Republic of the Philippines) City of Zamboanga. . . . . . .)S.S.

COUNTER-AFFIDAVIT
I, Goceb Kristoff Y. Ang, of legal age, married to _____ Ang, Filipino Citizen with residence and postal address at _____ 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.____ for the crime of Rape under Article 266-A of the Revised Penal Code; 2. I am employed as a Sales Representative of the Got Milk Incorporated with business address located at Sto. Nio Village, Putik, Zamboanga City; 3. I am assigned to conduct sales representation and delivery of all the companys products within the area covering Canelar, Sta. Maria, Tetuan, Guiwan and Putik, Zamboanga City; 4. I conduct my delivery, to the companys 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 Complainants Affidavit, that I have been regularly delivering milk at her residence in ____ Zamboanga City; 7. I deny the allegations in the Paragraph___? of the Complainants Affidavit, that I repeatedly convinced her to taste the sample of the milk despite her refusal to do so; ANTECEDENTS

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8. On ____ 2013, I received a memorandum dated ____20131 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 companys 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 6o 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 companys log book2, and a pack of transparent plastic cups; 12. At some point, we went to our delivery to one of the companys 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 companys 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 2

See Exhibit 1- Company Memorandum No. 056 dated ___2013. 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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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 oclock 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 Milk5; 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 companys 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 5

See Exhibit 6 Survey Foem of Mr. Tony Padayhag. See Exhibit 8 Schedule of Deliveries.
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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 10th day of November, 2013 at Zamboanga City, Philippines.

COSEB KRISTOFF Y. ANG Affiant -OATHRepublic of the Philippines) City of Zamboanga. . . . . . .)S.S.

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SUBSCRIBED AND SWORN TO before me this 10th day of November 2013, affiant Coseb Kristoff Y. Ang exhibiting competent evidence of his identity through his Drivers License No. J04-01-013694 issued by the Land transportation Office at Zamboanga City.

ATTY. MIKE LANZA

Doc. No.:___; Page No.:___; Book No.:___; Series of 2013

Notary public
Commissioned until 12.13.2015 554 Sto. Nio Village, Putik, ZC IBP OR No. 987123, 01/02/2013.ZC PTR OR No. 5671235, 01/02/2013 Roll No. 59213

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