1

Republic of the Philippines

Department of Justice
National Prosecution Service
Office of the City Prosecutor
Iloilo City

AURELIO MANA-AY Docket No. VI-10-INV-201-00462

y CURATCHO et al.,
Complainant/s For:

-versus- Syndicated Estafa committed in Large

Scale (Art. 315, Par. 2, RPC)
CHRISTOPHER WOLF CRUTCHER
et al.,
Respondent/s
x- -- - - - - -- - - - - - - - - - - - - -x

JUDICIAL AFFIDAVIT OF RESPONDENT CLEMENTE R. LAGUDA IV

I, CLEMENTE R. LAGUDA IV, of legal age, Filipino and a resident

of Brgy. Caingin, La Paz, Iloilo City, Philippines, state under oath, as
follows:

Preliminary Statement

The person interrogating me is Atty. Rene S. Sarabia with his office

address at No. 394 E. Lopez Street, Jaro, Iloilo City. The interrogation is
being held at his law office at Jaro, Iloilo City and I am answering the
questions fully conscious that I do so under oath and may face criminal
liability for perjury and false testimony. This Judicial Affidavit is written in
English and the examination is conducted in English.

Questions and Answers

1. Question: Please state your name, age, address and other personal
circumstances?

1. Answer: I am CLEMENTE R. LAGUDA IV, 42 years of age, Filipino

and a resident of Brgy, Caingin, La Paz, Iloilo City, Philippines.

2. Q: What is your purpose for executing this affidavit?

2. A: I am one of the respondents in a criminal complaint for Syndicated

Estafa committed in Large Scale, Art. 315, Par. 2 of the Revised Penal
Code, as amended by P.D. 1689, filed against us by complainants Aurelio
Mana-ay, Joemarie Beriber, Balbino Tiezo, Lelita Anas, Annie Mana-ay,
Susan Movera, Marlon Occeno and Jonalyn Joy Alagao subject of
Preliminary Investigation by the Office of the City Prosecutor of Iloilo City.
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3. Q: What do you say to this criminal complaint for Syndicated Estafa

filed against you by the above mentioned complainants?

3. A: I vehemently and categorically deny the allegations contained in the

Judicial Affidavits of Aurelio Mana-ay and his co-complainants dated July
2, 2020 for complainant Aurelio Mana-ay and July 3, 2020 for the other
complainants and subscribed before Atty. Ramilo D. Quinto, Executive
Officer, NBI-WEVRO, Iloilo City for being false, fictitious, and fabricated,
and consisting of misrepresentations and distortions of the actual facts
and circumstances. The truth of the matter is that, respondents Lina
Deslate and Maruja Reyes among others were swindled and defrauded of
millions of pesos by the Swindling Gang led by Greg Lapatis and
complainant Aurelio Mana-ay which also included several of the other
complainants namely Joemarie Beriber, Balbino Tiezo, Marlon Occeño,
Lelita Anas, Annie Mana-ay, Susan Movera and Jonalyn Joy Alagao. This
criminal complaint is just a counter charge to an earlier and previously
filed criminal complaint for Syndicated Estafa filed by complainants Lina
Deslate, Maruja Reyes, Zenaida Aguilar, Liezl Consolacion, Benjamin
Jaleco, Tommy Huinda, Jonjie Quinto and Abner Berate against Greg
Lapatis, complainants Aurelio Mana-ay, Jomarie Beriber, Balbino Tiezo,
Annie Mana-ay and Marlon Occeño before the Iloilo City Prosecutor’s
Office docketed as NPS Docket No. VI-10-INV-20H-00389 and is presently
subject of preliminary investigation.

4. Q: How were you able to know the main complainant Aurelio Mana-ay?

4. A: I was able to know complainant Aurelio Mana-ay through Greg

Lapatis sometime in June or thereabouts of 2018. He is one of the persons
who visited Greg Lapatis frequently at the time. To my understanding
Greg Lapatis and Aurelio Mana-ay had previous dealings with each other
involving land transactions and treasure hunting activities.

5. Q: Could you describe the preceding events that led to your interaction
with complainant Aurelio Mana-ay at the time?

5. A: Sometime in the first week of June 2018, Greg Lapatis went to

Angeles City, Pampanga. He was brought there by Atty. Stephen Arceño
and his wife Nilda Arceño who were from Capiz to be introduced to a
foreigner interested to develop humanitarian projects. Greg Lapatis
brought me along as his assistant. Greg Lapatis was introduced by Atty.
Stephen Arceñoo to Christopher Crutcher who was the foreigner interested
to develop humanitarian projects. Then, Greg Lapatis proposed and
discussed various potential projects in the Visayas Region, primarily in
Iloilo City and Province of Iloilo. Lapatis represented himself to be the
overall chieftain of all the tribal leaders of the indigenous peoples of the
island of Panay. Then, he showed to Christopher Crutcher documents
purportedly signed by different tribal leaders all over Panay. Lapatis
claimed he has the authority in behalf of all the indigenous people of
Panay to negotiate and transact the use of their lands of ancestral
domain. He further bolstered his position by showing Christopher Crutcher
pictures of ancient artifacts such as old jars, old Japanese swords, gold
bars buried in bunkers, precious gems and stones and documents of coal
ore and crude oil deposits. Christopher Crutcher told Greg Lapatis that he
cannot accept Lapatis invitation to visit Iloilo and the Visayas Region at
 3

the time because has a schedule to travel to some other countries to

follow up developments on his proposed humanitarian projects. So, Greg
Lapatis, Atty.Arceño, his wife, Nilda Arsenio and I went back to Iloilo City
after three days of meetings.

6. Q: Do you have any documentary proof or any kind of proof of your

claim that Greg Lapatis, spouses Stephen and Nilda Arceño and you
visited Angeles City, Pampanga to meet with Christopher Crutcher
sometime in June 2018?

