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