REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
QUEZON CITY

_________________________,
Complainant,

-versus-
NPS: XV-03-INV-211-______
For: Qualified Theft

_________________________,
Respondent.
x--------------------- x

COUNTER-AFFIDAVIT

I, __________________, of legal age, with residence address at

______________________, and after having been duly sworn in
accordance with law, hereby depose and state that:1

1. I vehemently deny that I committed acts constituting

Qualified Theft as defined under Article 310, in relation to Articles
308 and 309, of the Revised Penal Code (“RPC”), as amended by
Batas Pambansa Blg. 71, as maliciously charged by private
complainant _________________ (“Complainant”), in her Complaint-
Affidavit dated 15 September 2021.

2. Complainant maliciously, albeit vaguely, accuses me of

committing the crime of Qualified Theft by alleging that I took
Complainant’s Hermes Kelly bag without her consent or knowledge,
which she voluntarily delivered to me on 16 January 2021. However,
in truth and in fact, there has been no unlawful taking or neither an
intent to gain on my part when I graciously accommodated her
request to have her bag authenticated. Prior to the filing of this case,
we are in the process of settling myriad of issues surrounding our
business venture including the return of the subject bag, when
suddenly Complainant came up with incredible and baseless
accusations against me of committing fraudulent acts against her.

3. These accusations prompted me to become more vigilant

in dealing with her, including a request to Complainant that a
1
In the Subpoena, the Honorable Prosecutor ordered me to file my Counter-Affidavit on 16
November 2021. Hence, this Counter-Affidavit is timely filed.

1
proper accounting be made of all the transactions we had and a
written acknowledgment on her part of all the items that will be
returned to her including the subject bag to which Complainant
acceded to. Unfortunately, however, and to my utter surprise
Complainant filed this case and made incredible and baseless
accusations against me on matters that could have been addressed
amicably. Complainant resorted to outright exaggerations and
blatant lies in her Complaint-Affidavit without sufficient proof to
support her claim.

4. The charge against me is misplaced at best and as will be

further shown below, our relationship as business partners cannot, as
they should not be construed as unlawful, nor should my acts of
vigilance in requesting for proper accounting and written proof of
our settlement be punished. The accusations against me is without
basis in fact and in law. To illustrate why I am not, could not and
should not be held liable for allegedly committing Qualified Theft,
and/or any other crime or offense for that matter, the relevant facts
are as follows.

COUNTER STATEMENT OF FACTS

5. Complainant and I met around 7 years ago, or sometime

in the year 2014. During the seven (7) years that I have known the
complainant, we would jointly venture into transactions which
involves the buying and selling of luxury bags and other items. The
transactions in such agreed venture would normally follow the
foregoing arrangement:

a. I would buy luxury bags and I would advance for the

purchase price and cost of acquisition of these items.

b. I would then deliver the items to complainant for sale to

her client-buyers. We would agree on a certain purchase
price covering the cost of the bags plus an agreed profit
margin;

c. She will then offer for sale and sell the delivered luxury
bags to her own clients;

d. Complainant will pay me only after the item is sold and the
buyers pay her. The payment of the agreed price are
conditioned on the item being sold and payment received
from the buyers.

2
 6. We extended the scope of our venture together to include
selling luxury watches. The same terms and consignment
arrangement was generally applied and followed for the sale of the
luxury watches.

a. I would buy luxury watches and I would advance for the

purchase price and cost of acquisition of these items.

b. I would then deliver the items to complainant for sale to

her client-buyers. We would agree on a certain purchase
price covering the cost of the watches plus an agreed profit
margin;

c. She will then offer for sale and sell the delivered luxury
watches to her own clients;

d. Complainant will pay me only after the item is sold and the
buyers pay her. The payment and sharing of proceeds are
conditioned on the item being sold and payment received
from the buyers.

7. The consignment arrangement for the watches also

happens then other way around sometimes.

a. Complainant would buy or provide the luxury watches;

b. She would then deliver the items to me for sale to my client-

buyers. We would agree on a certain purchase price
covering the cost of the watches plus an agreed profit
margin;

c. I will then offer for sale and sell the luxury watches to my
own client-buyers;

d. Reciprocally, it is agreed that I will pay her only after the

item is sold and the buyers pay me. The payment and
sharing of proceeds are conditioned on the item being sold
and payment received from the buyers.

