REPUBLIC OF THE PHILIPPINES)

CITY OF ZAMBOANGA ) S.S.

AFFIDAVIT

I, VILMA VILLARES BALAIS, of legal age, married, US Citizen, and a

resident of 1447 Medfield, Baltimore City, Maryland, 21211, United States of
America, now here in the Philippines, after having been duly sworn to in
accordance with law, do hereby depose and state that:

1. That, I am a nurse currently residing in the United States of

America;

2. That, I was born on March 7, 1955 in Zamboanga City;

3. That, I am a member of the Church of Jesus Christ of Latter Day

Saints where I came to know and became friends with Carmen
Señ olos since the 1980s;

4. That, I went to the United States of America in 1990 and worked

there as a Nurse from 1990 until the present day;

5. That, Carmen Señ olos and I have had no further communication

since moving to the United States of America until September of
2017 when she added me on the social media website Facebook
(FB, for brevity);

6. That, on October of 2017, I came back to Zamboanga City for my

class reunion of General Hospital, currently known as Zamboanga
City Medical Center;

7. That, Carmen Señ olos invited me to visit her in Cebu City for a
possible business venture through facebook messenger;

8. That, on or about the second half of October, 2017, I was

scheduled to go to Bohol for the continuation of our reunion. I left
Zamboanga City via the Zamboanga City International Airport and
landed in Cebu City where I again met with Carmen Señ olos
wherein she brought me to the ferry bound for Bohol;

9. That, after three (3) days in Bohol, I returned to Cebu City where
Carmen Señ olos fetched me from the ferry and brought me to her
home in Cebu, or more specifically at 37 D, Guadaville Homes,
Guadalajara, Lilac Street, Cebu City, 6000;

10. That, it was during this time that Carmen Señ olos again
brought up the topic for the possible business venture which was
to be a medical laboratory located at Sogod, Cebu City. Carmen
 Señ olos even stated the name and address which is ViC Medical
Laboratory CO. located at Ground Floor, Seamount Part I, Damolog
Sogod, Cebu City;

11. That, Carmen Señ olos stated that we will be splitting the
capital on a 50/50 basis and asked for an initial capitalization of
THREE HUNDRED FIFTY THOUSAND (PHP 350,000.00) Pesos;

12. That, Carmen Señ olos intimated that her live – in partner
was a former director at the Ian Ginaldo Hospital and that the
building where the proposed laboratory was to be established
was located near the abovementioned hospital and that the rent
was about EIGHT THOUSAND (PHP 8,000.00) Pesos per month;

13. That, I rented a car which cost about FOUR THOUSAND

(PHP 4,000.00) Pesos to visit different places in Cebu City like the
Temple of Leah, Chinese Temple and other places;

14. That, while touring in Cebu City, Carmen Señ olos brought
me to the building where the proposed laboratory was supposed
to be established;

15. That, while in the area, we visited a restaurant adjacent to

the building and there asked who the owner of the adjacent
building was, only to find out the owner of the restaurant and of
the adjacent building was the same person;

16. That, one of the waiters gave the mobile number of the
owner to Carmen Señ olos and they conversed with each other.
During this time, I was beside Carmen Señ olos but I did not ask
about their conversation. Carmen Señ olos stated that the owner
was asking for FORTY THOUSAND (PHP 40,000.00) Pesos for
payment of the rent;

17. That, I immediately asked my sister, Susana B. Flores, to

send me the amount of FIFTY THOUSAND (PHP 50,000.00) Pesos
which was sent through Palawan Express. I gave the amount of
FORTY THOUSAND PESOS by hand to Carmen Señ olos. The FIFTY
THOUSAND PESOS sent through Western Union is evidenced by
Palawan Express Transaction Code BDX – 9 – 76166 – ZAW.
Machine reproduction copy of the Palawan Express Transaction
Code BDX – 9 – 76166 – ZAW is herein attached to as Annex “A”;

18. That, during my time in Cebu City, Carmen Señ olos did not
present to me any document, paper, receipt or contract for the
business venture;
19. That, after some time I returned to the United States of
America and during the next few months, or specifically from
November 2017 until February 2018, Carmen Señ olos convinced
me to send addition funds for the business venture which
amounted to about SEVEN THOUSAND (USD 7,000.00) US Dollars
or about THREE HUNDRED FIFTY THOUSAND (PHP 367,000.00)
Pesos;