6. A: Yes sir. I personally took pictures and videos or I was included in

the pictures taken during the meetings and discussions that took place in
our three (3) day stay in Angeles City, Pampanga in the first week of June
2018. Likewise, I have pictures of the alleged ancient artifacts, alleged
buried gold bars in bunkers, etc shown by Lapatis to Crutcher. The
pictures or documents I am referring to, are as follows:

6.a. A picture showing Greg Lapatis and Christopher Crutcher taken

at Angeles City, Pampanga on June 3, 2018.
6.b. A picture showing Greg Lapatis and Christopher Crutcher
together Atty. Stephen Arceño and wife Nilda Arceño taken in
Angeles City, Pampanga on June 3, 2018
6.c. A picture showing Greg Lapatis, Christopher Crutcher together
with Nilda Arceño and me during a conference meeting taken in
Angeles City, Pampanga on June 3, 2018
6.d. Another picture from a different angle showing Greg Lapatis,
Christopher Crutcher together with Nilda Arceño and me at the same
conference meeting taken in Angeles City, Pampanga on June 3,
2018
6.e. A picture showing Greg Lapatis, Atty. Arceño and me having
some drinks after the conference meeting taken in Angeles City,
Pampanga on June 3, 2018
6.f. Four pictures contained in in one page of an alleged mining site
for coal ore deposits purportedly located in Calatrava, Negros
Occidental which was presented by Greg Lapatis to Christopher
Crutcher
6.g. Seven pictures contained in one page of an alleged mining site
for crude oil deposits purportedly located in Calatrava, Negros
Occidental which was presented by Greg Lapatis to Christopher
Crutcher.
6.h. Eighteen pictures contained in one page showing twin bunkers
allegedly containing buried gold bars purportedly located in
Buenavista, Guimaras.
6.i. Four pictures contained in two pages showing assorted alleged
ancient artifacts.
.

(For the purposes of this Judicial Counter-Affidavit, the above

enumerated documents are marked, as follows: Document 6.a as Annex
“1”, Document 6.b as Annex “1-A”, Document 6.c as Annex “1-B”,
Document 6.d as Annex “1-C”, Document 6.e as Annex “1-D”,
Document 6.f as Annex “1-E”, Document 6.g as Annex “1-F”,
Document 6.h as Annex “1-G”, Document 6.i as Annex “1-H)
 4

7. Q: What happened when Greg Lapatis and you went back to Iloilo City?

7. A: Immediately after our arrival, Greg Lapatis contacted all his

connections involved in land acquisition such as brokers, land agents and
land owners to discuss the proposed humanitarian projects of Christopher
Crutcher, code named Project Galileo wherein according to Greg Lapatis
there is a need to acquire large tracks of land for the development of the
agricultural, aqua culture, tourism and industrial aspects or components of
the said project. Since, st the time I acted as the assistant of Greg
Lapatis, I was present in almost all of the meetings on the land acquisition
operations spearheaded by Greg Lapatis. Greg Lapatis’ closest confidants,
advisers and operatives in his land acquisition operations were
complainant Aurelio Mana-ay Jose Reden de Juan, Joemarie Bereber and
Liezl Aragones. Greg Lapatis in conspiracy with complainant Aurelio Mana-
ay Jose Reden de Juan, Joemarie Bereber and Liezl Aragones presented
himself and claimed that he was authorized by Empire Group, Ltd. to
negotiate and transact for the acquisition of large tracts of land for the
agricultural, aqua culture, tourism and industrial components of Project
Galileo being undertaken by Empire Group, Ltd. Greg Lapatis in
consultancy and advisement of his core group Aurelio Mana-ay, Jose
Reden de Juan, Liezl Aragones and Joemarie Bereber designed and
proposed a commission scheme for the brokers and the land agents who
will participate in the land acquisition program. Further, Lapatis also
designed and proposed an overprice or mark-up scheme for buying price
of the land to be shared by him, the land brokers and agents and the
landowners.

8. Q: Do you have documentary evidence or any kind of proof of this

alleged commission scheme for land brokers and agents who participated
in the land acquisition program of Greg Lapatis?

8. A: Yes, sir. I have several documents most of which are notarized

which are all signed by Greg Lapatis detailing the commission scheme
designed by him and also showing that he was the principal actor and
main beneficiary in all the land transactions he is allegedly undertaking in
behalf of Empire Group, Ltd. These documents which are only a miniscule
sample of thousands of similar documents are, as follows:

8.a. Authorization Letter signed by Greg Lapatis in favor of Zenaida

Aguilar dated May 31, 2019
8.b. Agent Agreement on the Commission Scheme dated and
notarized on October 8, 2019 between Greg Lapatis and the
brokers/agents on the proposed acquisition of the property of
Jocelyn Paduga located in Brgy. Maasin, Puerto Princesa, Palawan
with an area of 318.4121 hectares
8.c. Agent Agreement on the Commission Scheme dated and
notarized on December 2, 2019 between Greg Lapatis and the
brokers/agents on the proposed acquisition of the property of
Jocelyn Paduga located in Brgy. Maasin, Puerto Princesa, Palawan
with an area of 326.0199 hectares
8.d. Agent Agreement on the Commission Scheme dated and
notarized on December 31, 2019 between Greg Lapatis and the
brokers/agents on the proposed acquisition of the property of
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Jocelyn Paduga located in Brgy. Maasin, Puerto Princesa, Palawan

with an area of 326.0199 hectares
8.e. Memorandum of Agreement between the landowner, the land
agent with exclusive authority to sell and Greg Lapatis as the
representative/mandated by Empire Group, Ltd. in relation to the
sharing of the commission and overprice on the sale of the land of
Christine Jen P. Red located at Brgy. Sta. Monica, Puerto Princesa,
Palawan dated and notarized on November 23, 2018.
8.f. Memorandum of Agreement between the landowner, the land
agent with exclusive authority to sell and Greg Lapatis as the
representative/mandated by Empire Group, Ltd. in relation to the
sharing of the commission and overprice on the sale of the land of
Jessie Sumaylo located at Brgy. Nicanor Zabala, Roxas, Palawan
dated and notarized on November 23, 2018.
8.g. Memorandum of Agreement between the landowner, the land
agent with exclusive authority to sell and Greg Lapatis as the
representative/mandated by Empire Group, Ltd. in relation to the
sharing of the commission and overprice on the sale of the land of
Erlinda V. Mayo located at Brgy. Bahay Toro, Quezon City dated and
notarized on November 23, 2018.
8.h. Memorandum of Agreement between the landowner, the land
agent with exclusive authority to sell and Greg Lapatis as the
representative/mandated by Empire Group, Ltd. in relation to the
sharing of the commission and overprice on the sale of the land of
Jocelyn Paduga located at Brgy. Sta. Monica, Puerto Pricesa,
Palawan dated and notarized November 23, 2018.
8.i. Memorandum of Agreement between the landowner, the land
agent with exclusive authority to sell and Greg Lapatis as the
representative/mandated by Empire Group, Ltd. in relation to the
sharing of the commission and overprice on the sale of the land of
Darwin T. Alajar located in Palawan dated and notarized on
November 23, 2018.
8.j. Memorandum of Agreement between the landowner, the land
agent with exclusive authority to sell and Greg Lapatis as the
representative/mandated by Empire Group, Ltd. in relation to the
sharing of the commission and overprice on the sale of the land of
Conchita Salvame located in Brgy. Casilao, Taytay, Palawan dated
December 31, 2018.