8. There are however times that an item is slow moving, or

due to circumstances beyond our control, such as the happening of
the Covid-19 pandemic, the items do not get sold immediately. In
times like these, we have the option of advancing the payment of the
same so that the one who owns it or advanced for it is not unduly
burdened.

3
 9. Sometime in September 2019, I purchased from an
Hermes Shop in Paris through my supplier Fadzaleen Shahida Binti
Ruslithe the subject Hermes Kelly bag with the intention to give it to
Complainant as an incentive for our previous successful business
transactions. Otherwise stated, the subject Hermes Kelly bag was
actually purchased by me, and came from me.

10. I paid the amount of Seven Thousand Four Hundred

Euros (€ 7,400) 2 or Five Hundred Thousand Pesos (Php 500,000) to
Fadzaleen Shahida Binti Rusli3 for the purchase of the subject Hermes
Kelly bag from the Hermes Shop in Paris . I also booked and paid
for the shipment of the bag from Kuala Lumpur, Malaysia to the
Philippines.4 Thereafter, upon receipt of subject Hermes Kelly bag 5, I
handed it over to Complainant.6

11. Complainant was so happy to receive her “dream bag”

from me. 7

“Stephanie: I am SO HAPPY with my bag

Stephanie: I cry
Stephanie: Thank you for making my dream come true
hahahhaahha
Monica: Nakuha mo na?
Monica: Nakita mo na I mean?”

12. Sometime in March 2020, lockdown was imposed by the

Government due the surge of Covid-19 cases in Metro Manila. The
subsequent lockdowns had a negative impact on our business and
since most of our items were sourced overseas, shipments were
delayed, thus, items were not sold immediately.

13. Complainant was able to use the subject Hermes Kelly

bag for a couple of months before she decided to want to sell it
sometime January 2021. Prior to selling it, she however felt paranoid
that there seem to be a variance in the padlock of the subject Hermes
Kelly bag and another Hermes Kelly bag of another friend she had.

14. Thus, despite having a receipt from Hermes Shop in

Paris, she requested me if I can help her have it authenticated with an

2
A copy of the Receipt of the Hermes Bag is attached as Annex “A”
3
A screenshot copy of the Bank Transfer Transaction is attached as Annex “B”.
4
A copy of the Travel Itenerary is attached as Annex “C”.
5
Picture of the Hermes Kelly Bag is attached as Annex “D”.
6
Screenshots of whatsapp conversation are attached as Annexes “E” to “E-11”
7
See Screenshos of whatsapp 10 March 2020 conversation attached as Annexes “E-3”

4
authenticator we know Ms. Sally Lugtu. As a friend, and as the one
who gave it to her, I accommodated her request for help.

15. She asked me to have the Hermes Kelly bag picked up

from her place in Quezon City. In coordination with her, I booked
the Grab service from my house in Alabang, Muntinlupa City, to pick
up from her house in Quezon City. Complainant voluntarily handed
the Hermes Kelly bag to the Grab delivery rider. The Grab delivery
rider then delivered the Hermes Kelly bag to me in Alabang,
Muntinlupa City.

16. It is worthy to note that she voluntary turned over the

possession of the Hermes Kelly bag to me not as an employee, not
as an agent, not even pursuant to a business transaction we were
handling, but as friend who will assist her get an authentication.
There definitely was no unlawful taking to talk about. She herself
admits that there was no unlawful taking and that possession was
voluntarily transferred in Paragraph 7 and 8 of her complaint
affidavit.

15. I immediately sent the Hermes Kelly bag to Sally the

authenticator to check its authenticity. She confirmed that the
Hermes Kelly bag was authentic. Sally thereafter sent back the bag to
me.

16. There is no truth that I refused to return the Hermes Kelly

bag to complainant. I have no intentions of gaining or making profit
from it. I never even attempted to use, appropriate, or sell it. I had
offered to return it to the complainant on several occasions but I
asked her that she should simultaneously issue me an
acknowledgment receipt that she received the bag at the same time I
returned it.8

“ _________: Ung Kelly mo? Babalik lang pag binalik

magacknoledge ka?

_________: Dbale na. If u want ur way, ed so be it.

__________: I want in my way? Di naman ganun e

___________: Anong babalik lang pag binalik?

__________: Bbalik lang syo pag binalik iaacknowledge mo?

Bawas listahan”
8
Copy of the conversation requesting that Complainant Acknowledge the return of the
subject bag is attached as Annex “F”.