20. That, while in the United States of America, Felixberto Maico

told me that Carmen Señ olos scammed a lot of people in
Zamboanga City for acts and transactions related to the City
Agriculture’s Office and that Carmen Señ olos is a swindler;

21. That, in December 2017, I asked Carmen Señ olos through

Facebook Messenger about the progress of the business venture
and she merely replied that she cannot concentrate because her
live – in partner was sick. She never mentioned anything about
our business;

22. That, on or about January to February 2018, I again inquired

about the business to which she indicated that the business is not
moving and that her eldest son had died;

23. That, during one of our conversations, she indicated that

she intended to purchase a Biochemistry Device which costs
around ONE MILLION SEVEN HUNDRED THOUSAND to ONE
MILLION EIGHT HUNDRED THOUSAND (PHP 1,700,000.00 to PHP
1,800,000.00) Pesos. However, I researched about the
Biochemistry Device and the price which I found to be readily
available in Manila only costs about SEVEN HUNDRED
THOUSAND (PHP 700,000.00) Pesos;

24. That, by means of deceit, false pretenses and coupled with

fraudulent acts, Carmen Señ olos was able to convince me to part
with the money which I earned and saved through years of
working as a nurse and which I was planning to use for my
retirement;

25. That, I am executing this affidavit to attest to the veracity of

the foregoing statements.

FURTHER, Affiant sayeth naught.

VILMA VILLARES BALAIS

Affiant
 SIGNED IN THE PRESENCE OF:

_________________________________ _______________________________

Republic of the Philippines)

City of Zamboanga ) S.S.

ACKNOWLEDGMENT

BEFORE ME, a Notary Public for Zamboanga City, on this ____ day of ___________,
2018, personally appeared:
            
Name                                     ID and ID No.                         Date/Place Issued

VILMA VILLARES BALAIS ________________________ ____________________

________________________ ____________________

           
Known to me and to me known to be the same person who executed the
foregoing instrument and acknowledged to me that the same is his free and
voluntary act and deed.

WITNESS MY HAND AND NOTARIAL SEAL on the date and place

abovewritten.

Doc. No. ____;

Page No. ____;
Book No. ____;
Series of 2018.
 SPECIAL POWER OF ATTORNEY

KNOW ALL MEN BY THESE PRESENTS:

I, VILMA VILLARES BALAIS, of legal age, married, US Citizen, and a

resident of 1447 Medfield, Baltimore City, Maryland, 21211, United States of
America, now here in the Philippines

Hereby NAMED, CONSTITUTED and APPOINTED:

SHEMAE B. FLORES, of legal age, Filipino single, and a resident of

Barangay Tetuan, Zamboanga City as my true and lawful ATTORNEY – IN –
FACT, for me and in my name, place and stead to do the following acts:

To file the necessary case in relation to the monies which

Carmen Señ olos convinced me to part and against any and all
persons, their heirs, assigns and successors – in – interest for a
possible collection of sum of money case, estafa or any other civil,
criminal or administrative case to protect my proprietary rights
and interests;

To represent and appear in my behalf and stead before any

barangay proceedings to protect my interest and to enter into any
amicable settlement and to present witnesses and evidence;

To sign, prepare and present any and all document relative

to the filing of any civil, criminal or administrative case to protect
my rights and interest;

HEREBY GIVING AND GRANTING unto my said Attorney – in – fact, full

power and authority to do and perform all and every act and thing which may
be proper and necessary to be done in and about the premises, as fully to all
intents and purposes as I might or could do if personally present and acting
and HEREBY RATIFYING AND CONFIRMING all that my said Attorney shall
lawfully do or cause to be done by virtue of these presents;

IN WITNESS WHEREOF, I have hereunto set my hand on the date and

place hereinafter mentioned.

VILMA VILLARES BALAIS

Grantor

SIGNED IN THE PRESENCE OF:

 __________________________ ___________________________

Republic of the Philippines)

City of Zamboanga ) S.S.

