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 MARUJA B. REYES

I, MARUJA B. REYES, of legal age, Filipino and a resident of Brgy.

Bontongon, Estancia, Iloilo, 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 MARUJA B. REYES, of legal age, Filipino and a

resident of Brgy. Bontongon, Estancia, Iloilo, Philippines.

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

2. Answer: 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.

3. Question: What do you say to this criminal complaint for Syndicated

Estafa filed by the above mentioned complainants?
 2

3. Answer: 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, I together
with respondent Lina Deslate, among others were swindled and defrauded
of millions of pesos by the Swindling Gang led by Greg Lapatis and
complainant Aurelio Mana-ay and 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. In
fact, I together with respondent Benjamin Jaleco and Lina Deslate joined
by some other complainants, have previously and earlier filed a criminal
complaint for Syndicated Estafa 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. This case is merely a counter-charge to the criminal
complaint we have filed earlier with the Iloilo City Prosecutor’s Office.

4. Question: You said that you together with respondents Lina Deslate,
Benjamin Jaleco and some other complainants have earlier and previously
filed a criminal complaint for Syndicated Estafa against complainant Mana-
ay, Greg Lapatis, Jose Reden de Juan and some others subject of
preliminary investigation of the Iloilo City Prosecutor’s Office, what was
the substance or essence of your criminal complaint?

4. Answer: We averred that Greg Lapatis, complainant Aurelio Mana-ay,

Jose Reden de Juan and Leizl Aragones were the brains and masterminds
of a swindling gang who in conspiracy and confederation with several of
the other complainants in this criminal complaint falsely claimed and
pretended that Lapatis has a foreign investor who will buy large tracts of
land in Iloilo, Guimaras, Negros, Mindoro, Palawan, Romblon and other
places here in the Visayas. Because of Lapatis false pretense that he has a
foreign investor with billions and billions of dollars, real estate brokers,
land agents and land owners visited and flocked to his house and office at
33 Waling-Waling Street, Barrio Obrero, Lapuz, Iloilo City. Greg Lapatis
promised all the real estate brokers, land agents that when his foreign
investor will pay the price of the lands, they (real estate agents and land
agents) will earn millions and millions of pesos in commissions. Because of
the promise of millions and millions of pesos in commission (I was among
those who believed in the promises of Lapatis), the multitude of real
estate brokers and agents like me, submitted documents of the lands
offered for sale. Greg Lapatis and his co-conspirators and confederates in
his office, charged and collected from the real estate brokers and agents
monies for notarial fees for the documents they (Lapatis and his group)
required, such as Special Power of Attorney, Authority to Sell and other
contracts they claim are needed to process the documentation of the
properties for sale. Greg Lapatis another fraudulent scheme is that he
 3

offered people like myself to invest in his operation on the promise that he
will give me a hefty return on my investment when his foreign investor
will pay the price of the land sold. Likewise, Lapatis collected and
extracted from several of us (namely Lina Deslate, Zenaida Aguilar, Liezl
Consolacion and me) monies for alleged operational expenses and
expenses to fund the lodging and itinerary of his foreign investor.

5. Question: Do you do know complainant Aurelio Mana-ay?

5. Answer: Yes, sir. I met him sometime around early September 2018
at the house and office of Greg Lapatis in Barrio Obrero, Lapuz, Iloilo City
in relation to my land transactions with Greg Lapatis.

6. Question: When did you meet this Greg Lapatis and what was the
purpose of the said meeting?

6. Answer: I met Greg Lapatis for the first time sometime in August 2018
at his house which also served as his office in Barrio Obrero, Lapuz, Iloilo
City together with my friends Cynthia Bonapus Santos, Carol Bonapus
Gonzales and Ferlyn de la Cruz who like me were from Estancia, Iloilo. I
also met for the first time at the house and office of Greg Lapatis, the
person of Jose Reden de Juan, a close associate of Lapatis and who is also
a friend of one of my companions Ferlyn de la Cruz. Greg Lapatis told me
and my group to look for landowners who own big tracts of land and who
are interested to sell their lands at a high price and he promised us that
he will give us a hefty commissions as real estate agents if the said lands
will be purchased by his buyer, funder or investor. He further told us that
if we join his group, we will be earning millions of pesos as commissions. I
was so convinced by his promises and assurances that I started
frequenting his house at Barrio Obrero, Lapuz, Iloilo.

7. Question: What did you do because you were promised by Mr. Greg
Lapatis that you will earn hefty commissions when his investor will buy the
lands where you are acting as an agent?