5
 17. Between April 2021 up to the time prior to the instant
case, complainant and I had a few misunderstanding but were in the
process of reconciling or accounting for the items or funds
respectively in our possession. In fact, sometime in April 2021, a
supplier named Elga, whom both Complainant and I knew,
deposited to the Complainant in two installments the amount for the
partial refund of an Hermes Birkin bag intended for me in the
amount of One Million Two Hundred Thousand Pesos
(PHP1,200,000.00). The Complainant acknowledged and confirmed to
me the receipt by her of the said amount from Elga. 9 Complainant
however did not remit the amount of One Million Two Hundred
Thousand Pesos (PHP1,200,000.00) back to me. She also took
possession of several items in our inventory but refused to
acknowledge the same after her receipt.

18. Because of the above incidents, and the distrust that was
slowly growing between us, I told complainant that I was ready to
return the Hermes Kelly bag on several occasions but I demanded
that an acknowledgment receipt be simultaneously issued to
properly document my return of the same.

19. Complainant was well aware that I was ready and willing
to return the Hermes Kelly bag, I was just asking for the proper
documentation. In fact, complainant and I were in the middle of
reconciling our respective accounts and what we owe each other, and
the return of Hermes Kelly bag was part of the discussion.

20. However, in the middle of discussions, I was surprised to

find out that complainant, in bad faith, filed series of cases including
this case. Complainant was even threatening members of my family
by sending the messages even though they had nothing to do with
this transaction.10

21. Hence, this Counter-Affidavit.

22. Counsel advised that the crime of Theft as found under

Article 308 of the Revised Penal Code may be committed as follows:

ART. 308. Who are liable for theft. — Theft is committed by

any person who, with intent to gain but without violence,
against, or intimidation of neither persons nor force upon
9

10
Screenshots of the messages threatening members of my family are attached as
Annexes “G” to “G-1”.

6
 things, shall take personal property of another without the
latter's consent.

Theft is likewise committed by:

1. Any person who, having found lost property, shall fail to

deliver the same to the local authorities or to its owner;

2. Any person who, after having maliciously damaged the

property of another, shall remove or make use of the fruits or
objects of the damage caused by him; and

3. Any person who shall enter an enclosed estate or a field

where trespass is forbidden or which belongs to another and
without the consent of its owner, shall hunt or fish upon the
same or shall gather fruits, cereals, or other forest or farm
products.

23. Counsel also advised me that Article 310 of the RPC

reads:

ART. 310. Qualified Theft. — The crime of theft shall be

punished by the penalties next higher by two degrees than
those respectively specified in the next preceding article, if
committed by a domestic servant, or with grave abuse of
confidence, or if the property stolen is motor vehicle, mail
matter or large cattle or consists of coconuts taken from the
premises of a plantation, fish taken from a fishpond or fishery
or if property is taken on the occasion of fire, earthquake,
typhoon, volcanic eruption, or any other calamity, vehicular
accident or civil disturbance.

24. Stated otherwise, the essential elements of qualified theft

are as follows: (1) there was a taking of personal property; (2) the said
property belongs to another; (3) the taking was done without the
consent of the owner; (4) the taking was done with intent to gain; (5)
the taking was accomplished without violence or intimidation
against person, or force upon things; and (6) the taking was done
under any of the circumstances enumerated in Article 310 of the
RPC, i.e., with grave abuse of confidence.11

There is no cause or ground to charge the

respondent with Qualified Theft, as the
elements for the same do not exist.

11
Matrido v. People, 610 Phil.203, 214 (2009)

7
There is no unlawful taking, as
complainant voluntarily delivered the
possession of the subject item to me.

25. As admitted by Complainant in her Complaint Affidavit

dated 15 September 2021, sometime in January 2021, Complainant
requested from me that the bag I had given to her be authenticated.
Thus, on 16 January 2021 with Complainant’s knowledge and
consent the bag was voluntarily delivered to me for the foregoing
purpose. Clearly, there is no unlawful taking considering that
Complainant voluntarily delivered to me the subject bag.

25.1 Thus, despite having a receipt from Hermes

Shop in Paris, she requested me if I can help her have it
authenticated with an authenticator we know Ms. Sally
Lugtu. As a friend, and as the one who gave it to her, I
accommodated her request for help.

