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Republic of the Philippines)

City of Zamboanga. . . . . . .)S.S.

COUNTER-AFFIDAVIT

I, Roberto M. Cruz, of legal age, married to Adelina B. Cruz, Filipino Citizen


with residence and postal address at Block 30, Lot 10, Paraiso Homes, Tumaga,
Zamboanga City, after having been duly sworn to an oath in accordance with the
law, do hereby depose and state that:

1. I am the accused in the Criminal Case No. 45678 for the crime of Murder under
Article 248 of the Revised Penal Code;

2. I am recently unemployed as a Sales Representative of the Got Milk


Incorporated with business address located at Sto. Niño Village, Putik,
Zamboanga City;

3. I am assigned to conduct sales representation and delivery of all the


company’s products within the area covering Canelar, Sta. Maria, Tetuan,
Guiwan and Putik, Zamboanga City;

4. I conduct my delivery, to the company’s accredited clients/customers such as


stores and individuals based on the lists provided to me by the Got Milk, Inc.;

5. I only came to know about the complainant Ms. ____ as being an accredited
client of the company for quite a long time;

6. I admit the allegations in the paragraph ___ of the Complainant’s Affidavit, that
I have been regularly delivering milk at her residence in ____ Zamboanga City;

7. I deny the allegations in the Paragraph___? of the Complainant’s Affidavit, that


I repeatedly convinced her to taste the sample of the milk despite her refusal
to do so;

ANTECEDENTS

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Counter Affidavit of Coseb Kristoff Y. Ang
8. On ____ 2013, I received a memorandum dated ____2013 1 signed by our area
manager Mr. Roberto M. Nillas, instructing all sales representatives to
introduce to all our customers the “Delight” a none fat Carabao Milk as one of
the company’s brand new product;

9. In the memorandum, we were instructed to provide free taste samples of the


above-mentioned product for about One(1) glass of milk per customer and a
corresponding survey question to be signed by them;
10. Around 6’o clock in the morning of ____ 2013, Me and our company driver Mr.
Talib loaded the company van with Ten(10) cases of “Heaven Sent” Fresh Milk,
wherein each case is packed with Six(6) bottles of 500ml of the said product;

11. We also brought Four(4) extra unopened bottles of brand new “Delight” Milk
for free sample purposes as evidenced through the herein attached copy of the
company’s log book2, and a pack of transparent plastic cups;

12. At some point, we went to our delivery to one of the company’s accredited
client Mrs. Mary Rose Guevarra, who owns a store located at House No.12
block-4, Sunrise, Guiwan, Zamboanga City;

13. After delivering the orders at her store, I introduced to Mrs. Guevarra our
company’s new brand of milk and offered her one glass poured out from the
extra bottles to one of the plastic cups we brought;

14. Mrs. Guevarra received and consumed the milk I offered and signed on the
survey sheet3;

15. We immediately left the premises and headed towards our other client Mr.
Tony Padayhag, at his residence in house no.21-B Morning Glory, Putik
Zamboanga City;

16. After delivering the said orders at his residence, I introduced to him the new
brand of milk the same manner I offered to the prior client Mrs. Guevarra;

1 See Exhibit “1”- Company Memorandum No. 056 dated ___2013.


2 See Exhibit “3”- Machine copy of the logbook dated ___2013.
3 See Exhibit “5” – Survey Form of Mrs. Mary Rose Guevarra.

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Counter Affidavit of Coseb Kristoff Y. Ang
17. Mr. Padayhag received and consumed the milk I offered and filled the survey
form4 and signed;

18. We left the premises and headed towards to our other client the herein
complainant at her residence in Daisy Road, Putik Zamboanga City;

19. Around 7 o’clock in the morning, upon arrival at the area of her residence, I
went towards door step and brought the her orders of 2 bottles of 500ml
“Heaven Sent Fresh Milk”5;

20. The same manner I did with the previous clients, I brought an extra Bottle of
the said Brand new Milk together with a survey form with me;

21. Upon reaching her door step, I knocked several times at her door and waited
for a response;

22. When the door opened, the herein complainant appeared in front of me with
only a towel covering her chest down towards her knees;

23. I felt awkward on that moment and tried to look away as much as possible
because of the fear that the herein complainant might misunderstood my
actions and gets offended;

24. The herein complainant told me to put her orders of milk on the floor inside
near her doorstep and asked me to hurry up, Much as a wanted to avoid
embarrassment, I followed what she told me to;

25. Because of the memorandum I remember, I took the opportunity to introduce


to herein complainant about the company’s new Brand of milk, in the hopes
that she might be satisfied and have an additional satisfactory remark on my
over all survey sheet;

26. The herein complainant agreed to try the milk however, I failed to bring the
plastic cups and will take me more time to go back to the van and get it;

4 See Exhibit “6” – Survey Foem of Mr. Tony Padayhag.


5 See Exhibit “8” – Schedule of Deliveries.

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Counter Affidavit of Coseb Kristoff Y. Ang
27. The complainant insisted that she is on a hurry and proposed to use her
utensils instead, so she hurriedly went inside her house then came back with a
glass and gave it to me;

28. I opened the extra bottle of the “Delight” milk I brought and poured it to the
above-mentioned cup;

29. Upon filling up the cup with milk, The herein complainanty told me “Salamat,
kailangan ko nang pumunta”, “thank you, I need to go now”(translation
supplied ours), and immediately closed the door without signing any survey
form nor having seen her consumed the glass of milk;

30. I immediately left the premises and proceeded the delivery to our other
clients;

31. I vehemently deny the accusations of Rape charged against me;

32. I am executing this affidavit to attest the truth of the above facts and for the
purpose of complying with the procedures of the Honorable Court.

AFFIANT FURTHER SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto set my hands this 10 th day of


November, 2013 at Zamboanga City, Philippines.

COSEB KRISTOFF Y. ANG


Affiant

-OATH-

Republic of the Philippines)


City of Zamboanga. . . . . . .)S.S.

SUBSCRIBED AND SWORN TO before me this 10th day of November 2013,


affiant Coseb Kristoff Y. Ang exhibiting competent evidence of his identity through

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Counter Affidavit of Coseb Kristoff Y. Ang
his Driver’s License No. J04-01-013694 issued by the Land transportation Office at
Zamboanga City.

ATTY. MIKE LANZA


Doc. No.:___; Notary public
Page No.:___; Commissioned until 12.13.2015
Book No.:___; 554 Sto. Niño Village, Putik, ZC
Series of 2013 IBP OR No. 987123, 01/02/2013.ZC
PTR OR No. 5671235, 01/02/2013
Roll No. 59213

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Counter Affidavit of Coseb Kristoff Y. Ang

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