COUNTER AFFIDAVIT

I, ROBERT PAUL M. DAGDAGAN , Filipino, of legal age, single and presently

residing at 222 Escolta Street, Binondo, Manila, Philippines, after having been sworn
in accordance with law do hereby depose and say:

1) That I am the same person who is charged with the crime of QUALIFIED
SEDUCTION filed with Regional Trial Court of Manila Branch I docketed
under CRIMINAL CASE NO. 19-12345;

2) That Paragraph 5, 6, 7, 8, 9, and 10 of the Complaint Affidavit of Ella Sheena

Esguerra dated February_, 2018 is untrue. I have not been committed any of the
particular acts she mentioned in the Complaint. The reason why we accept her
as helper in our house is an act of generosity. In fact, as a niece of my wife. We
are giving her financial support and I/we have not request any lawful or
unlawful acts in exchange to this generosity.

3) That Paragraph 11, 12, 13, 14, 15, and 16 of the Complaint Affidavit is untrue.
That following paragraph were just a figment of imagination of the
Complainant and to conceal her unwanted pregnancy done by another person.

4) That the filing of this instant complaint is a product of vendetta due to

discontinuation of giving a financial support with the Complainant.

5) That I am voluntarily executing this affidavit to attest to the truthfulness of the

foregoing facts and to support the outright dismissal of the complaint filed
against me.

IN WITNES WHEREOF, I have hereunto affixed my signature this ___ day of

__________ __________ at ___________________________, Philippines.

ROBERT PAUL M. DAGDAGAN

Affiant