siya
na nakatago sa loob ng kanyang condo na nakalagay sa loob ng closet ng
cabinet sa loob ng kanyang condo.

T10 : Kailan at saan mo naman huling nakitang may baril si Too Chwan Jie?
S10 : Huling kong nakita ang baril ni Too Chwan Jie sa loob ng kanyang condo
noong bumisita ako sa kanya nito lamang May 31, 2019.

T11 : Sa anong dahilan naman at nagbibigay ka ng iyong salaysay.

S11 : Upang maisyuhan ng Search Warrant ng hukuman ang condo ni Too
Chawn Jie sa Unit 716 Jazz Residences Tower 3, N. Garcia St., Barangay
Bel-Air, Makati City at ang kanyang nasabing mga sasakyan.

AFFIANT FURTHER SAYETH NAUGTH:

ROMULO NAJITO Y VENTURA

(Deponent/Affiant)

SUBSCRIBED AND SWORN to before me this ____ day of June 2019 at Makati
City. Likewise, I have personally examined the affiant and I am fully satisfied that the
affiant voluntarily executed and understood his foregoing affidavit.

____________________________________
(Executive Judge)
 Republic of the Philippines
Philippine National Police
National Capital Region Police Office
Southern Police District
MAKATI CENTRAL POLICE STATION
STATION INVESTIGATION SECTION
Ayala Ave., Ext. cor. Yakal St., Makati City Tel. 843-7522

OFFICE OF THE EXECUTIVE JUDGE

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus - SW NO: ________________________

FOR : Violation of R.A. 10591
[Comprehensive Firearms and
Ammunition Regulation Act]

TOO CHWAN JIE

Unit 716 Jazz Residences Tower 3
N. Garcia St., Barangay Bel-Air, Makati City
Respondent.
x-----------------------------------------x

APPLICATION FOR SEARCH WARRANT

COMES NOW, the undersigned applicant, PMAJ GIDEON T INES JR, active
member of the Philippine National Police, presently assigned at the Makati City Police
Station, Makati City and designated as Chief, Criminal Investigation Section, after having
been duly sworn to in accordance with the law states, that:

1. I am the applicant in applying for a Search Warrant on the premises of Too

Chwan Jie, located at Unit 716 Jazz Residences Tower 3, N. Garcia St., Barangay Bel-
air, Makati City and occupied by the same person;

2. The undersigned strongly believes upon perusal and evaluation of the

statement and pieces of evidence submitted by Romulo Najito y Ventura, that Too
Chwan Jie had been reportedly concealing and is in possession of firearms and
ammunitions which is a violation of R.A. 10591 (Comprehensive Firearms and
Ammunition Regulation Act);

3. The premises owned/occupied by Too Chwan Jie located at Unit 716 Jazz
Residences Tower 3, N. Garcia St., Barangay Bel-Air, Makati City and his two (2) vehicles
described above which were park at the Jazz Residences parking area, have the following
items, which could be used and/or intended to be used in the commission of an offense
and that could be a threat to other constituents. Among the items under the custody,
possession and/or control of Too Chwan Jie, Owner/Occupant of the above-mentioned
address are kept and/or stored at the above mentioned premises, particularly in his
drawer situated on his living room inside the condominium and in his private vehicles
described as Toyota Vios E color gray with plate number NDG 1022 and Mazda color
blue with temporary plate number 006303 of the subject person to wit:
 a. One (1) caliber .45 with several ammunitions of the same caliber

4. All the above-described articles and objects are kept and concealed in the
above-given address and sometimes at the above-described vehicles of the respondent
was seen by deponent Romulo V Najito.

5. In the deposition of witness, Romulo V. Najito stated that subject person has
caliber 45 firearms and several ammunitions of the same caliber described above and
are being kept inside his closet cabinet located inside the living room.

6. Hence the undersigned applicant believes that Too Chawn Jie, Owner
/Occupant of the house/premises located Unit 716 Jazz Residences Tower 3, located at N.
Garcia St., Barangay Bel-Air, Makati City is clearly violating R.A. 10591 (Comprehensive
Firearms and Ammunition Act).

7. The undersigned applicant respectfully attached the following annexes to

support this application, to wit:

Annex “A” - Application for Search Warrant;

Annex “B” - Certification and Verification;
Annex “C” - Deposition of Witness;
Annex “D” – Attached pictures of the respondent
Annex “E” - Sketch of the location of the subject
Annex “F” – Referral signed by Acting Chief of Police

In view of the foregoing, the undersigned has strong reasons to believe that a
SEARCH WARRANT should be issued to enable the undersigned to conduct a search
at the house/premises and vehicles of Too Chwan Jie and to take possession of the
above-mentioned properties to be brought before this Honorable Court.