7. Answer: By reason of the promise of hefty commissions by Greg

Lapatis, I joined his group and frequented his house and office, starting
August 2018 bringing documents of ownership of landowners who are
offering to sell their lands.

8. Question: How were you able to believe that the promises of Greg
Lapatis might come true?

8. Answer: I saw so many people going to the house and office of Greg
Lapatis at Barrio Obrero, Lapuz who believed in his promises because I
saw said people bringing to him papers and documents on lands here in
Iloilo and from other places such as Negros, Guimaras, Romblon, Palawan
 4

and Mindoro. Said papers and documents on land are received and
checked his partners and co-conspiratiors such as Aurelio Mana-ay, Jose
Reden de Juan, Leizl Aragones, Joemarie Beriber and his other employees.

9. Question: Going back to complainant Mana-ay how often did you see
him at the house cum office of Greg Lapatis at Barrio Obrero way back in
late 2018 and what did you observe about him?

9. Answer: Every time I went to house of Greg Lapatis in 2018, which

was around three (3) times a week I almost always see Aurelio Mana-ay
present at the time. Aurelio Mana-ay who claims to be a real estate broker
was always loaded with folders containing documents of the properties he
is submitting for acquisition to Greg Lapatis.

10. Question: In the subsequent months after you first met him, what
information if any, did you know and learn about complainant Aurelio
Mana-ay?

10. Answer: I learned that Greg Lapatis and complainant Aurelio Mana-
ay have known each other for almost ten (10) years previously. They have
teamed up with each other in many transactions like treasure hunting,
mining, artifacts hunting, humanitarian programs for foundations, network
marketing for herbal medicines and food supplements, etc. In their
relationship, Aurelio Mana-ay was the brains and Greg Lapatis was the
implementor.

11. Question: You stated earlier that Greg Lapatis falsely pretended that
he has a foreign investor who will buy vast tracts of land which was the
basis of his land acquisition operations he is conducting through his office
at Barrio Obrero, Lapuz, Iloilo City. 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?

11. Answer: 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 of Companies. In behalf of Greg Lapatis, he likewise
monitors and directs 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. I refer to the commission scheme, mark-up or
overprice scheme, tenor 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
 5

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.

12. Question: Going back to your participation in the land acquisition

scheme of Greg Lapatis and his co-conspirators and cabal, you said earlier
that you brought documents on various lands to the house and office of
Greg Lapatis starting sometime in August 2018. What happened to those
various documents on lands that you brought and were received and
checked by the cabal and core group of Greg Lapatis at his house and
office at Barrio Obrero, Lapuz, Iloilo City?

12. Answer: I submitted copies of the land titles and tax declarations to
the office of Greg Lapatis. His secretary Leizl Aragones was the one who
received the documents and she gave forms which she alleged will be
used for landowner information, which requires the following: a) authority
to sell, b) exclusive authority to sell, c) Special Power of Attorney d)
Memorandum of Agreement, and e) Certification of No Tenants. The office
of Greg Lapatis charged P300.00 for the notarization of each of the
accomplished and completed forms. If there is an error or deficiency or
corrections in the accomplished forms, we have to pay again the notarial
fees of P300.00.

13. Question: Did the alleged “foreign investor” of Greg Lapatis already
arrived at the time?

13. Answer: Not yet. However, Greg Lapatis is always telling the throng
of real estate agents that the “foreign investor” is coming.

14. Question: Did Greg Lapatis identify his buyer of the lands or “foreign
investor” and when said foreign investor will arrive in Iloilo City?

14. Answer: The alleged name of his foreign investor is Christopher Wolf
Crutcher of the Empire Group, Ltd. and who will arrive at their house in
Iloilo City on October 2018.

15. Question: What did Greg Lapatis require in preparation for the arrival
of his investor Christopher Crutcher?

15. Answer: He asked and solicited money from land agents like me
who submitted documents of the lands proposed to be sold for the
accommodation expenses of his investor/buyer and for the food expenses
of all the people going to his house and for so called “operational
expenses” in exchange for the hefty commission that he will give to us
when his buyer/investor pays the value of the lands.
 6

16. Question: According to Greg Lapatis, when will his buyer or investor
arrive?

16. Answer: He first told us that his buyer or investor by the name of
Christopher Wolf Crutcher will arrive in the month of October 2018.

