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Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecution Service
Office of the City Prosecutor
Malolos City, Bulacan

ADELAIDA P. CRUZ,
Complainant,

-versus- NPS Docket No. III-07-INV-16L-00442

BENJAMIN DELA CRUZ, ET


AL.,
Respondents.
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REPLY AFFIDAVIT

I, ADELAIDA CRUZ, Filipino, of legal age, and with


residence at 1625 Malanggam Bliss Project, Bulihan, Malolos
City, after having been duly sworn to in accordance with the
law, hereby depose and state that:

1. I am in receipt of the Counter-Affidavit of


Respondent Benjamin Dela Cruz (Respondent Benjamin)
dated 23 January 2017.

2. Respondent Benjamin argues that he had no


participation in the execution of the impugned Deed of
Absolute Sale (Deed) as his signature was not affixed
thereon.

3. Firstly, it must be emphasized that in the same


Counter-Affidavit, Respondent Benjamin declared, under oath,
that as per the record of Radthien Builders, the company
bought the subject from the Paulino Family and not from me
and my husband. He even attached different vouchers in
favor of Julie Ann Paulino, to wit:

3. Per the record of Radthien Builders,


the company bought the property from
the Paulino Family for an agreed price
of P2,054,560.00 through Julie Ann
Paulino in 2012 on installment basis.
4. Now, if it were really true that their records disclose
that the property was bought from Julie Ann Paulino, how
come that they did not ask Julie Ann Paulino, or anyone from
the Paulino Family to produce proof of ownership so they
could buy it straight from them? As a partnership engaged in
real estate development, the company is expected to exercise
extraordinary diligence, such that purchasing properties from
a purported owner thereof who cant adduce evidence of
ownership is not only absurd but also inconsistent with
extraordinary diligence.

5.