(For the purposes of this Judicial Counter-Affidavit, the above

enumerated documents are marked, as follows: Document 8.a as
Annex “2”, Document 8.b as Annex “2-A”, Document 8.c as
Annex “2-B”, Document 8.d as Annex “2-C”, Document 8.e as
Annex “2-D”, Document 8.f as Annex “2-E”, Document 8.g as
Annex “2-F”, Document 8.h as Annex “2-G”, Document 8.i. as
Annex “2-H, and Document 8.j. as Annex “2-I”)

9. Q: When for the first time did you come to know of Greg Lapatis
claiming that he was authorized by Empire Group, Ltd. to negotiate and
transact for the acquisition of large tracts of land for the agricultural, aqua
culture, tourism and industrial components of Project Galileo being
allegedly undertaken by Empire Group, Ltd.?
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9. A: Immediately after we arrived in Iloilo City in early June of 2018,

Greg Lapatis contacted all of his connections in the real estate business
and announced that he has a foreign investor in Empire Group, Ltd. who
authorized him to negotiate and transact for the acquisition of large tracts
of land for the humanitarian development programs of Project Galileo.

10. Q: What was the reaction of the public to the said announcement of
Greg Lapatis that he has an alleged foreign investor who authorized him
to negotiate and transact for the acquisition of large tracts of land?

10. A: The declaration of Greg Lapatis that he has a foreign investor who
authorized him to transact and negotiate for the acquisition of large tracts
of land spread like wildfire among real estate brokers, land agents and
land owners and everybody believed his story. Overnight, his house in
Barrio Obrero, Lapuz, Iloilo City teemed with people who were real estate
brokers, land agents and landowners who wanted to negotiate and
transact with him the sale of various properties they were representing or
own as the case maybe. For many months since then, real estate brokers,
land agents and landowners from all over the Visayas and as far away as
Mindanao and Metro Manila flocked to the house of Greg Lapatis in Barrio
Obrero to present documents of the properties they were selling to his
alleged foreign investor through him.

11. Q: While all of these things were happening way back in June of 2018
and for months and months thereafter, where was complainant Aurelio
Mana-ay at that time, if you know?

11. A: Complainant Aurelio Mana-ay was always present at the house

cum office of Greg Lapatis at Barrio Obrero, Lapuz, Iloilo City. He together
with Jose Reden de Juan and Leizl Aragones were the persons who aided
Greg Lapatis in developing the strategies and procedures to be
implemented in the land acquisition operations of Greg Lapatis allegedly in
behalf of the Empire Group, Ltd.

12. Q: Do you have personal knowledge of these facts you are claiming?

12. A: Yes, sir. At the time, I was also present every day in the house
and office of Greg Lapatis because I was then acting as his Personal
Assistant cum Communications Officer considering that I was the one who
receives the visitors to his office, organize his meetings with said visitors
and manage his communication or information requirements such as
composing and sending his e-mails, prepare his communications or
letters, call or text the persons he wants to be in contact with and deliver
to them his messages or instructions. I was present in almost all his
meetings with his daily visitors at his house and office who were mostly
composed of land agents and brokers and land owners who wanted to sell
their lands to the Empire Group Ltd, through the land acquisition
operations of Greg Lapatis.

13. Q: Could you describe the roles of complainant Aurelio Mana-ay, Jose
Reden de Juan and Leizl Aragones in the land acquisition operations of
Greg Lapatis at the time?
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13. A: Complainant Aurelio Mana-ay was the brains of the land acquisition
strategies in terms of how to approach the targeted land owners and
explain the mission and vision of the humanitarian programs of the
Empire Group Ltd. In behalf of Greg Lapatis, he likewise monitors and
direct the activities of various real estate brokers and agents groups in the
campaign to expand the land acquisition operations of Greg Lapatis to
other areas, provinces and regions. Jose Reden de Juan is responsible for
auditing, verifying and approving the properties offered for sale or
acquisition. The three (3) of them, Greg Lapatis, Aurelio Mana-ay and Jose
Reden de Juan designed and devised the documentation protocol or
procedures for the lands being offered to qualify for acquisition by the
Empire Group Ltd. I refer to the commission scheme, mark-up or
overprice scheme, the language of the Authority to Sell, Memorandum of
Agreements between the land owners or their representatives, brokers or
agents, Greg Lapatis and other undisclosed parties. On the other hand,
Liezl Aragones is the person receiving, recording and filing all the
supporting documents submitted by real estate brokers and land agents
as required by Greg Lapatis and his swindling cabal. She also oversees
and monitors the notarization of all supporting documents submitted by
the land brokers and agents and receives and collects the notarization
fees. In the event that Leizl Aragones finds that the supporting documents
were deficient or defective she will require that they be corrected and
amended and she again will charge and collect new notarization fees.

14. Q: You said that Greg Lapatis claimed that he was authorized by
Empire Group Ltd., through its Chairman, Christopher Crutcher, to acquire
lands in its behalf, do you have personal knowledge of any formal or
authority in writing issued by Christopher Crutcher in favor of Greg Lapatis
at the time the latter started his land acquisition operations way back in
June of 2018?

14. A: I was with Greg Lapatis when he went to Angeles City, Pampanga
to meet with Christopher Crutcher for the first time. We were there for
three (3) days and have daily meetings with Christopher Crutcher and his
group. Never in the three (3) days of meetings did I hear any mention of
any land acquisition program for the Empire Group, Ltd. What was
discussed was what kind of humanitarian projects that Empire Group Ltd.,
would like to undertake in the Philippines. On the other hand, Greg Lapatis
claimed that he is a very influential person in the Visayas Region and he is
the chief tribal leader of all the indigenous people of Panay Island. Greg
Lapatis promised that he was the right person to partner with by Empire
Group Ltd., to implement its humanitarian project in the Philippines
primarily centered in the Visayas Region. However, when we went back to
Iloilo City Greg Lapatis embarked on his land acquisition scheme allegedly
in behalf of Empire Group, Ltd. together with his cohorts and co-
conspirators Aurelio Mana-ay and Jose Reden de Juan.

