By Jeffrey Damicog Former Health Secretary Paulyn Jean Rosell-Ubial has denied allegations cited in a criminal complaint against her that she should be held liable for the deaths of children inoculated with Dengvaxia. Former Health Secretary Pauline Jean Ubial (Photo courtesy of alamy.com | Manila Bulletin) “I deny these false and unfounded accusations,” read her counter-affidavit filed before Assistant State Prosecutor Claire Eufracia Pagayanan who is conducting the preliminary investigation of the complaint filed by former Health Secretary Janette Garin. In the complaint, Garin accused Ubial of having committed reckless imprudence resulting to homicide under Article 365 of the Revised Penal Code (RPC). Garin said the Department of Health (DOH) implemented a school-based dengue immunization program but, when Ubial took over, there was a reckless decision to have it expanded into a community-based program which resulted to the reported deaths. In her counter-affidavit, Ubial said “complainant Garin utterly fails to establish probable cause that would warrant the filing of a criminal case for reckless imprudence resulting to homicide.” “Hence, the Complaint-Affidavit must be dismissed outright,” she urged. Ubial pointed out Garin “merely surmises that the implementation of the Community-Based Dengue Immunization Program ‘may have’ contributed to ‘alleged reported deaths’.” “It does not allege, much less prove through any piece of evidence, the factual circumstances surrounding said alleged deaths. To repeat, probable cause demands more than bare suspicion and must rest on competent relevant evidence,”Ubial said. “Thus, even assuming that the alleged reported deaths occurred, the Complaint-Affidavit should nevertheless be dismissed outright because it fails to establish the said deaths were caused by Dengvaxia administered during the Community-Based Dengue Immunization Program,” she added.