BEFORE ME, a Notary Public for Zamboanga City, on this ____ day of ___________,
2018, personally appeared:
            
Name                                    ID and ID No.                           Date/Place Issued

VILMA VILLARES BALAIS __________________________ ____________________

__________________________ ____________________

Known to me and to me known to be the same persons who executed the

foregoing instrument and acknowledged to me that the same is their free and
voluntary act and deed.

WITNESS MY HAND AND NOTARIAL SEAL, on the date and place first above
written.

Doc. No. ____;

Page No. ____;
Book No. ____;
Series of 2018.
 SPECIAL POWER OF ATTORNEY

KNOW ALL MEN BY THESE PRESENTS:

I, VILMA VILLARES BALAIS, of legal age, married, US Citizen, and a

resident of 1447 Medfield, Baltimore City, Maryland, 21211, United States of
America, now here in the Philippines

Hereby NAMED, CONSTITUTED and APPOINTED:

SHEMAE B. FLORES, of legal age, Filipino single, and a resident of

Barangay Tetuan, Zamboanga City as my true and lawful ATTORNEY – IN –
FACT, for me and in my name, place and stead to do the following acts:

To sign, prepare and present any and all document relative

to the filing of any civil, criminal or administrative case to protect
my rights and interest.

To file any civil, criminal or administrative case to protect

my rights and interest against Carmen Señ olos or any and all
persons and their heirs, assigns and successors – in – interest;

To act for and in our name and stead and to represent me

during the hearing of any civil case, criminal or administrative
case, to represent me before the Philippine Mediation Center, to
enter into amicable settlement, to submit to alternative modes
of dispute resolution and to make admissions or stipulations of
facts and documents without further consultation from me.

To agree on the simplification of issues, amend the

pleadings, limit the number of witness, and agree on such other
matters as may aid in the prompt disposition of the action.

To attend, appear and participate in and during the Pre –

Trial Conference relative to the filing of any case.

HEREBY GIVING AND GRANTING unto my said Attorney – in – fact, full

power and authority to do and perform all and every act and thing which may
be proper and necessary to be done in and about the premises, as fully to all
intents and purposes as I might or could do if personally present and acting
and HEREBY RATIFYING AND CONFIRMING all that my said Attorney shall
lawfully do or cause to be done by virtue of these presents;
 IN WITNESS WHEREOF, I have hereunto set my hand on the date and
place hereinafter mentioned.

VILMA VILLARES BALAIS

Grantor

SIGNED IN THE PRESENCE OF:

__________________________ ___________________________

Republic of the Philippines)

City of Zamboanga ) S.S.

BEFORE ME, a Notary Public for Zamboanga City, on this ____ day of ___________,
2018, personally appeared:
            
Name                                    ID and ID No.                           Date/Place Issued

VILMA VILLARES BALAIS __________________________ ____________________

__________________________ ____________________

Known to me and to me known to be the same persons who executed the

foregoing instrument and acknowledged to me that the same is their free and
voluntary act and deed.

WITNESS MY HAND AND NOTARIAL SEAL, on the date and place first above
written.

Doc. No. ____;

Page No. ____;
Book No. ____;
Series of 2018.
 SPECIAL POWER OF ATTORNEY

KNOW ALL MEN BY THESE PRESENTS:

I, VILMA VILLARES BALAIS, of legal age, married, US Citizen, and a

resident of 1447 Medfield, Baltimore City, Maryland, 21211, United States of
America, now here in the Philippines

Hereby NAMED, CONSTITUTED and APPOINTED:

The lawyers of CASTILLO & CLIMACO LAW OFFICE, specifically: ATTY.

LUIS M. CLIMACO, ATTY. JAN CEASAR A. CLIMACO, ATTY. BRIETHNER G.
AMELDA, ATTY. ISMAEL G. ABUBAKAR, III and ATTY. JIHAN EL R.
EDDING, all of legal age, Filipinos and a residents of Zamboanga City, as my
true and lawful ATTORNEY – IN – FACT, for me and in my name, place and
stead to do the following acts:

To file the necessary case in relation to the monies which

Carmen Señ olos convinced me to part and against any and all
persons, their heirs, assigns and successors – in – interest for a
possible collection of sum of money case, estafa or any other civil,
criminal or administrative case to protect my proprietary rights
and interests;

To represent and appear in my behalf and stead before any

barangay proceedings to protect my interest and to enter into any
amicable settlement and to present witnesses and evidence;

To sign, prepare and present any and all document relative

to the filing of any civil, criminal or administrative case to protect
my rights and interest;

HEREBY GIVING AND GRANTING unto my said Attorneys – in – fact,

full power and authority to do and perform all and every act and thing which
may be proper and necessary to be done in and about the premises, as fully to
all intents and purposes as I might or could do if personally present and acting
and HEREBY RATIFYING AND CONFIRMING all that my said Attorney shall
lawfully do or cause to be done by virtue of these presents;

IN WITNESS WHEREOF, I have hereunto set my hand on the date and

place hereinafter mentioned.