15. Q: What was the reaction of the public when Greg Lapatis let it to be
known that he has a foreign investor who authorized him to negotiate the
acquisition of vast tracts of land for the latter’s investment or business
purposes way back in June of 2028?

15. A: The real estate brokers and land agents community in the Visayas
went into a frenzy. Hundreds of real estate brokers and land agents
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flocked to the house and office of Greg Lapatis in Barrio Obrero, Lapuz,
Iloilo City every day. Greg Lapatis entertained them and showed them
pictures of Christopher Crutcher and his foreign staff together with him in
Angeles City, Pampanga during meetings and picture takings to bolster his
claim that he truly has a foreign investor. He did not show any written or
formal authority to prove that he was legally empowered by Empire
Group, Ltd. to acquire lands in its behalf.

16. Q: Was Greg Lapatis able to convince the public, primarily the real
estate brokers and land agents community of the legitimacy of his alleged
land acquisition scheme even if he did not present any formal or written
proof of his authority to transact business for and in behalf of Empire
Group, Ltd,?

16. A: Yes sir. It is as if everybody was in a trance or under hypnotism

that they simply believed Greg Lapatis. Even I who was together with him
in Angeles City when he met Christopher Crutcher. I did not doubt him
Greg Lapatis) because he told me that he had private and closed door
meetings with Christopher Crutcher which I was not present and privy to
wherein they hammered out their agreements and covenants. It is the
modus operandi of Greg Lapatis to show the pictures I have taken and the
video I have recorded during our meeting in Angeles City, Pampanga to
assure his target visitors of the credibility of his claims. People simply
believed him hook, line and sinker.

17. Q: During these initial months of the launching of the land acquisition
operations of Greg Lapatis allegedly in behalf of Empire Group, Ltd.
starting early June 2018 and onwards, what was the role of complainant
Aurelio Mana-ay in all of these?

17. A: He assisted Greg Lapatis in entertaining and convincing the real

estate brokers and land agents community of the legitimacy and
authenticity of the land acquisition scheme of Greg Lapatis. Exploiting his
condition as a person with disability (PWD), he made testimonies to the
effect that even he who is a disabled person is committed to fulfillment of
the humanitarian programs of Empire Group, Ltd. to alleviate the life and
lot of humanity primarily the indigenous people of the Philippines. In his
testimonies before a crowd of real estate brokers, land agents and land
owners Complainant Mana-ay claimed that Empire Group, Ltd. is willing to
pour in billions of dollars of investment in the Philippines which will employ
thousands of people and revitalized our economy. In my observation,
many people were touched and sympathized with Mana-ay’s false and
deceptive testimonies.

18. Q: When Greg Lapatis launched his land acquisition operations in June
of 2018 and onwards, did he communicate with Christopher Crutcher who
was then outside of the Philippines at the time?

18. A: A few months after June 2018 when Greg Lapatis launch his land
acquisition operations or sometime in September 2018, Greg Lapatis
instructed me to contact Christopher Crutcher by e-mail to inform the
latter that he (Lapatis) has set in motion actions to prove the sincerity of
his commitment to Christopher Crutcher that he (Lapatis) will create an
environment wherein the humanitarian programs of Empire Group Ltd.
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codenamed Project Galileo could be implemented in the Philippines

primarily in the Visayas Region. In return, Christopher Crutcher should
also fulfill his promise to visit the Philippines to pursue his humanitarian
projects.

19. Q: Do have any proof or evidence of such e-mail exchanges between

Greg Lapatis and Christopher Crutcher on the matter?

19. A: Yes sir. I was the one who drafted and composed the e-mail
messages upon instruction of Greg Lapatis to be sent to Christopher
Crutcher. Basically, the e-mail messages reiterates the invitation of Greg
Lapatis for Christopher Crutcher to visit the Philippines. He instructed me
to attach to his e-mail messages, pictures and videos of activities he has
undertaken to promote the humanitarian and environmental programs of
Christopher Crutcher codenamed Project Galileo. The pictures and videos
were purported to show that a good number of people from various places
all over the Visayas support and are aware of the humanitarian purposes
of Project Galileo. In truth and in fact, these people who are presented in
the pictures and videos were all landowners, real estate brokers and land
agents were present at the activities because Greg Lapatis promised them
that he will buy the lands they are selling at a high price so that they will
earn hefty commissions and will have a share in the overprice or mark up
on the purchase price of said lands.

20. Q: Could you enumerate and mark your documentary evidence or

proof of e-mail messages, pictures and videos referred to in the previous
question?

20. A: Yes, sir. The following are a few samples of the e-mail messages
and exchanges between Christopher Crutcher and Greg Lapatis which I
composed, drafted and sent under instructions from Greg Lapatis together
with attachments of pictures and videos of events and activities
undertaken by said Greg Lapatis purportedly showing the groundwork
Lapatis has done towards the achievement of Christopher Crutcher’s
humanitarian project known as Project Galileo during the period
September 10, 2018 to December 29, 2019. However, in truth and in fact,
the activities undertaken by Greg Lapatis at the time was to promote his
fraudulent land acquisition operations to collect and extract money from
unsuspecting victims with promises of hefty commissions and shares in
the mark up or overprice of the lands he (Lapatis) has approved for
acquisition allegedly in behalf of Empire Group, Ltd., as follows:
20.a. Nine (9) Extracts or excerpts of the e-mail messages and
exchanges through Yahoo mail between Greg Lapatis and
Christopher Crutcher contained in two (2) pages covering the
period September 10, 2018 until December 29, 2019
20. b. Twelve (12) pictures contained in three (3) pages showing
Greg Lapatis presenting the mission and vision of Project Galileo
which was extracted from the Internet to several invited audiences
at his house and office at Barrio Obrero, Lapuz, Iloilo City.
20.c. Seven (7) pictures contained in two (2) pages showing people
(who were actually brokers, agents and owners) lead by Greg
Lapatis and complainant Mana-ay wearing black t-shirts printed in
the front upper portion with Empire Group and at the front lower
portion with Project Galileo, Philippines.
 10

20.d. Nineteen (19) pictures contained in five (5) pages wherein

Greg Lapatis displayed, exhibited and used a photo of himself
posing with Christopher Crutcher way back when they met each
other in Angeles City, Pampanga in June 2018 to prove the veracity
of his claim of having a foreign investor.
20.e. A picture of complainant Aurelio Mana-ay addressing an
audience of real estate brokers, land agents and invited indigenous
people of the legitimacy and authenticity of the land acquisition
scheme of Greg Lapatis. Exploiting his condition as a person with
disability (PWD), he made testimonies to the effect that even he
who is a disabled person is committed to fulfillment of the
humanitarian programs of Empire Group, Ltd. to alleviate the life
and lot of humanity primarily the indigenous people of the
Philippines. In his testimonies before this crowd of real estate
brokers, land agents and land owners Complainant Mana-ay claimed
that Empire Group, Ltd. is willing to pour in billions of dollars of
investment in the Philippines which will employ thousands of people
and revitalized our economy.