17. Question: Did the alleged buyer or investor of Greg Lapatis arrive at
the expected date?

17. Answer: The investor did not arrive. According to Greg Lapatis, he
was delayed because he had other things he had to attend to in other
countries.

18. Question: When again was the buyer scheduled to come to Iloilo.

18. Answer: Greg Lapatis again scheduled the arrival of his investor on
the month of January 2019, then March 2, 2019, then March 15, 2019 and
some other dates on the following months but his investor did not come.

19. Question: in the meanwhile that Greg Lapatis were arbitrarily

changing the schedule of the arrival of his buyer or investor, what did
Lapatis do to the land agents he has promised to give a hefty commission,
such as you?

19. Answer: He continued to ask and collect money from the land agents
and sponsors for his expenses for his family and his close-in people and
partners inside his house and office, and for alleged operational expenses
and he also asked for food in form of kilos of pork, fish, seafood, poultry,
rice, vegetables and others to feed all his people all those who come to his
house by dangling the promise that Christopher Wolf Crutcher is coming
bringing with him vast sums of money to pay all of us.

20. Question: For how long did Greg Lapatis do those things to you who
believed in him, that he will give you hefty commissions?

20. Answer: For myself, it was around twenty one (20) months starting
from the month of August 2018 until the month of May 2020. In the
beginning there were numerous property agents who joined Greg Lapatis.
Towards the end there were only a few of us. Those of us from whom
Greg Lapatis collected large amounts of money were Zenaida Aguilar, Leizl
Consolacion, Lina Deslate and me.

21. Question: Do you have any evidence or proof of the amounts of

money collected or extracted from you by Greg Lapatis?

21. Answer: Yes, sir. Greg Lapatis signed and issued a receipt in my
favor dated February 4, 2020 acknowledging that he has received from
 7

me the amount PhP1,600,000.00 and food supplies starting August 2018

to February 4, 2020 valued at PhP450,000.00. Said receipt was signed by
witnesses Benjamin Jaleco and Abner Beraye. The receipt is hereto
attached to this Judicial Affidavit as Annex “1”

22. Question: Aside from being a real estate agent for the lands
proposed to be sold, were there other transactions which Greg Lapatis
offered to you?

22. Answer: yes, sir. Because I have knowledge and experience in the
processing of the sale and titling of real estate, he offered me to be his
assistant in assessing and evaluating the lands being offered for sale. He,
then, invited me to invest in his real estate business operations in terms
of providing him some cash, spend for the food requirements of his office
and the people working for him, finance the operating expenses of his real
estate business, process the creation of his personal corporation and pay
for the fees, permits, licenses and other related expenses related to the
registration of the corporation with the SEC and the BIR. In exchange for
my investment (the money I spent), Greg Lapatis will give me a share
from his commission on the sale of the lands under consideration.

23. Question: How much is the share of Greg Lapatis in any parcel of
land that will be sold?

23. Answer: Greg Lapatis will get or earn fifty (50%) percent of the
commission including the overprice for every property that will be sold.

24. Question: What is your evidence or proof on that kind of

arrangement in the proposed sale of targeted lands through Greg Lapatis?

24. Answer: I have two (2) notarized documents belonging to Zenaida

Aguilar which involved one landowner, however, there was an alleged
defect in the original document such that it was notarized for the second
time. The first document was notarized on October 8, 2019 and the
second document was notarized on December 2, 2019 which documents
were both subscribed before the same notary public. The important thing
is that both notarized documents state the price of the land agreed to by
the landowner, the amount of the projected overprice, the projected
capital gains tax, the 50% share of Greg Lapatis (aka GLL) in the total
commissions to be shared by the pertinent real estate agents. The
documents notarized on October 8, 2019 and December 2, 2019 are
hereto attached and marked as Annexes “2” and “2-A”.

25. Question: Did the “so called” buyer or investor of Greg Lapatis
actually arrived in Iloilo?

25. Answer: Yes, on December 29, 2019.

 8

26. Question: In answer to question number 12 in his Judicial Affidavit,

complainant Mana-ay said that he met Christopher Crutcher on December
29, 2019, what do you said to that?

26. Answer: We, who were all involved in the land acquisition operations
of Greg Lapatis, except Greg Lapatis himself and respondent Clemente
Laguda met Christopher Crutcher for the first time on December 29, 2019
when the latter arrived in Iloilo.