25.2 She asked me to have the Hermes Kelly bag

picked up from her place in Quezon City. In coordination
with her, I booked the Grab service from my house in
Alabang, Muntinlupa City, to pick up from her house in
Quezon City. Complainant voluntarily handed the Hermes
Kelly bag to the Grab delivery ride. The Grab delivery rider
then delivered the Hermes Kelly bag to me in Alabang,
Muntinlupa City.

25.3 There definitely was no unlawful taking to

talk about. She herself admits that there was no unlawful
taking and that possession was voluntarily transferred in
Paragraph 7 and 8 of her complaint affidavit.

26 I was advised by my counsel that a felonious taking may

be defined as the act of depriving another of the possession and
dominion of movable property without his privity and consent and
without animus revertendi (intent to return). Thus, an unlawful taking
takes place when the owner or juridical possessor does not give his
consent to the taking; or, if the consent was given, it was vitiated. 12 

27 Here, it cannot be denied Complainant’s assent to my

taking of the subject bag at the time she yielded the physical
possession thereof for the purpose of having it authenticated. Thus,
there is no basis in fact and in law that the element of unlawful taking
is present.
12
People of the Philippines v. Tan, G.R. No. 135904, 21 January 2000.

8
There has never been an intent to gain on my part.

28 Furthermore, as to the element of intent to gain Counsel

advised me that intent to gain or animus lucrandi, is an internal act
that is presumed from the unlawful taking by the offender of the
thing subject of asportation.

29 In this case, such intent is not present, since I always have

the intention of returning the bag which I previously gave to her.

29.1 There is no truth that I refused to return the Hermes

Kelly bag to complainant. I have no intentions of gaining or
making profit from it.

29.2 I never even attempted to use, appropriate, or sell it.

In fact, no such thing was alleged in the complaint.

29.3 I had offered to return it to the complainant on

several occasions but I asked her that she should
simultaneously issue me an acknowledgment receipt that she
received the bag at the same time I returned it.

30 It is absurd for Complainant to conclude that I had the

intention of gaining from allegedly taking a bag which I paid for,
made extreme efforts to have shipped to Manila, and handed to
complainant generously.

31 As explained, the reason why I have not completed the

return of the bag is because complainant has not agreed to document
my return of it. I suspect that complainant is giving me a difficult
time as a leverage for the other discussions and reconciliation we are
currently doing, including the subject matter of her appropriation of
a Php1.2 Million refund by Elga intended for me.

32 I am more than willing to do the physical delivery and

return of the Hermes Kelly bag before this Honorable Office as long
as there is proper acknowledgment and documentation of such
return lest my lack of documentation be used maliciously against me
again by the complainant.

The qualifying circumstances do not exist. I

am neither complainant’s employee, nor
domestic servant. Nor was nay unlawful
taking done with grave abuse of confidence.

9
 33 Despite having a receipt from Hermes Shop in Paris, she
requested me if I can help her have the bag I gave her authenticated
with an authenticator we know. I helped her as a friend, and as the
one who gave it to her. I accommodated her request for help.

34 It is worthy to note that she voluntary turned over the

possession of the Hermes Kelly bag to me not as an employee, not
as a domestic helper, not as an agent, not even pursuant to a business
transaction we were handling, but as friend who will assist her get an
authentication. There definitely was no unlawful taking to talk about.
Moreover, there was no absue of confidence.

35 In essence, I have always acted in good faith when I

maintained possession over the subject bag requesting for proper
documentation of my return. My counsel advised me that in common
usage, the term good faith is ordinarily used to describe that state of
mind denoting honesty of intention, and freedom from knowledge of
circumstances which ought to put the holder upon inquiry; an honest
intention to abstain from taking any unconscientious advantage of
another, even through technicalities of law, together with absence of
all information, notice, or benefit or belief of facts which render
transaction unconscientious.13

36 Moreover, good faith is actually a question of intention.

Although this is something internal, we can ascertain a person’s
intention by relying not on his own protestations of good faith, which
is self-serving, but on evidence of his conduct and outward acts14.

37 Our circumstances with respect to the subject Hermes

Kelly bag was a mere misunderstanding and is subject to an on-going
discussion of proper accounting of any sum of money that are still
due between the two of us, and that we properly document any off-
setting or payment via exchange of items.

38 Thereafter, due to the impatience of Complainant, she

filed this complaint alleging incredible and baseless accusations
against me and resorted to outright exaggerations and blatant lies.

