COUNTER-AFFIDAVIT

I, James Reid, 27 years old, male, single, Filipino, and a resident of

Purok 7, Ayala, Zamboanga City, after having been duly sworn to in
accordance with law, do hereby depose and state:

1. That I am the respondent in Criminal Case NPS Docket No.

123456 for the crime of Rape under Article 266-A, par. 1(b), of the
Revised Penal Code;

2. That I am executing this Counter-Affidavit as a reply and comment

to the Complaint-Affidavit of Nadine Alexis Paguia Lustre who is
under investigation by this Honorable Office in connection with the
case filed against me;

3. That I vehemently denies all the allegations that she stated on her
complaint-affidavit having raped Ms. Lustre, in violation for the
crime of Rape under Article 266-A, par. 1(b), of the Revised Penal
Code;

4. That I deny the allegations contained in the complaint impugning

me of having raped Nadine, in violation of Article 266-A, par 1(b),
of the Revised Penal Code;

5. That I admit I was persistently knocking to the door that she thought
that there was some sort of emergency. So, she hurriedly wrapped a
towel on her torso and went out of the bathroom and partially opened
the door to check out who was knocking as stated in her Judicial
Affidavit.

6. That I know the complainant as residing in the same barangay where

our residence is located but have not maintained any close
relationship with her or her family.
7. That is it physically impossible for me to commit the crime charged
because after I delivered the milk I already went out the house
due to the facts that Ms.Lustre is about to take her bath and was
already wrapped in a towel.

8. That the allegations stated in the affidavit-complaint are mere

malicious fabrications by the complainant which may have been
spurred by the bitter enmity harbored by members of her family
arising from dispute that involved both our families from way back
before.

9. I am executing this counter-affidavit for the purpose of attesting to

the truth of the foregoing statements, to inform the proper
authorities of the above facts, to support my prayer for the
dropping or dismissal of the instant case against me and for
whatever purpose this may serve best.