REPUBLIC OF THE PHILIPPINES

Department of Justice
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
Tagbilaran City, Bohol

DAD SERIUS
Complainant, NPS No. VII-02-XXX-XXX-XXXX
For:
-versus QUALIFIED SEDUCTION

AGUSTIN VIBER,
Respondent.

COUNTERAFFIDAVIT

I, AGUSTIN VIBER, Filipino, of legal age, single, and presently residing at Purok 2,
Cogon, Tagbilaran City, Philippines, the respondent of the above case, after having been sworn
in accordance with law, hereby depose and say THAT:

1. I am the High Priest of the religious sect Paglipay Church, duly registered with the
Securities and Exchange Commission with Company Reg. No. C00000000.

2. Paglipay Church conducted the Adlaw sa Pagmaya last December 25, 2015 at our
Main Church at 344, 9th Heaven Street, Red Light District, Tagbilaran City. This is a
whole day activity, from 8 AM to 12 AM the next day, where the faithful praise the
Almighty with songs and dances together with counseling for the members of the
church.

3. After dinner at 7:00 PM I told the members of the church that the Adlaw sa
Pagmaya has concluded but I requested the parents to leave their youth until 12 MN
behind for the Special Prayer Service for them. It is mandated by our religious
doctrine that Special Prayer Service should be done at night for each individual in
order to commune with God more intimately.

4. At around 7:15 PM, I convened the remaining youth members of our church and
informed them that the Special Prayer Service will start at 8:00 PM as I needed to
rest. Thereafter I proceeded to the High Priest Chambers and sat in my reclining
office chair to relax.

5. At around 7:30 PM, at the High Priest Chambers, MAY LEE SERIUS, hereinafter
referred as MAY, the daughter of the complainant, DAD SERIUS, approached me
and offered a glass of Iced Tea. As I was thirsty and because she was also a very
religious girl I readily accepted her drink, thanked MAY, and thereafter drank the
 majority of the Ice Tea in the glass. Together with me in the chambers is my
assistant, DEXTERIO CHAN ROBLEX, hereinafter referred as DEX, who is at that
moment cleaning the chambers.

6. I requested MAY to also give DEX a glass of Iced Tea. MAY then said that she will
not give DEX a glass as he is not worthy of her affection. Puzzled by her reaction, I
gave a stern look at MAY and told her to please watch her words. MAY just smiled
and left immediately. I then told DEX, who also had a puzzled look, on what is wrong
with that girl and he said he does not know.

7. At around 8:00 PM while resting I suddenly felt a sudden and extreme sense of
Euphoria and a feeling of inner peace. I did not know why but I was always smiling
even though I was really tired. I also felt that which arms and legs have become
really weak.

8. I repeatedly tried to stand to pick up the Bibos, our religious book, in the book shelf
near my chair but could not due to weakness of my limbs. DEX noticed my hard ship
and asked on whether I was ok while assisting me on standing up. I told him my
predicament and requested him to pick the Bibos and place it in my table. DEX then
asked me if it is really ok to proceed with the Special Prayer Service Given my
condition. I told him that it was ok as I can still use my fingers to open the pages of
the Bibos and I could still speak loudly.

9. At 8:15, the Special Prayer Service began. I called the first youth in line outside. Also
at that time DEX requested to leave to go home. He told me to call him in case I will
have difficulty in moving around or going home. I gave DEX permission to leave and,
still feeling really happy, euphoric but paralyzed, thereafter proceeded with the
Special Prayer Service of the first youth.

10. At around 10:00, after many youth have finished the Special Prayer Service, I still
felt euphoric and at peace. I still cannot move my arms and legs as in fact the
paralysis has worsened. I also felt a slight headache and I was sweating profusely. I
was thirsty and I felt dehydrated. I also felt a slight grinding and clenching of my
teeth,

11. A few minutes after MAY entered the chambers and closed the door. I noticed that
she locked said door and asked her why did she lock the door. She then said that I
will be owned by her. Puzzled, I asked her what does she mean by those words. She
immediately took off her clothes and removed her bra and panties. She squeezed
her breasts and touched her vagina and inserted her fingers to it repeatedly with
apparent grunts and moans. I was really shocked and angrily asked her on what she
was doing. She just smiled and thereafter approached me. I tried to move and
distance myself but I cannot due to inability to move my hands and feet. MAY then
took off first my polo and suddenly licked my nipples repeatedly. I felt a weird intense
increase in bodily sensations and perceptions than I was used to, even though my
 mind does not want to feel it. I was thinking on whether she put something in the iced
tea she offered me to drink. She thereafter removed my pants and my brief. She then
proceeded to fellate me for a few minutes and then reclined my chair downwards and
sat on top of me, forcible positioning herself in making my penis enter her vagina.
MAY moved intensely up and down afterwards. I wanted to stop her but I still cannot
move. I was really confused and disgusted by what she is doing and thereafter told
her that she will regret it and that she will soon submit to the will of the most high for
judgement. The movements done by MAY, together with the weird feeling of really
enhanced sensations, made me orgasm inside her. Afterwards I angrily told her that
she will pay for what she has done. She then said mockingly to me that she has
done these acts with many other high ranking people in religion and she always got
away with it, and it was I who will face the judgement by the law. She then hurriedly
wore her clothes and removed a small plastic container in her pocket, opened it, and
applied some substance in her eyes which immediately produced tears. She then
smiled at me with fake tears in her eyes and left the chambers with the door
unlocked. At around 10:30 PM, while still naked and paralyzed, I felt really sleepy
and slept afterwards in my reclining chair.

