Republic of the Philippines)

City of Iloilo )S.S.

X----------------x

ADDITIONAL COUNTER-AFFIDAVIT
I, GERARDO R. DE LUZURIAGA, of legal age, Filipino, and with
business address at c/o LA BOTICA, INC., E. Lopez Street, Jaro, Iloilo
City, after having been sworn to in accordance with law, hereby
depose and state;

1. That on 3 February 2003 I had subscribed and sworn to my

Counter-Affidavit and/or Complaint-Affidavit in I.S. No. 087-03, under
Subpoena no. 11-03, re: Rosa de los Santos, et. al., vs. Gerardo R.
de Luzuriaga, before City Prosecutor Enrique Z. Trespeces and
thereafter filed the same;

2. That in the said Counter-Affidavit I affirmed, among other

things, that “…my infusion of capital into the joint venture was used
to pay off the loans of complainants or their family with Mr. Henry
Chusuey. Truth to tell, complainants’ contributions to the corporation
was saddled with debt which was serviced by cash infusion I made.”

3. That to prove the preceding assertion, I was able to retrieve

some of the checks I paid to Mr. Henry Chusuey for the
aforementioned loans of complainants amounting to P/7,077,183.45
(Pesos) Philippine Currency, with the following particulars, to wit:

Bank Check Date Amount Attached

No. As
China 449465 Feb. 23, P/16,500.00 Annex “1”
Bank 1989
China 449486 Mar. 8, P/63,000.00 Annex “2”
Bank 1989
China 504001 Mar. 22, P/16,500.00 Annex “3”
Bank 1989
China 504029 Apr. 8, P/63,000.00 Annex “4”
Bank 1989
China 510657 Apr. 21, P/16,500.00 Annex “5”
Bank 1989
China 510687 May 9, P/63,000.00 Annex “6”
Bank 1989
China 510699 May 23, P/16,500.00 Annex “7”
Bank 1989
China 513438 June 9, P/63,000.00 Annex “8”
Bank 1989
 2

China 7211 June 23, P/16,500.00 Annex “9”

Bank 1989
China 7253 July 7, P/63,000.00 Annex “10”
Bank 1989
China 7274 July 24, P/16,500.00 Annex “11”
Bank 1989
China 44571 Sept. 1, P/31,000.00 Annex “12”
Bank 1989
China 44583 Sept. 6, P/32,500.00 Annex “13”
Bank 1989
China 44592 Sept. 9, P/72,000.00 Annex “14”
Bank 1989
China 52608 Sept. 23, P/16,500.00 Annex “15”
Bank 1989
China 52678 Nov. 2, P/37,333.45 Annex “16”
Bank 1989
China 52696 Nov. 6, P/35,000.00 Annex “17”
Bank 1989
China 63705 Nov. 9, P/81,000.00 Annex “18”
Bank 1989
China 63732 Nov. 23, P/550,000.00 Annex “19”
Bank 1989
China 63777 Dec. 4, P/14,000.00 Annex “20”
Bank 1989
China 63778 Dec. 4, P/600,000.00 Annex “21”
Bank 1989
China 63785 Dec. 6, P/24,500.00 Annex “22”
Bank 1989
China 63786 Dec. 6, P/300,000.00 Annex “23”
Bank 1989
China 63788 Dec. 7, P/25,600.00 Annex “24”
Bank 1989
China 63795 Dec. 11, P/81,000.00 Annex “25”
Bank 1989
China 63779 Jan. 3, P/400,000.00 Annex “26”
Bank 1990
China 63787 Jan. 5, P/700,000.00 Annex “27”
Bank 1990
China 69850 Jan. 8, P/24,000.00 Annex “28”
Bank 1990
China 63790 Jan. 8, P/800,000.00 Annex “29”
Bank 1990
China 69861 Jan. 9, P/68,750.00 Annex “30”
Bank 1990
China 69862 Jan. 9, P/200,000.00 Annex “31”
Bank 1990
 3

China 69863 Feb. 8, P/2,500,000.00 Annex “32”

bank 1990
Total P/7,077,183.4
5

4. That I am executing this sworn statement in order to attest

to the truth of the foregoing facts.

IN WITNESS WHEROF, I hereunto set my hand this _____

day of March 2003 in Iloilo City, Philippines.

GERARDO R. DE LUZURIAGA
Affiant

SUBSCRIBED AND SWORN to before me this ____ day of

March 2003 at Iloilo City, Philippines, and that I hereby certify that I
have personally examined the affiant and I am fully satisfied that he
voluntarily executed and understood the contents of his affidavit.

___________________