27. Question: In answer to question number 13 in his Judicial Affidavit,

complainant Mana-ay stated that Christopher Crutcher was introduced to
him by Greg Lim Lapatis who according to him is a businessman in Iloilo
City and owner of a brokerage firm known as PYXIS OPC engaged in real
estate development and holding corporation. He claimed that he worked
as real estate/ development program/assistant consultant of PYXIS –OPC
Corporation that Greg Lapatis owned, what do you said to that?

27. Answer: That is a blatant lie or misrepresentation of complainant

Aurelio Mana-ay. On December 29, 2019 PYXIS OPC was not yet
established, created or operating. It was approved by registered with the
SEC only on February 23, 2020. I know it as a fact because I was the one
who processed and financed its creation and establishment for and in
behalf of Greg Lapatis. At the time that Christopher Crutcher arrived in
Iloilo December 29, 2019 there was no such corporate entity as PYXIS
OPC that existed. Thus, complainant Mana-ay that he was working as a
consultant something for PYXIS OPC at the time he met Christopher
Crutcher was clearly false and misleading.

28. Question: Do you have any evidence or proof of such claim?

28. Answer: Yes, sir. I am hereby attaching some documents to this

Judicial Affidavit and marking them, as follows:

Annex “3” – Certificate of Incorporation of PYXIS, OPC

Annex”3-A” – Company Information Form where I was designated
as the contact person for said corporation
Annex “3-B” – Articles of Incorporation consisting of four (4) pages
Annex “3-C” – Business Permit of PYXIS, OPC approved on March
13, 2020
Annex “3-D”- Certificate of Registration with BIR dated April 20,
2020

29. Question: 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
 9

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?

29. Answer: Said statements of complainant Aurelio Mana-ay are blatant

lies and misrepresentations. I, (who was one of those defrauded and
swindled by Greg Lapatis), complainant Mana-ay and their cabal, also
heard the same yarn or tall tale from Greg Lapatis. In fact, Greg Lapatis
showed us pictures of him together with Christopher who he represented
as his investor/funder to convince us to join his land acquisition
operations. On the part of complainant Mana-ay, his 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 for 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 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.

30. Question: 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
 10

NBI evidence. Do you have knowledge of said letter and what can you say
about that?

30. Answer: 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 January 7, 2020. Thus, this
is another 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 August
2018 when I first came into contact with Greg Lapatis. Hence, it is clear
and definite that sixteen 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 said Christopher Crutcher. 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 us 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 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. One more point of the deviousness of Greg Lapatis and
complainant Mana-ay is that they caused the notarization of the letter
without the knowledge and consent of Christopher Crutcher. The other
complainants echoed in toto the allegations of complainant 00Mana-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.

31. Question: In his answer to questions number 17 and 18 of his

Judicial Affidavit complainant Mana-ay alleged that because of the
assurance of Christopher Crutcher that Mr. Lapatis and his group will be
refunded of their expenses as well as earn commissions/incentives from
the transaction, he (Mana-ay) and Lapatis traveled to different parts of
the Visayas Region to look for potential lots for sale. He claimed that he
processed, facilitated and consolidated about 1,700 hectares located in
Panay Island, Guimaras Province and Negros Island. What do you say to
that?
 11

31. Answer: I myself was also hoodwinked by Greg Lapatis by his

promises of hefty commissions which enticed me to part with my hard
earned money and even mortgage my properties. However, in retrospect
it was merely a fantasy without any basis in reality. It was very clear and
definite from the start that Greg Lapatis has no written, legal or valid
authority from Empire Group to negotiate the purchase of properties.
What Greg Lapatis did was to display the enlarged pictures of him and his
purported investor Christopher Crutcher standing side by side when he
was entertaining the real estate brokers, land agents and landowners.
That was his evidence of the veracity of his land acquisition operations.
Greg Lapatis together with complainant Aurelio Mana-ay operated an
elaborate hoax to defraud so many people of their hard earned money.
In fact, I have in my possession a notarized or public document
entitled Real Estate Brokers Agreement dated and subscribed on February
10, 2020 wherein Greg Lapatis as one of the contracting parties being
designated as the First Party declared under oath that: a) He (the First
Party) is a partner/joint venture of Empire Group Ltd. and its
representative tasked with looking for real estate and acquiring
the same in the name of a Filipino corporation to be formed and
designated by Greg Lim Lapatis, b) He (the First Party) shall look
for and or employ at his expense and his accredited people to look
for real properties to be sold to the designated FILIPINO
CORPORATION to be owned by 40% by Empire Group Ltd. and the
Group of Greg Lim Lapatis, 60%. Meanwhile that the Filipino
Corporation is not yet formed, the (sic) sell shall be made in the
name of Greg Lapatis in trust for the Filipino Corporation.
This document proves the fact that Greg Lapatis is very well aware
that at that point in time, February 10, 2020, there is no legal or
corporate entity through which all the properties he has gathered and
earmarked for acquisition from June 2018 to February 2020 could be sold
to. By his admission, the Filipino Corporation which will be the vehicle to
acquire the properties is yet to be formed. The notarized or public
document entitled Real Estate Brokers Agreement dated and subscribed
on February 10, 2020 containing two (2) pages are attached to this
Judicial Affidavit and marked as Annexes “4” and “4-A”.