PRAYER

WHEREFORE, PREMISES CONSIDERED, the undersigned prays to this

Honorable Court for the issuance of a search warrant authorizing him and his agents or
any peace officer, to search the premises described in his application at any time of the
DAY or NIGHT, and to seize the illegal FIREARM AND AMMUNITIONS that may be
found therein and bring to this Honorable Court, to be dealt with as the law may direct.

Respectfully submitted.

June ____, 2019, Makati City Philippines

PMAJ GIDEON T INES JR

Applicant

SUBSCRIBED AND SWORN to before me this ___ day of June 2019 in Makati
City, Philippines. I HEREBY CERTIFY that I have personally examined the applicant
and I am satisfied that he voluntarily executed the foregoing Application for Search
Warrant and that the allegations therein are true and correct of his own knowledge.

_________________________
Presiding Judge
 CERTIFICATION AND VERIFICATION

I, THE UNDERSIGNED, under oath, depose and say that:

1. I am the applicant in the above-entitled application for Search Warrant;

2. I personally caused the preparation of the foregoing application for Search

Warrant and have read its content and the allegations therein, which are
true and correct to my own personal knowledge and belief.

3. I further certify that (a) I have not therefore commenced or filed any
application for a Search Warrant involving the same issues in any court,
tribunal or quasi-judicial agency and to the best of my knowledge, no such
other application for Search Warrant is pending therein; (b) If there is such
other pending Application for Search Warrant, I will therefore inform this
Honorable Court of the present status thereof; (c) If I should thereafter learn
that the same and similar application for Search Warrant has been filed or
its pending , I shall report that fact within five (5) days there from to this
Honorable Court, wherein the aforesaid application for Search Warrant has
been filed.

PMAJ GIDEON T INES JR

Applicant
 Republic of the Philippines
Philippine National Police
National Capital Region Police Office
Southern Police District
MAKATI CENTRAL POLICE STATION
OFFICE OF THE CHIEF OF POLICE
Ayala Ave., Ext. cor. Yakal St., Makati City Tel. 843-7522

June 3, 2019

Hon. Elmo M. Alameda

Executive Judge
Regional Trial Court, Branch 150
Justice Hall, Makati City

Dear Executive Judge Alameda;

Greetings!

Respectfully referred to your Honorable Court for appropriate action is an application for
Search Warrant for Violation of R.A. No. 10591 (Comprehensive Firearms and
Ammunition Regulation Act).

The undersigned strongly recommends approval of its issuance to allow the applicant,
PMAJ GIDEON T INES JR, Chief, Criminal Investigation and Detective Management
Section, Makati City Police Station and his agents of the law to search the premises of
Unit 716 Jazz Residences Tower 3, located at N. Garcia St., Barangay Bel-Air,
Makati City owned or rented and controlled by herein respondent Too Chwan Jie
and to search the vehicles of the same respondent described as Toyota Vios E
with plate number NDG 1022 color gray and Mazda color blue with temporary plate
number 006303 which were park at the parking area of Jazz Residences.

This will enable them to take into custody and present to this Honorable Court the
articles, which is the subject of the search and to be dealt with the law.

The undersigned prays unto this Honorable Court most favorable action.

ROGELIO P SIMON
Police Colonel
Chief of Police
 Republic of the Philippines
Philippine National Police
National Capital Region Police Office
Southern Police District
MAKATI CENTRAL POLICE STATION
STATION INVESTIGATION AND DETECTIVE MANAGEMENT SECTION
Ayala Ave., Ext. cor. Yakal St., Makati City Tel. 843-7522

MEMORANDUM

FOR : Director, CSG

(Attn: Chief, FED)

FROM : Chief of Police, Makati CPS

SUBJECT : Request for Record Check

DATE : June 3, 2019

--------------------------------------------------------------------------------------------------------------------

1. This pertains to the application for Search Warrant of PMAJ GIDEON T INES
JR, Chief, SIDMS of this police station wherein after casing and surveillance, the target
of the SW named Too Chawn Jie, Malaysian National and a resident of Unit 716 Jazz
Residences Tower 3, N. Garcia St., Barangay Bel-Air, Makati City have found in his
possession one (1) caliber 45 with several ammunitions of the same caliber.

2. In this connection, respectfully request furnished this police station any

pertinent data/information of the above-named subject, if he legally owns a firearm.

2. Further request favorable action.

FOR THE CHIEF OF POLICE, PCOL ROGELIO P SIMON:

GIDEON TANGAN INES JR

Police Major
Chief, SIDMS