VILMA VILLARES BALAIS

 Grantor

SIGNED IN THE PRESENCE OF:

__________________________ ___________________________

Republic of the Philippines)

City of Zamboanga ) S.S.

BEFORE ME, a Notary Public for Zamboanga City, on this ____ day of ___________,
2018, personally appeared:
            
Name                                    ID and ID No.                           Date/Place Issued

VILMA VILLARES BALAIS __________________________ ____________________

__________________________ ____________________

Known to me and to me known to be the same persons who executed the

foregoing instrument and acknowledged to me that the same is their free and
voluntary act and deed.

WITNESS MY HAND AND NOTARIAL SEAL, on the date and place first above
written.

Doc. No. ____;

Page No. ____;
Book No. ____;
Series of 2018.
 SPECIAL POWER OF ATTORNEY

KNOW ALL MEN BY THESE PRESENTS:

I, VILMA VILLARES BALAIS, of legal age, married, US Citizen, and a

resident of 1447 Medfield, Baltimore City, Maryland, 21211, United States of
America, now here in the Philippines

Hereby NAMED, CONSTITUTED and APPOINTED:

The lawyers of CASTILLO & CLIMACO LAW OFFICE, specifically: ATTY.

LUIS M. CLIMACO, ATTY. JAN CEASAR A. CLIMACO, ATTY. BRIETHNER G.
AMELDA, ATTY. ISMAEL G. ABUBAKAR, III and ATTY. JIHAN EL R.
EDDING, all of legal age, Filipinos and a residents of Zamboanga City, as my
true and lawful ATTORNEY – IN – FACT, for me and in my name, place and
stead to do the following acts:

To sign, prepare and present any and all document relative

to the filing of any civil, criminal or administrative case to protect
my rights and interest.

To file any civil, criminal or administrative case to protect

my rights and interest against Carmen Señ olos or any and all
persons and their heirs, assigns and successors – in – interest;

To act for and in our name and stead and to represent me

during the hearing of any civil case, criminal or administrative
case, to represent me before the Philippine Mediation Center, to
enter into amicable settlement, to submit to alternative modes
of dispute resolution and to make admissions or stipulations of
facts and documents without further consultation from me.

To agree on the simplification of issues, amend the

pleadings, limit the number of witness, and agree on such other
matters as may aid in the prompt disposition of the action.

To attend, appear and participate in and during the Pre –

Trial Conference relative to the filing of any case.

HEREBY GIVING AND GRANTING unto my said Attorneys – in – fact,

full power and authority to do and perform all and every act and thing which
may be proper and necessary to be done in and about the premises, as fully to
all intents and purposes as I might or could do if personally present and acting
and HEREBY RATIFYING AND CONFIRMING all that my said Attorney shall
lawfully do or cause to be done by virtue of these presents;

IN WITNESS WHEREOF, I have hereunto set my hand on the date and

place hereinafter mentioned.

VILMA VILLARES BALAIS

Grantor

SIGNED IN THE PRESENCE OF:

__________________________ ___________________________

Republic of the Philippines)

City of Zamboanga ) S.S.

BEFORE ME, a Notary Public for Zamboanga City, on this ____ day of ___________,
2018, personally appeared:
            
Name                                    ID and ID No.                           Date/Place Issued

VILMA VILLARES BALAIS __________________________ ____________________

__________________________ ____________________

Known to me and to me known to be the same persons who executed the

foregoing instrument and acknowledged to me that the same is their free and
voluntary act and deed.

WITNESS MY HAND AND NOTARIAL SEAL, on the date and place first above
written.

Doc. No. ____;

Page No. ____;
Book No. ____;
Series of 2018.