32. Question: In his answers to questions numbers 19 and 20 in his

Judicial Affidavit complainant Mana-ay with respect to the expenses he
has incurred, Mana-ay claimed that he spent the amount of
PhP1,000,000.00, however, he (Mana-ay) does not have any receipt
covering said expense because he submitted the same for reimbursement
to Christopher Crutcher who has custody of the said receipts. What do you
say to that?

32. Answer: Such claims of complainant Mana-ay are blatant lies. Greg
Lapatis and complainant have been so busy managing the land acquisition
operations of Greg Lapatis as far back as August 2018 when I first came
 12

to know them. Christopher Crutcher arrived in Iloilo only on December 29,

2019. Thus, to my personal knowledge Lapatis and Mana-ay have been
working on their land acquisition scam for around sixteen (16) months
prior to the arrival of Christopher Crutcher. How can Christopher Crutcher
assure complainant Mana-ay that he (Crutcher) will refund Mana-ay’s
expenses and promised Mana-ay commissions/incentives when he
(Crutcher) has not yet arrived in the Philippines at the time.

33. Question: What happened when the foreign investor finally arrived to
the Philippines?

33. Answer: I was disappointed to realize that the foreign investor did
not actually intend to buy land because what he wanted was to enter into
joint ventures and long term lease agreements. There was no purchase of
any vast tracts of lands to speak of. Neither was I refunded of all my
expenses in the operation of Mr. Greg Lapatis and his group’s real estate
business.

34. Question: How did you realize that the foreign investor did not
actually intend to buy land but instead he wanted to enter into joint
ventures and long term lease agreements?

34. Answer: Around January 2020, we personally asked Mr. Christopher

Crutcher, the foreign investor. He told us that he doesn’t want to buy land
but instead, enter into joint ventures and long term lease agreements with
the landowners. Initially, I was prevented by Mr. Greg Lapatis and his
group from talking to Mr. Christopher Crutcher. Greg Lapatis kept
repeating “Don’t talk to Mr. Crutcher! Only pay-pay!”, Lapatis referring to
my non-communication with Mr Crutcher but instead only just to fan him.

35. Question: After you talked to Mr Crutcher, what did you do?

35. Answer: I continued to help the group working on the proposed

project of Mr. Christopher Crutcher.

36. Question: What happened to the relationship between Greg Lapatis

and Christopher Crutcher?

36. Answer: Sometime in the middle of May 2020, Christopher Crutcher

discovered and came to realize that he was being used and exploited by
Greg Lapatis, complainant Aurelio Mana-ay, Jose Reden de Juan 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. Further,
Greg Lapatis appropriated for himself funds which were earmarked for
payment of obligations already incurred. Thus, a bitter quarrel ensued
 13

between Greg Lapatis and Christopher Crutchcer which caused the

termination of their relationship.

37. Question: Do you have knowledge of what events and circumstances

that led to breakdown of the relationship between Christopher Crutcher
and Greg Lapatis?