(For the purposes of this Judicial Counter-Affidavit, the above enumerated

documents are marked, as follows: Two (2) pages of e-mail exchanges
referred to in 20.a as Annexes “3” and “3-A” , Three (3) pages of
pictures referred to 20.b. as Annexes “3-C”, “3-D” and “3-E”, Two (2)
pages of pictured referred to in 20.c. as as Annexes “3-F” and “3-G”),
Five (5) pages of pictured referred to in 20.d. as as Annexes “3-H”,”3-
I”, “3-J”, “3-K” and “ 3-L“ The picture referred to in 20.e as Annex “3-
M”)

21. Q: Aside from the above, do have you other pictures or documents of
the activities undertaken by Greg Lapatis, complainant Aurelio Mana-ay
and their swindling cabal, prior to the arrival of Christopher Crutcher in
the Philippines on December 29, 2019?

21. A: Yes, sir. I have multiple pictures of the activities of Greg Lapatis,
complainant Mana-ay and their swindling gang in pursuit of Lapatis’
fraudulent land acquisition operations prior to the arrival of Christopher
Crutcher in the Philippines. These pictures basically fall into two (2)
categories namely: first, the gathering and consolidation of documents of
the lands being offered for sale and second, the site inspection of the
properties targeted for acquisition. The pictures falling into the first
category as as follows:
21.a. Twenty (20) pictures contained in seven pages showing Greg
Lapatis and his confederates gathering and consolidating the
ownership documents of the lands being offered for sale.
21.b. Twenty one (21) pictures of the site inspections conducted by
Greg Lapatis joined by his swindling cabal of complainant Mana-ay,
Jose Reden de Juan and Leizl Aragones in Negros Island allegedly to
evaluate the suitability of the properties submitted for sale through
Lapatis bogus land acquisition operations.
21.c. Fourteen pictures contained in three (3) pages of the site
inspections conducted by Greg Lapatis joined by his swindling cabal
of Jose Reden de Juan and Leizl Aragones in Palawan Island
allegedly to evaluate the suitability of the properties submitted for
sale through Lapatis bogus land acquisition operations.
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(For the purposes of this Judicial Counter-Affidavit, the above

enumerated documents are marked, as follows: Twenty (20)
pictures contained in seven pages showing Greg Lapatis and his
confederates gathering and consolidating the ownership documents
of the lands being offered for sale referred to in 21.a. as Annexes
“4”, “4-A”, “4-B”, “4-C”, “4-D”, “4-E”and “4-F”
Twenty one (21) pictures of the site inspections conducted by Greg
Lapatis joined by his swindling cabal of complainant Mana-ay, Jose
Reden de Juan and Leizl Aragones in Negros Island allegedly to
evaluate the suitability of the properties submitted for sale through
Lapatis bogus land acquisition operations referred to to in 21.b as .
as Annex “4-G”
Fourteen pictures contained in three (3) pages of the site
inspections conducted by Greg Lapatis joined by his swindling cabal
of Jose Reden de Juan and Leizl Aragones in Palawan Island
allegedly to evaluate the suitability of the properties submitted for
sale through Lapatis bogus land acquisition operations referred to in
21.c. as Annexes “4-F”, “4-G” and “4-H”.

22. Q: Are you saying that Greg Lapatis aided by complainant Aurelio
Mana-ay and their co-conspirators, cohorts and confederates launched the
land acquisition operations full steam ahead even if the alleged investor
was not even present to certify or approve the same or has issued any
written, formal, valid or legal authority for such activity to be undertaken
in his behalf?

22. A: Yes sir. Greg Lapatis and his cabal led by complainant Aurelio
Mana-ay, Jose Reden de Juan, Leizl Aragones acted with certainty and
confidence as if they have all the legal authority to represent and act for
and in behalf of Empire Group, Ltd. and Christopher Crutcher.

23. Q: Considering that you are the communications man of Greg Lapatis
in 2018 through 2019 who prepares his e-mails, uploads and sends his
pictures and videos through the internet to Christopher Crutcher, what
was the schedule for Christopher Crutcher to visit the Philippines at the
time?

23. A: In reply through messenger/e-mail on January 22, 2019 due to the

persistent invitation by Greg Lapatis to visit the Philippines, Christopher
Crutcher communicated that he has tentative plans to visit the Philippines
as soon as he completes his commitments to his projects in other
countries. Christopher Crutcher congratulated Greg Lapatis for the
activities he has undertaken to promote Christopher Crutcher’s
humanitarian projects as shown by the pictures Lapatis has uploaded to
him. In April 29, 2019, Christopher Crutcher through messenger/e-mail
messaged that he is firming up his plan to visit the Philippines.

24. Q: When did Christopher Crutcher, actually arrive in Iloilo City?

24. A: He arrived in the Philippines on December 25, 2019 and proceeded

to Iloilo City on December 29, 2019.

25. Q: Mr. Witness, to be clear and definite about the facts and
circumstances, Greg Lapatis launched and engaged in his land acquisition
 12

activities allegedly for and in behalf of Christopher Crutcher eighteen (18)

months prior to the arrival of Christopher Crutcher in Iloilo City?

25. A: Yes sir.

26. Q: What happened when Christopher Crutcher arrived in late

December 2019, in terms of his accessibility to the public?

26. A: Greg Lapatis curtailed accessibility by anyone to Mr. Christopher

Crutcher. Anyone who wants to talk to Mr. Christopher Crutcher has to ask
the permission of Greg Lapatis. Only Greg Lapatis close confidants such as
complainant Aurelio Mana-ay, Jose Reden de Juan and Leizl Aragones
have access to Mr. Christopher Crutcher while the rest of us cannot come
near Mr. Crutcher unless allowed by Greg Lapatis.

