Republic of the Philippines)

Province of Aklan ) S. S.
Municipality of Kalibo )
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REPLY-AFFIDAVIT

I, TRIXIE S. ANGELES , female, single, of legal age, resident of

Poblacion, Kalibo, Aklan, Philippines, after having been duly sworn
to in accordance with law, now depose and state:

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 dated

October 24, 2018 submitted by repondent Anthony
Taberna, he merely concentrated on denying his
acts of issuing to the undersigned worthless checks
on September 5, 2018. “Denial, like alibi, is
inherently a weak defense and cannot prevail over
the positive and credible testimony of the
prosecution witness that the accused committed the
crime. (People of the Philippines vs. Edwin
Belibet, Manny Banoy and Ronnie Rosero G.R.
No. 91260, July 25, 1991) At the outset, suffice it to
say that respondent’s convenient defense of denial
is a matter best threshed out in a full blown trial;

3. I deny the allegation of the respondent that he was

not informed of the dishonor of the checks. In fact,
the demand letter/notice of dishonor with attached
checks stamped “INSUFFICIENT FUNDS” dated
September 27, 2018 was personally served upon
the respondent on September 28, 2018 as
evidenced by his signature acknowledging the
receipt thereof. The demand letter/notice of
dishonor was attached in the Complaint Affidavit as
Annex “K;”

4. I deny having received any conditional letter of

payment dated September 7, 2018 and attached as
 annex “12” of the Complaint Affidavit. Moreover, the
registry receipt attached as Annex “13” of the
Counter Affidavit does not prove receipt of any
document.

5. I also deny having agreed to comply first on the

delivery of the materials before the respondent may
pay in full there being no evidence of such facts.

6. That I am executing this Reply-Affidavit to attest to

the truthfulness and veracity of the foregoing
contents and for the purpose of lodging a criminal
case of ESTAFA and/or violation of B.P. 22 against
ANTHONY G. TABERNA.

TRIXIE S. ANGELES
(Affiant)
Pag-Ibig ID No. 0005642
Valid until: 03/16/2020

SUBSCRIBED AND SWORN to before me this 25th day of

January 2018, at Kalibo, Aklan, Philippines by affiant who has
satisfactorily proven to me her identity indicated below her name-
affiant is known to me and to be the same person who executed
the foregoing affidavit. I hereby certify that I have personally
examined the affiant and I am satisfied that she has freely
executed the foregoing affidavit and the allegation contained are
fully understood by her.

ATTY. MARIA CHARISE C. LEYSON

Prosecutor I