12. The statements in paragraph 4 of the Sworn Statement of ROBERTO CICERO are
thus misheard statements. The statement that I said that it is duty of the faithful to
submit to the will of the Most High and of His Priest is inconsistent with what I really
said at that time.

13. The next day, December 26, 2015, at almost 9:00 AM I was woken up in the
chambers by DEX and another assistant RECHILDE GALLOGERO, hereinafter
refered as CHIL, and they shockingly asked on why I was naked. I noticed I had
difficulty opening my mouth and narrated the events to them in a muddled voice
which they said they understood. DEX immediately assisted me in wearing my
clothes. I tried to stand and walk but I fell down because I still had weakness. CHIL
assisted me in standing up and both DEX and her decided to accompany me to the
nearest Doctor.

14. At 9:30 AM, I was brought to the clinic of Dr. Cecilio Claretero at BITICOX Hospital at
Manga, Tagbilaran City for him to check my medical condition. Dr. Claretero gave a
medical certificate (See ANNEX A) saying that I am experiencing Hyperthermia,
grinding and clenching of the teeth, lock jaw, loss of appetite, dehydration, and
increased dilation of the Iris, together with a recommendation for a need for chemical
analysis of hair, blood, and urine, as well as for admission at the hospital.

15. I was thereafter admitted at BITICOX Hospital at Room 69X on 10:15 AM (See
Certificate of Confinement of said hospital as ANNEX B). Fearing that I may have
been drugged by May, I requested CHIL to retrieve the glass of Iced Tea, which was
not all consumed in the high priests chambers, and submit to the hospitals affiliate
BITICOX Chemistry Laboratory, a registered chemical analysis company, for them to
compare with the chemical contents with my blood, urine, and hair. I specially
 informed CHIL to be accompanied by the Punong Barangay in retrieving the sample
up to examination at the laboratory to attest on future questions regarding the chain
of custody of the sample. At 10:30 AM, nurses retrieved samples of my urine, blood,
and hair.

16. The statements of paragraphs 12 and 13 of the Sworn Statement of Dad Serious are
thus blatant lies. The screaming and punching supposedly done to me by Mr.
Serious at the Main Church never happened as I was not there. Hence, it is
impossible for me to have told Mr. Serious that MAY and I are lovers nor did some
sacristans save me.

17. The next day, December 27, 2015 I was still admitted. At 10:00 AM, CHIL delivered
to me the results of the chemical analysis (See ANNEX C for the Ice Tea, ANNEX D
for the blood, hair, and urine) which showed that both the Iced Tea and my blood,
hair, and urine samples contained dangerous amounts of 3,4-methylenedioxy-
methamphetamine commonly known as Ecstasy, Ketamine, gamma hydroxybutyric
acid also known as GHB, and flunitrazepam also known as Rohypnol. These drugs
are called date rape drugs or predator drug, which are incapacitating agents which,
when administered to another person, incapacitates the person and renders them
vulnerable to a drug facilitated sexual assault, while having an immediate effect of
euphoria and enhanced bodily sensations and perceptions (Lyman, Michael D.
(2006). Practical Drug Enforcement (3rd ed.). Boca Raton, Fla.: CRC. p. 70.).

18. It is therefore safe to conclude that these chemicals present in the Iced Tea given by
MAY that I drank resulted to my paralysis, increased sensitivity to bodily stimuli, and
subsequent experience of adverse symptoms which prevented me from stopping the
evil acts of MAY.

19. With this we can deduce that the malicious plan of MAY is to frame me with the
crime of Qualified Seduction. She will indubitably fail in this plan as intentional sexual
intercourse never happened as it was clearly the intent of MAY to have sexual
intercourse with me without my consent, and not the other way around. To make this
certain MAY necessitated the use date rape drugs. The physiological and
psychological effects of the date rape drugs will also make it impossible for abuse of
authority or confidence to be used in the situation. There is also no evidence
presented that showed intentional prior and present acts constituting abuse of
confidence. Finally, her statement that she has done these frame-ups with many
religious figures and her act of using date rape drugs will surely make her reputation
questionable.

20. That I execute this affidavit to attest to the truth of all the foregoing.
 IN WITNESS WHEREOF, I have hereunto set my hand this February 3, 2016, at
Tagbilaran City, Bohol, Philippines.

AGUSTIN VIBER
Affiant

SUBSCRIBED AND SWORN to before me this 3rd of February 2016, affiant exhibiting to
me his Drivers License No. G00-00-00000 issued on November 15, 2015 at LTO Tagbilaran
City and I hereby certify that I have examined the herein affiant and I am fully convinced and
satisfied that he voluntarily executed the affidavit in his own free will and volition and that he
understood all the contents of the same.

MARIA M. MANGUBAT
Assistant City Prosecutor
Tagbilaran City