The complaint must be dismissed

on the ground of improper venue .

13
Blacks Law Dictionary, sixth edition, 1990 at 693 (underscoring supplied), citing Efron vs.
Kalmanovitz, 249 Cal.App. 187, 57 Cal.Rptr. 248, 251; Leung Yee vs. Frank L. Strong
Machinery Co., 37 Phil. 644 (1918); Fule vs. Legare, 117 Phil. 368 (1963).
14
Gabriel vs. Mabanta, G.R. No. 142403, March 26, 2003, 399 SCRA 573.

10
 39 The complaint was incorrectly filed with the Office of the
City Prosecutor of Quezon City since the essential elements of the
alleged offense was committed in Alabang, Muntinlupa City.

40 As previously mentioned, Complainant asked me to have

the Hermes Kelly bag picked up from her place in Quezon City. In
coordination with her and pursuant to complainant’s instructions, I
booked the Grab service from my house in Alabang, Muntinlupa City,
to pick up from her house in Quezon City. Complainant voluntarily
handed the Hermes Kelly bag to the Grab delivery rider. The Grab
delivery rider then delivered the Hermes Kelly bag to me in
Alabang, Muntinlupa City. I only took possession, as voluntarily
handed by complainant to me through the Grab delivery rider, in
Muntinlupa City. The Hermes Kelly bag was handed to Sally Lugtu
from my residence in Alabang, Muntinlupa City and was likewise
returned in the same residence. Thus, all of the essential elements of
the alleged offense was committed in Muntinlupa City.

41 My counsel advised me that it is fundamental rule of

procedure that venue is an element of jurisdiction in criminal cases. It
determines not only the place where the criminal action is to be
instituted but also the court that has jurisdiction to try and hear the
case. A finding of improper venue in criminal cases carries with it
jurisdictional consequences.15

42 In this regard, it was palpable error for the Complainant

to submit her Complaint-Affidavit in the Office of the City Prosecutor
of Quezon City when the law clearly provides that it should have
been filed with the Office of the City Prosecutor of Muntinlupa City,
the place where the alleged taking was committed.

43 In light of the attendant facts and the context in which

this criminal complaint was maliciously filed against me, I implore
this Honorable Office to protect me from such baseless charges and to
dismiss the criminal complaint against me, outright. I am
disheartened that such acts are imputed against me, when I have
clearly done nothing wrong and I am simply relying on the
assumption that Complainant and I are threshing out our issues
amicably.

44 The present case filed against me is baseless with no other

purpose other than to harass, vex me and to pressure me to comply
with all her demands. Complainant have not presented any sufficient
nor credible evidence to substantiate her malicious claims against me
15
Section 15(a) of Rule 110, 2000 Revised Rules of Criminal Procedure.

11
aside from screenshots of conversations which were taken out of
context. It is settled that upon him who alleges rests the burden of
proof:16

“A complainant, who in effect accuses another person

of having committed an act constituting an election
offense, has the burden, as it is his responsibility, to
follow through his accusation and prove his complaint.
If the complainant fails to proffer the necessary
evidence to show probable cause… the complaint must
be dismissed.”17

45 Complainant miserably failed to discharge her burden of

proving that I committed the crime of Qualified Theft or any other
crime for that matter.

46 While it is true that “probable cause need not be based on

clear and convincing evidence of guilt, neither on evidence
establishing guilt beyond reasonable doubt and, definitely, not on
evidence establishing absolute certainty of guilt; but it certainly
demands more than bare suspicion and can never be left to
presupposition, conjecture, or even convincing logic.”18

47 In light of the attendant facts and the context in which

this criminal complaint was maliciously filed against me, I implore
this Honorable Office to protect me from such baseless charges and to
dismiss the criminal complaint outright.

48 According to my counsel, the following oft-repeated

admonition by the Supreme Court as held in Cabahug v. People of the
Philippines, et al.19 should be thus heeded:

“We cannot overemphasize the admonition to agencies

tasked with the preliminary investigation and
prosecution of crimes that the very purpose of a
preliminary investigation is to shield the innocent
from precipitate, spiteful and burdensome
prosecution. They are duty-bound to avoid, unless
absolutely necessary, open and public accusation of

16
See Albana et al. v. Belo, et al., G.R. No. 158734, October 2, 2009; Spouses Boyboy v.
Yabut, A.C. No. 5225, April 29, 2003; Angeles, et al., v. Figueroa, A.C. No. 5050,
September 20, 2005; Kilosbayan, Inc., et al., v. COMELEC, et al., G.R. No. 128054,
October 16, 1997.
17
See Kilosbayan, Inc., et al., v. COMELEC, et al., G.R. No. 128054, October 16, 1997.
18
See Gonzalez v. Hongkong & Shanghai Banking Corporation, G.R. No. 164904. October
19, 2007.
19
G.R. No. 132816, 5 February 2002, 376 SCRA 113.

