REPUBLIC OF THE PHILIPPINES) S.S.

VALENZUELA CITY )
X---------------------------------------------X

JOINT COUNTER AFFIDAVIT

THAT WE, RODRIGO S. RACAL JR., GLEN CAREL, GAYE QUISAY,

REI DE TORRES and DANDI DAGATAN all with office address at Room 2006 2nd
Floor, Felicidad Bldg, Mac Arthur Highway, Karuhatan, Valenzuela City, all Filipinos,
of legal ages, after having been duly sworn to in accordance with law, hereby
depose and say:

That we are presently being charged by CANDIDA D.R. BARCO for Art.
315 2 (a) of the RPC (Syndicated per PD 1689), and Violation of Anti Money
Laundering Act of 2001, docketed as NPS Docket No. XV-17-INV-191-971 of the
City of Prosecutor’s of Valenzuela City;

That we vehemently deny the imputations against us by said complainant

embodied in his complaint affidavit dated September 13, 2019 for lack in basis in
fact and in law, the truth being as follows:

1. GLENRICH TRADING with office and business address at Room 206,

2nd Floor, Felicidad Bldg. Mac Arthur Highway, Karuhatan, Valenzuela, is duly
registered with the Department of trade and Industry way back August 6, 2018 as
shown by the document issued by said office hereto attached as “Annex 1” and
made integral part hereof affiant Rodrigo Solis Racal Jr. ( RACAL ) it’s sale
propreitorship although with sales speaker led by complainant, Julio Diaz, Rose
Cunanan, Kevin Alapar and Sophia Eugenio.

2. GLENRICH sells food supplement and as part of the Marketing Plan

ans strategies GLENRICH has different packages with equivalent prices to the
products as follow:

A. Starter Package - 1,500.00 - 6 Gaviola Juices

B. Bronze Package - 4,500.00 - 18 Gaviola Juices
C. Silver Package - 10,500.00
D. Gold Package - 22,500.00
E. Platinum - 46,500.00
F. Sapphire - 94,500.00
G. Ruby - 190,500.00

All said packages have equivalent products which they receive for the
Marketing purposes. Several incentives programs were also put up by GLENRICH
such as:
A. Dynamic Pool Bonus here GLENRICH share it’s income to distributor
B. Direct Referral Bonuses
C. Pairing Bonus
D. Unilevel Bonus

Which just like other business practices GLENRICH gives incentives from it’s
income; this shown by several distributor who have already paid out more than their
account specially the Core Leaders of GLENRICH led by complainant, Julio Diaz,
Sophia Eugenio and several others;

That part of GLENRICH’s program as bonuses include a dynamic pool where

after second purchase, the purchases receives the amount depending upon the
package purchased. However, due to business reverses, GLENRICH was not able
to give said bonus and herein affiant RACAL would like to deeply apologize in this
matter to all concerned. He will exist his very best efforts to comply with this within a
reasonable period of time;

E. As for respondent GLENN CAREL (CAREL) he is a member of GLENRICH and

friend of it’s owner and co-respondents RACAL. As much he voluntarily helps it’s
company activities like seminars, office works and als0 sells products, and received
payments which he remits to the owner,

F. As for REI DE TORRES (DE TORRES) as member of GLENRICH. She also

purchased the package offered by the company with a promise to receive a bonus
from the dynamic pool within (2) months. She goes to the office of GLENRICH as a
volunteer without salary and time reporting. As a member, she is concerned with her
investment and also receives payments from customers which she remit and before
leaving the office to co-respondent CAREL.

G. Affiant respondent DANDI L. DAGATAN (DAGATAN) was merely invites as

“SPEAKER” by co-respondent CAREL who is his friend. He is not involve in the
operation of GLENRICH with it’s new program which did not materialize. He did not
attend any seminar at GLENRICH did not receive any payment there from and he is
not a member of said company;

H. As for GAYE QUISAY was also a member of GLENRICH on December, 2018 she
was invited by RACAL to join. She also purchased package offered by the company
with a promise to receive Dynamic Pool Bonus within (2) months and reward from
direct referrals and pairing binary. She had many purcng Act of 2001hased
GLENRICH under the name of her family and friends she used her own money to
purchase packages. She goes to the office and receives payments which she remits
and before leaving the office to co-respondents CAREL;

That the transaction between complainant and GLENRICH is purely a

business transaction. There could be no defraudation or money laundering;

That just like other business, the delayed return of promised income to one’s
investments like in complainant’s case could not be defraudation or money
laundering;

That is very clear from the foregoing representation were never employed by
respondents to complainant to paid with his money. GLENRICH is a business duly
registered with the government and was making good when complainant made her
investment. However in the natural course of events, business showed down and
promised returns had as yet to be completed with. It is a fact that respondent
RACAL also suffered under the situation and much more than any member like
complainant;

Under Section 4 of the Anti-Money Laundering Act of 2001, it provides that

“Money Laundering is committed by any other person who is knowing that any
monetary instrument as property represents, involves as related to the proceed of
any unlawful activity” However as clearly shown all the activities of GLENRICH a
legal entity are in accordance with law and the money involve are the proceeds of
unlawful activities;

That since there is no misrepresentation or deceit involve in the complainant’s

parting with his money and all transaction with GLENRICH there is no Estafa under
PD 1689 which involve illegal transaction resulting to misappropriation of funds
contributed by stockholders, as member of Rural banks, cooperative, samahan
nayon or former association or of funds solicited by corporation/stockholders from
the general public;
 That in view of all the foregoing, herein respondent/affiants respectfully pray
that the instant complaints against them be dismissed for lack of basis of facts and in
law.

IN WITNESS WHEREOF, we have hereunto set our hands this

_________________day of _________________ 2019 at Valenzuela City
Philippines.

RODRIGO S. RACAL JR. GLEN CAREL

Affiant Affiant

GAYE QUISAY REI DE TORRES

Affiant Affiant

DANDI DAGATAN
Affiant

SUBSCRIBED AND SWORN to before me this ______ day of

__________________ 2019.

Assistant City Prosecutor