27. Q: On the other hand, what was happening in so far as the land
buying operations of Greg Lapatis, complainant Aurelio Mana-ay, Jose
Reden de Juan and their close associates?

27. A: Upon the arrival of Christopher Chrutcher, Greg Lapatis,

complainant Aurelio Mana-ay and their swindling gang consolidated the
documentation of the properties submitted for acquisition to the real
estate office of Greg Lapatis at Barrio Obrero, Lapuz, Iloilo City. The
consolidation of the documents entailed the verification, evaluation and
validation of the documents submitted as to its completeness and
compliance with the requirements prescribed and to prioritize which
property should be acquired first. People scrambled to contribute money
to the coffers of Lapatis and his swindling gang because Lapatis was able
to produce the foreign investor he touted he will bring in and every
wanted that their properties will be prioritized for payment. Among those
who gave millions of pesos in money to Lapatis and Mana-ay and their
gang were Zenaida Aguilar, Lina Deslate, Maruja Reyes and Liezl
Consolacion who were the sponsors who paid for the expenses for the stay
of Christopher Crutcher and also paid for all the food and monetary
expenses of Greg Lapatis and all the people involved in the land buying
operation scam.

28. Q: On the part of Mr. Christopher Crutcher, what was his involvement
in the land buying operations of Greg Lapatis, complainant Aurlio Mana-ay
and their swindling gang?

28. A: Mr. Christopher Crutcher has no participation whatsoever in the

land buying operations of Greg Lapatis, Aurelio Mana-ay and their
swindling gang. Christopher Crutcher does deal nor negotiate with the real
estate agents and the landowners personally. Those people negotiated
with Greg Lapatis directly and exclusively and he was aided by
complainant Aurelio Mana-ay and the other members of their swindling
gang who are the false complainants in this case.

29. Q: What else did Greg Lapatis and Aurelio Mana-ay aided by
swindling gang do in pursuit of their fraudulent land buying operations?

29. A: In pursuit of their fraudulent land buying operations, Greg Lapatis,

Aurelio Mana-ay organized visits or tours by Christopher Crutcher to
 13

several places in the Philippines such as Palawan, Guimaras, Negros

Occidental, Negros Oriental, Capiz, Antique, Aklan and several other areas
purported to inspect the properties suited for the projects Christopher
Crutcher would recommend to his investors abroad. However, these visits
and tours for the benefit of Christopher Crutcher were merely camouflage
or smokescreen for Greg Lapatis, complainant Aurelio Mana-ay and their
swindling gang to perpetrate their land buying scam by soliciting and
collecting money from real estate or land agents by parading Greg Lapatis’
alleged foreign investor before the public. Greg Lapatis, Aurelio Mana-ay
and their swindling gang used and took advantage of Christopher Crutcher
to further the fraudulent scam by saying that here is our investor and
financier, give us some money so that we will prioritize your lands for the
purchase by the investor.

30. Q: Do you have proof or evidence of the said tours or visits of

Christopher Chrutcher to several places organized by Greg Lapatis,
complainant Aurelio Mana-ay and their swindling gang?

30. A: Yes, sir. I have personally taken pictures and recorded videos of
those tours and visit purportedly for site inspection to determine the
suitability of the land for the implementation of viable humanitarian
projects which I am hereby marking and attaching to this Judicial
Counter-Affidavit, as follows:
30.a. Four (4) pictures contained in one (1) page showing Greg
Lapatis, complainant Aurelio Mana-ay and Jose Reden de Juan
accompanying Christopher Crutcher on site inspection of areas in
Iloilo Province that the Lapatis swindling cabal recommended as
locations for the development of Project Galileo.
30.b. Four (4) pictures contained in one (1) page showing Greg
Lapatis, complainant Aurelio Mana-ay and Jose Reden de Juan
accompanying Christopher Crutcher on site inspection of areas in
the Province of Guimaras that the Lapatis swindling cabal
recommended as locations for the development of Project Galileo.
30.c. Four (4) pictures contained in one (1) page showing Greg
Lapatis, complainant and Jose Reden de Juan accompanying
Christopher Crutcher on site inspection of areas in Province of
Negros that the Lapatis swindling cabal recommended as locations
for the development of Project Galileo.
30.d. Four (4) pictures contained in one (1) page showing Greg
Lapatis and Jose Reden de Juan accompanying Christopher Crutcher
on site inspection of areas in Province of Romblon that the Lapatis
swindling cabal recommended as locations for the development of
Project Galileo.
(For the purposes of this Judicial Counter-Affidavit, the above enumerated
documents are marked, as follows: Four (4) pictures referred to in 30.a
as Annex “5”, Four pictures referred to in 30.b. as Annex “5-A”, Four
(4) pictures referred to 30.c. as Annexes “5-B”, Four pictures referred to
in 30.d. as Annex “5-C”)

31. Q: How long did these state of affairs continued?

31. A: Starting the month of January 2020, Greg Lapatis organized this
visits of Christopher Crutcher to several places initially in Panay Island,
Guimaras and onward to other places in the Visayas. These trips were
 14

financed by the interested landowners and agents who have great

expectations that their lands will be purchased by the investor through the
intercession of Greg Lapatis. All the money raised and collected for the
trips were given to, controlled and disbursed by Greg Lapatis. If the
landowners and the real estate agents want Greg Lapatis and Christopher
Crutcher to visit their area, they have to send money to Greg Lapatis to
finance the visit. This modus operandi of Greg Lapatis and his swindling
gang started in January 2020 and ended in the middle of May 2020.

32. Q: Why did it end?

32. A: Christopher Crutcher discovered and came to realize that he was

being used and exploited by Greg Lapatis, complainant Aurelio Mana-ay,
Jose Reden de Jesus and their swindling gang as a prop or window
dressing for their fraudulent scheme to solicit, extort and collect money
from landowners and real estate agents in exchange for a promise that
they will prioritize their properties when the foreign investor pay for the
lands being offered for sale. Thus, a bitter quarrel or disagreement ensued
between Greg Lapatis and Christopher Crutcher which ended their
relationship.