37. Answer: Yes, sir. The background story was that sometime on the
later part of April 2020, the IT people employed by Pyxis (OPC) owned by
Greg Lapatis informed all of us that the website of Project Galileo bogged
down and needed to be renewed and updated. Greg Lapatis was required
to raise money in the amount of more than PhP300.000 to renew and
update the website. So, Greg Lapatis accompanied by Jose Reden de Juan
went to respondent Lina Deslate on May 4, 2020 asking her help them find
a person who will loan to him (Lapatis) the amount of PhP300,000.00 to
pay for the renewal of the use of the website of Steven Voice who is based
in England. The website is needed to launch the “Social Awareness
Campaign” designed by Christopher Crutcher for Project Galileo. According
to Lapatis, when the Social Awareness Campaign is launched, we can now
start to get billions of pesos and Greg Lapatis can now pay the properties
he has approved for purchase and refund us of our expenses. Since
nobody is willing to lend money to Greg Lapatis because he has no
capacity to pay, Lapatis convinced me to mortgage one of my land titles
as security or collateral for the loan. Thus, respondent Lina Deslate
looked for the money. On May 7, 2020 I and respondent Lina Deslate met
at the house of Greg Lapatis cum office at Barrio Obrero, Lapuz, Iloilo City
where I signed a real estate mortgage of one of my properties in favor of
respondent Lina Deslate which was also signed by Greg Lapatis and Jose
Reden de Juan as witnesses. Then respondent Lina Deslate delivered and
turned over the money to Greg Lapatis. Out of the PhP300.000.00,
PhP94,000.00 was earmarked and utilized to pay for the website account
of complainant Aurelio Mana-ay’s foundation named Golden Heart Helping
Hands Foundation, Philippines, Inc. Subsequent thereto, Greg Lapatis
claimed that the PhP300,000.00 was not enough and he alleged there was
a deficit of PhP39,000.00 for the remittance center. Zenaida Aguilar gave
Greg Lapatis PhP20,000.00 to partially fund the deficit. For the remaining
PhP19,000.00 balance, Lina Deslate contributed PhP3,000.00 and Liezl
Consolacion contributed PhP16,000.00. When Lina Deslate, Liezl
Consolacion and Zenaida Aguilar went back to the house of Greg Lapatis
to recover the PhP20,000.00 earlier delivered to him by Zenaida Aguilar to
complete the PhP39,000.00 deficit for the remittance center, the
PhP20,000.00 was no longer with Greg Lapatis because he has already
spent it. That was the primary cause of the enmity and bitter quarrel
between Greg Lapatis and Christopher Crutcher. According to Christopher
Crutcher, if Greg Lapatis cannot be trusted with a small amount of
PhP20,000.00 how much if he has a bigger amount to embezzle.
Immediately thereafter Christopher Crutcher ended his relationship with
Greg Lapatis.

38. Question: 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?
 14

38. Answer: According to complainant Mana-ay, I was the International

Analyst and Personal Consultant of Mr. Crutcher. Mana-ay claimed that I
facilitated the various land documents endorsed to the group and acted as
negotiator between the group and the land owners selling their properties.
These claims of complainant Mana-ay and his clone co-complainants are
preposterous and laughable. In truth, the opposite is the case. It is
complainant Aurelio Mana-ay who was the brains of the land acquisition
strategies of the Lapatis swindling gang in terms of how to approach the
targeted land owners. In behalf of the Greg Lapatis swindling gang,
complainant Mana-ay likewise monitors and directs 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. 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 purportedly by the Empire Group. 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.

39. Question: Complainants attached as part of their evidence an allege

membership form which they purportedly filled up and claimed that they
paid PhP1,000.00 to Christopher Crutcher, what can you say to that?

39. Answer: Their claims are not true. First, their alleged claim of
payment of P1,000.00 to Christopher Crutcher was not supported by any
receipt or any proof of payment. Second, subscription to the Galileo Rising
e-book was designed to be paid through Paymaya online payment account
and not directly to any person. Third, on its face the alleged membership
forms are defective and flawed, such as: a) there was no date of
execution of the said form, b) there was no picture of the applicant
attached to the form, c) there was no referral code, d) there was no
control number, e) there was no office address of the entity issuing the
membership form and f) no signature of the person who acknowledge the
receipt of the application.

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

40. Answer: I only know complainant Aurelio Mana-ay who is a close

associate and confidante of Greg Lapatis and integral part of swindling
gang. I also know Joemarie Beriber who is also a close confidant of Greg
Lapatis and 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
 15

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

Lapatis. I also know Susan Movera who is the wife of Feliciano Movera, a
bodyguard of Greg Lapatis. I only know complainant Lelita Anas as a
passing acquaintance but I have never met Jonalyn Joy Alagao.

41. Question: All these 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?

41. Answer: That is not true and a very bizarre 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.

42. Question: Do you have anything more to say?

42. Answer: 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.

43. Question: Do you affirm and confirm to the truthfulness of your

affidavit?

43. Answer: Yes, sir.

44. Question: 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?

44. Answer: Yes, sir.

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

day of November 2020 at Iloilo City, Philippines.

MARUJA B. REYES

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.
 16

SWORN ATTESTATION OF THE LAWYER

(Who conducted or supervised the examination of the witness)

I, RENE S. SARABIA, of legal age, Filipino, widower 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 complaining 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.