Republic of the Philippines

Department of Justice
OFFICE OF THE CITY PROSECUTOR
Olongapo City

_______________,
Complainant,

- versus - NPS No.: III-10-INV-15K-

_____________,
Respondent.
x--------------------------------x

REPLY-AFFIDAVIT
I, _________________, 23 years old, Filipino citizen, single,
unemployed, and resident of _____________, Agusan del Norte,
under oath, hereby depose and states that:

1. All the allegations of the respondent in his counter

affidavit dated January 14. 2016 are nothing but misplaced assertions
and product of his imagination which are without bearing on the
instant complaint with the obvious purpose of suppressing the
truthful facts surrounding this case.

2. Paragraphs 2 to 6 of the counter affidavit, including the

annexes mentioned therein, are hereby DENIED for lack of personal
knowledge of the facts surrounding the counter allegations therein.
Herein complainant is not a privy to any of the transactions that
arose between the respondent and Mr._______ concerning the
management and operations of ________________., the
complainant not being a director or shareholder of the company.

3. Paragraphs 6 and 7 are hereby DENIED for lack of

knowledge or information sufficient to form a belief as to the truth
thereof. As stated in the complaint-affidavit, the undersigned have
already relocated to her hometown in _______, Agusan del Norte as
of January 2015, thus, it is physically impossible for her to have
attended the said board meeting on February 11, 2015 wherein she
was allegedly elected as the corporate secretary. Besides, the
undersigned did not give her consent and approval to be elected as
corporate secretary. If ever, it was the respondent in his capacity as
president of ____________. who devised such a scheme and the
only person who is in a position to do the same. If ever there was a
board meeting that took place on the said date as alleged in the said
paragraphs, the undersigned has no participation at all in the said
meeting.

4. Paragraph 8 is strongly DENIED for lack of knowledge or

information sufficient to form a belief as to the truth thereof. Roy
Anderson did not give a copy of the questioned Secretary’s Certificate
for me to sign. As previously stated, I already relocated to Agusan
del Norte beginning January 2015, thus, it is highly improbable that
the undersigned will be dismissed from the said company when as
early as January 2016 she is no longer connected with
____________, Inc. and have not been performing the functions of a
corporate secretary. Thus, how can a person be dismissed when she
has already left and resigned from her previous post? In fact,
respondent himself stated in his counter affidavit that “I presumed
it was her signature”, evidently, respondent did not see me sign
the said document.

5. Paragraphs 9 and 10 are vehemently DENIED for lack of

knowledge or information sufficient to form a belief as to the truth
thereof. Herein affiant was not prevailed upon by Mr. ____________
or any person for that matter in filing the present complaint. What
moved the undersigned to institute this criminal action against the
respondent is the latter’s blatant disregard and disrespect of her
rights as a person just to satisfy his (______) greed for money and
lust power at the expense of the complainant. If ever the
respondent and ________ who are now engaged in a legal tussle
involving the control and management of _____________, Inc., that
matter and that controversy is only between the two of them. The
undersigned is not a privy to the affairs of _________, Inc and the
said legal dispute to wrest ownership of ________ has nothing to do
with the forged signature in the secretary’s certificate.

6. Paragraph 11 is vehemently DENIED for lack of

knowledge or information sufficient to form a belief as to the truth
thereof. _________ and the undersigned are not engaged in an
amorous relationship. In his desperate attempt to save himself from
possible prosecution, respondent concocted a story fit only for the
movies and even came up with a dubious and questionable facebook
account. In this advance age of technology, it is no longer a secret
that anybody who is knowledgeable with computers and the internet
can easily create an account with social media facebook, even a
bogus account in order to annoy and pester a known target.

7. Paragraph 12 is hereby DENIED for lack of knowledge or

information sufficient to form a belief as to the truth thereof. He

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undersigned is not a director or a shareholder or an officer in charge
of the day to day financial operations of _____________, Inc.
relative to the issuance of the vouchers marked as Annexes 8.
Moreover, it is not a question of whether or not the respondent
gained nor benefitted therefrom, but more importantly, the forged
signature in the questioned secretary’s certificate paved the way for
the respondent to open an account with Unionbank. The issue at
hand is whether or not the signature of the undersigned was forged
in the secrtary’s certificate, not of how the money and profit derived
from the operations of Scootz was actually spent. Good faith is not a
defense.

8. Curiously and a profound matter of interest is the fact that

none of the Board Resolution attached to the respondent’s counter-
affidavit is supported by any secretary’s certificate confirming and
certifying that on the date/s appearing on the said resolution, a
board meeting (i) actually took place; (ii) that a quorum was
present; and (iii) a resolution was passed and unanimously
approved by the board of directors.

9. The rest of the allegations in the respondent’s counter-

affidavit are hereby denied, the truth of the matter are those alleged
in my verified complaint-affidavit.

10. Finally, the matters raised in the respondent’s counter

affidavit as well as the documents attached thereto are all evidentiary
in nature and that the truth surrounding the same can best be
threshed out in a full blown trial.

11. In support of this reply-affidavit, attached as Annexes A &

B, respectively, is the Affidavit of __________ together with the Joint
Affidavit of _________, __________________ and
____________________ forming integral parts hereof.

12. I am executing this Reply-Affidavit to attest to the truth

and veracity of the facts above narrated and to substantiate the
allegations stated in my Complaint-Affidavit against the above named
respondent.

______________
Affiant-Complainant

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 SUBSCRIBED AND SWORN TO before me this
________________ at Olongapo City, Zambales, as competent proof
of her identity, affiant exhibited to me her Philhealth ID numbered
07-________-3.

I hereby certify that I personally examined the affiant and I am

satisfied that she understood the contents of her reply-affidavit and
that she freely and voluntarily executed the same.

_____________________
Associate City Prosecutor

Copy furnished: (By Registered Mail)

________
________
Bo. Barretto, Olongapo City