REPUBLIC OF THE PHILIPPINES

Department of Justice
City Prosecution Office
City of Manila

MICHELLE DEE,
Complainant,
Docket NO. 2862
- versus –
For: Acts of Lasciviousness
RICHARD CRUZ,
Respondent.
X------------------------------X

REPLY-AFFIDAVIT

I, MICHELLE DEE, 24 years old, Flipino, single and a resident

of Blk.3 Purok Dos, Santa Ana Manila, states under oath as follows that:

1. I hereby reiterate and replead all the positions and arguments

contained in my Complaint-Affidavit as may be considered material and
relevant in this Reply-Affidavit;

2. As can be gleaned in the Counter-Affidavit submitted by herein

respondent, he merely concentrated on denying his acts of lasciviousness
toward me on June 30, 2023, and accused me of committing the said
felony;

3. Respondent wanted to convince this Honorable Office, that it

was I who tried to commit acts of lasciviousness against his person
because I like him, and that I am filing this complaint with malicious
intent;

4. I deny this accusation in the Respondent’s Counter-Affidavit, as

I am living with Michael Santos, Filipino, of legal age and a resident of
Blk.3 Purok Dos, Santa Ana Manila, as husband and wife without the
benefit of marriage for two (2) years now. A copy of the Affidavit of
Cohabitation executed by Michael Santos is herein attached as Annex
“A” and is made an integral part of this Reply-Affidavit;

5. My best friend Antonnia Porsild, also executed an Affidavit of

Witness, stated therein that she caught her ex-fiancé, herein Respondent,
masturbating on my bikini pictures, taken at Boracay, sometime on June
25, 2017, and that the same was the reason why she broke-up with him.
As of the time of the commission of the offense, Antonnia and the
Respondent were no longer together. A copy of the Affidavit of Witness
executed by Antonnia Porsild is herein attached as Annex “B” and is
made an integral part of this Reply-Affidavit;
 6. I therefore most respectfully pray that criminal information for
Acts of Lasciviousness be now filed against Richard Cruz as there is
more than probable cause for his indictment;

IN WITNESS THEREOF, I have hereunto affixed my signature

th
this 8 day of August 2023 at City of Manila.

ATTY. Catriona Gray

Office of the City Prosecutor