12
 crime not only to spare the innocent the trouble,
expense and torment of a public trial, but also to
prevent unnecessary expense on the part of the State
for useless and expensive trials. Thus, when at the
outset the evidence cannot sustain a prima facie case
or that the existence of probable cause to form a
sufficient belief as to the guilt of the accused cannot
be ascertained, the prosecution must desist from
inflicting on any person the trauma of going through a
trial.”20

49 On a final note, I was informed by my lawyer that the

Supreme Court in Malana v. People of the Philippines,21 pronounced that
in criminal cases, the proof required is proof beyond reasonable
doubt and the burden of proving that a person is guilty beyond
reasonable doubt rests upon the prosecution, and absent the
establishment of the said quantum of proof, the accused must be
afforded his constitutional presumption of innocence and must be
acquitted. Thus:

“Rule 133, Section 2 of the Revised Rules on Evidence

specifies the requisite quantum of evidence in
criminal cases:

50 x x x

This rule places upon the prosecution the task of

establishing the guilt of an accused, relying on the

20
Ibid., at 133 citing Salonga v. Cruz Paño, et al., G.R. No. 59524, 18 February 1985, 134
SCRA 439, 461-462; emphasis and underscoring supplied.

21
G.R. No. 175842, 18 March 2015.

13
strength of its own evidence, and not banking on the
weakness of the defense of an accused. Requiring
proof beyond reasonable doubt finds basis not only
in the due process clause of the Constitution, but
similarly, in the right of an accused to be "presumed
innocent until the contrary is proved." "Undoubtedly,
it is the constitutional presumption of innocence that
lays such burden upon the prosecution." Should the
prosecution fail to discharge its burden, it follows, as
a matter of course, that an accused must be acquitted.
As explained in Basilio v. People of the Philippines:

51 x x x

An accused has in his favor the presumption of

innocence which the Bill of Rights guarantees. Unless
his guilt is shown beyond reasonable doubt, he must
be acquitted. This reasonable doubt standard is
demanded by the due process clause of the
Constitution which protects the accused from
conviction except upon proof beyond reasonable
doubt of every fact necessary to constitute the crime
with which he is charged. The burden of proof is on
the prosecution, and unless it discharges that burden
the accused need not even offer evidence in his
behalf, and he would be entitled to an acquittal.
Proof beyond reasonable doubt does not, of course,
mean such degree of proof as, excluding the
possibility of error, produce absolute certainty. Moral
certainty only is required, or that degree of proof
which produces conviction in an unprejudiced mind.
The conscience must be satisfied that the accused is
responsible for the offense charged.

Well-entrenched in jurisprudence is the rule that the

conviction of the accused must rest, not on the

14
 weakness of the defense, but on the strength of the
prosecution. The burden is on the prosecution to
prove guilt beyond reasonable doubt, not on the
accused to prove his innocence. (Citations omitted)”22

52 I am executing this Counter-Affidavit to refute the charge

against me, to attest to the truth of all the foregoing, and to move for
the dismissal of the Complaint-Affidavit against me for a positive
declaration or finding by this Honorable Court that there exists no
probable cause to believe that I committed the crime I am charged
with. I hereby reserve the right to file criminal, civil, and/or
administrative cases at the proper time against Complainant and
before the appropriate fora. I likewise reserve the right to file
supplemental and/or additional pleadings and affidavits as may be
warranted and necessary under the circumstances.

IN WITNESS WHEREOF, I have hereunto set my hand on this

16 day of November 2021 in Quezon City.
th

______________________
Affiant

SUBSCRIBED AND SWORN to before me this ___ day of

______________ 2021 in ______________________ City, affiant
exhibiting to me her competent evidence of identity in the form of
LTO Driver’s License with No. _______________, expiring on 19 July
2024.

Doc. No. _____

Page No. _____
Book No. _____
Series of 2021.

22
Ibid.

15