33. Q: Going back to the allegations of complainant Aurelio Mana-ay in his

Judicial Affidavit dated July 2, 2020. In answer to question number 14 in
his Judicial Affidavit, complainant Mana-ay stated that Greg Lapatis told
them that he (Greg Lapatis) met Christopher Crutcher at Subic, Angeles
City, Zambales in June 2018 where Mr. Crutcher offered Mr. Lapatis to be
his point man or trusted contact in Iloilo City for his corporations known
as “Empire Group Philippines” and Project Galileo, Philippines and other
investment ventures under the auspices of Project Galileo Group. X x x x
x That Mr. Crutcher allegedly needs vast parcel of lands in Western
Visayas that have capacity in agriculture, tourism, aqua culture,
commercial-industrial properties for the projects and he (Crutcher)
allegedly tasked Mr. Lapatis of contacting would be sellers of properties
and get documentations of properties that are being sold in the Western
Visayas Region as he (Christopher Crutcher) made representations that
his firms will be buying his said properties with promise to pay and
reimburse all expenses incurred thru his (Crutcher) mobilization fund,
what do say to that?

33. A: Most of the claims of Aurelio Mana-ay in his said answer were
outright lies. First and foremost, whatever complainant Mana-ay, claims
on what transpired during the meeting between Greg Lapatis and
Christopher Crutcher in June 2018 are clearly hearsay statements because
he did not have personal knowledge of what he is talking about and he
derived his information from Greg Lapatis who clearly enhanced his story
to his own advantage. Further, if complainant Mana-ay applied some due
diligence to back check the story of Greg Lapatis considering that he
claims to be a licensed real estate broker and have extensive experience
in real estate transactions, he would have found that there was no legal or
formal authority in favor of Greg Lapatis to transact business for and in
 15

behalf of Christopher Crutcher or Empire Group, Philippines. In fact, at the

time there was no legal entity as Empire Group, Philippines nor was there
any legal document authorizing the Empire Group to do business in the
Philippines. He did not do such due diligence, because in truth and in fact,
he was in conspiracy and complicity with Greg Lapatis to launch a
fraudulent land acquisition operations to defraud and swindle the public at
large by falsely representing that Greg Lapatis has a foreign investor or
funder who authorized him to negotiate the acquisition of vast tracts of
land in the Philippines. To entice the public of such romantic concepts of
vast money being poured for humanitarian projects is easy but how to
implement the same under Philippine law and jurisdiction is a legal
nightmare.

34. Q: In his answers to questions numbers 15 and 16 in his Judicial

Affidavit complainant Mana-ay stated that Christopher Crutcher and Greg
Lapatis had an agreement or contract to engage in the real estate
transaction of Project Galileo. He claimed that their agreement is
contained in a letter by Christopher Crutcher to Greg Lapatis. Further,
complainant Mana-ay attached and marked the said letter as part of the
NBI evidence. Do you have knowledge of said letter and what can you say
about that?

34. A: Yes, sir. I am very familiar and aware of the said letter having
closely worked with Greg Lapatis and Christopher Crutcher in their
administrative and communications requirements. Firstly, the letter
alluded to by complainant Mana-ay was dated sometime in January 2020.
Thus, this is the second lie, misinformation and misrepresentation
committed by complainant Mana-ay in his Judicial Affidavit. To my
personal knowledge, Greg Lapatis and complainant Aurelio Mana-ay and
their cabal have been immersed in the land acquisition operations of Greg
Lapatis since June 2018 when I and Greg Lapatis arrived from Angeles
City, Pampanga after a three (3) day series of meetings with Christopher
Crutcher. Hence, it is clear and definite that eighteen months prior to the
arrival of Christopher Crutcher in Iloilo City, Greg Lapatis and complainant
Mana-ay have been engaging in the land acquisition operations of Greg
Lapatis allegedly in favor of Christopher Crutcher without any formal or
written authority from the latter. Then, complainant Mana-ay claimed that
Christopher Crutcher and Greg Lapatis had an agreement or contract to
engage in the real estate transaction of Project Galileo which was allegedly
contained in a letter by Christopher Crutcher to Greg Lapatis. In this
regard, to rebut the claim of complainant Mana-ay, a letter is not a
contract because a contract has legal formalities which should be signed
by the contracting parties as to the terms and conditions of their
agreement. Further, a perusal of the letter alluded to by complainant will
show that Greg Lapatis was not authorized to engage in real estate
transactions of Project Galileo but merely to conduct research and
discussions with local governments and land owners especially for
 16

potential joint ventures and long term leases. The language of the letter is
clear, unequivocal and speaks for itself. However, complainant Mana-ay in
his twisted mind read more meaning than what is actually written and the
import of the said written words. The other complainants echoed in toto
the allegations of complainant Mana-ay as if they were his clones or their
judicial affidavits were just cut and paste from the judicial affidavit of
main complainant Aurelio Mana-ay.

35. Q: In his answers to questions numbers 17 and 18 in his Judicial

Affidavit complainant Mana-ay stated that he was instructed by Greg
Lapatis to look for potential real properties for sale in Western Visayas.
Thus, he mobilized his network in the real estate industry to look for
properties to be indorsed to Christopher Crutcher. He also said that he
was able to process, facilitate and consolidate about 1,700 hectares of
properties for such purpose which he submitted to Greg Lapatis to be
endorsed collectively to Christopher Crutcher later. Mana-ay also stated
that he did all of those things in consideration or expectation of the return
or refund of his expenses as well as gaining commissions/incentives from
the said transactions. What can you say to that?

35. A: These statements of complainant Aurelio Mana-ay are blatant lies,

deceptions and misrepresentations. In the first place, when Lapatis and
Mana-ay started their land acquisition scam in June 2018, there was no
written or legal authority for Lapatis to represent or negotiate for and in
behalf of Empire Group, Ltd. or Christopher Crutcher. As his (complainant
Mana-ay) own evidence show that the letter he claimed to be the basis of
Greg Lapatis’ authority to represent Empire Group, Ltd. came only into
being in January 2020 which was 19 months after they have embarked in
their land acquisition scam. In the second place, how would complainant
Mana-ay aspire and expect Christopher Crutcher to refund or return his
expenses and give him commissions and incentives when he was not even
present in the Philippines at the time and he will be arriving 18 months
later. Second, there was no mention in the messenger or e-mail
conversations between Lapatis and Crutcher of any purchase of lands for
any purpose. Third, it was Greg Lapatis, complainant Mana-ay, Jose Reden
de Juan and Leizl Aragones who designed, created and proposed a
commission scheme for the brokers and the land agents who will
participate in the land acquisition program. Further, Lapatis also designed
and proposed an overprice or mark-up scheme for buying price of the land
to be shared by him, the land brokers and agents and the landowners.
Christopher Crutcher on the other hand, has no participation in the
creation and design of the commission schemes, mark up and overprice. It
was all Lapatis, Mana-ay and their ilk.

36. Q: Why did you side with Christopher Crutcher in his dispute and
quarrel with Greg Lapatis?

36. A: I realized that Christopher Crutcher was merely used by Greg

Lapatis, Aurelio Mana-ay and their swindling gang to further their
fraudulent schemes. I sympathize with Christopher Crutcher because I
was also blinded by the promises of Greg Lapatis that he will give me an
 17

executive position with a high salary in a corporation he will establish with

his foreign investor. Said promised never materialized. When Christopher
Crutcher arrived, Lapatis restricted access to Crutcher even from us who
were part of his land operations group. It is to be considered that
Christopher Crutcher is a foreigner and does not understand the Pilipino
language, more so, the local dialects we have here. He could not
communicate with the local people and merely relied on the people he is
allowed to talk to such as Greg Lapatis, complainant Aurelio Mana-ay and
other Lapatis core group such as Jose Reden de Jesus and Liezl Aragones.

37. Q: You are being included as a respondent in this criminal complaint

allegedly being in conspiracy with main respondent Christopher Crutcher,
in the judicial affidavits of the complainants, what acts of conspiracy did
they alleged you have committed?

37. A: The judicial affidavits of all the complainants did not specify any
act of conspiracy that I have committed. All the Judicial Affidavit
concentrated on the alleged criminal acts of the main respondent
Christopher Crutcher. There was no mention of my participation in any
alleged illegal act of Christopher Crutcher except that I was imputed to be
a Consultant and Head Real Estate Evaluator of Project Galileo,
Philippines, Project Galileo Rising, Philippines and Empire Group.

38. Q: What is your reaction to the said imputation upon you by

complainant Aurelio Mana-ay and by the other complainants?

38. A: I was baffled and bewildered how complainant Mana-ay and the
other complainants came up with the idea and characterization of my role
in the alleged organization of Christopher Crutcher. I have more
participation and involvement in the organization of Greg Lapatis because
for the duration of the build up of the relationship between Greg Lapatis
and Christopher Crutcher, I was the assistant and communications guy of
Greg Lapatis. I have no knowledge nor did I ever engage in any real
estate transaction. I know for a fact that Christopher Crutcher also never
engaged in any real estate transaction in the Philippines. Project Galileo,
Philippines and Project Galileo Rising, Philippines are merely incipient
concepts and ideas which were in the process of creation, realization and
formalization into concrete legal entities and personalities. Empire Group,
Ltd., is an offshore business entity which has yet to apply for a license to
operate or do business in the Philippines. It was Greg Lapatis and
complainant Aurelio Mana-ay who misrepresented themselves to be
cloaked with power and authority to represent Empire Group Ltd. in the
negotiation to acquire vast tracts of lands for its alleged humanitarian
projects

39. Q: By the way, do you know any of the complainants and interacted
with any of them?

39. Q: I know complainant Aurelio Mana-ay who is a close associate and

confidante of Greg Lapatis and an integral part of his swindling gang. I
also know Joemarie Beriber who is also a close confidant of Greg Lapatis
and an integral part of his swindling gang. I also know Marlon Occeno who
is photographer of Greg Lapatis. I also know Annie Mana-ay, the sister of
Aurelio Mana-ay who is a cook and helper in the household of complainant
 18

Mana-ay. I also know Balbino Tiezo who is a bodyguard of Greg Lapatis. I

also know Susan Movera who is the wife of Feliciano Movera, a bodyguard
of Greg Lapatis. I know complainant Lelita Anas who is one of the
sponsors of Greg Lapatis. I barely know Jonalyn Joy Alagao who I believe
I only met once in my life.

40. Q: All the complainants claim that they sustained damages in terms of
money which they invested in the project of Christopher Crutcher, what
can you say to that?

40 A: That is not true and a very laughable claim. All these people have
no clear and visible source of income. First and foremost, they have no
gainful employment. Where did all these money they claim they lost came
from? Let’s take the case of complainant Aurelio Mana-ay. What is his
source of income? Does he have an Income Tax Return to prove that he
earned this much in a year? Did he have properties which he sold to invest
in the project of Christopher Crutcher? As far as I know, he had some
money because was able to collect and extract money from innocent
people because of his connection to the land buying scam of Greg Lapatis.
All the rest of the complainants are all hangers on and tools of Greg
Lapatis who rely on his swindling scams to earn some good money.

41. Q: Do you have anything more to say?

41. A: Yes, I have much more to say about the fraudulent schemes of
Greg Lapatis, Aurelio Mana-ay and their swindling gang. However, for the
purpose of my counter-affidavit against this criminal complaint filed
againsts me and my co-respondents, the statements I made here I
believe are sufficient at this point in time.

42. Q: Do you affirm and confirm to the truthfulness of your foregoing

affidavit or statement?

42. A: Yes, sir.

43. Q: Are you aware or do you understand that you answering these
questions asked of you under oath and that you may face criminal liability
for false testimony or perjury?

43. A: Yes, sir.

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

day of November 2020 at Iloilo City, Philippines.

CLEMENTE R. LAGUDA IV

SUBSCRIBED AND SWORN to before me this ____ day of

November 2020 at Iloilo City, Philippines. The affiant whose name and
personal circumstances are stated above appeared in person before me
and known to me, signed this Judicial Affidavit in my presence and
affirmed or swore, under oath to the correctness of the contents of the
allegations therein.
 19

SWORN ATTESTATION OF THE LAWYER

(Who conducted or supervised the examination of the witness)

I, RENE S. SARABIA, of legal age, Filipino, married and a resident

of E. Lopez Street,, Jaro, Iloilo City, under oath declare:

That I was the lawyer who conducted and supervised the

examination of the witness who executed the foregoing judicial affidavit;

That I faithfully recorded or caused to be recorded the questions I

have asked and the corresponding answers that the witness gave, and

That I have not nor any other person then present or assisting me
coached the witness regarding the latter’s answers.

IN WITNESS WHEREOF, I hereunto set my hand this ___ of

November 2020 at Iloilo City, Philippines.

RENE S. SARABIA

SUBSCRIBED AND SWORN to before me this ____ day of

November 2020 at Iloilo City, Philippines. The affiant whose name and
personal circumstances are stated above appeared in person before me
and known to me through his Tax Payer’s Identification Number 191-756-
697 as competent evidence of identify, presented the foregoing sworn
attestation, signed the same in my presence and affirmed or swore under
oath to the correctness of the allegations contained thereof.