REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES

FIRST JUDICIAL REGION
BAGUIO CITY, BRANCH NO. ____

HEIRS OF DOMINGO SALAZAR

(REPRESENTED BY CELIA SALAZAR),
Plaintiff,
CIVIL CASE NO. 143
-Versus - FOR DAMAGES

AARON JAMES E. CO,

Defendant,
x---------------------------------x

REPLY

The plaintiff, through the undersigned counsel and unto this Honorable Court,
most respectfully alleges that:

1. The plaintiff denies the truth of the statements alleged in paragraph 2, 3 and 5 of the
answer with regards to the allegation that the vehicle bearing plate number FUB 036
was carnapped. The issuing authority stated in the paragraph 5 of the answer, the police
blotter and the affidavit of ANNA TERIS DE LEON-CO happens to be non-identical.
Thus, the validity and the veracity of the allegation of the vehicle being carnapped
cannot be ruled out to be true, as no valid, authentic and truthful document was given to
support the claim.

2. The plaintiff denies as well the allegations in paragraph 2 and 5 with regard to the
claim that the defendant was attending a seminar and was out of the country. The
duration of the said seminar as alleged in the answer and the affidavit of KRISLYN Y.
MARIO is also different. The duration in the answer was October 18 to October 22 and
the duration in the affidavit was October 18 to October 28 is clearly different and is now
to be subject of question respecting its truth.

3. The plaintiff denies also the claim mentioned in paragraph 4 with regard the affidavit
of GRACE U. RABANAL. It is crystal clear in the complaint that GRACE U.
RABANAL saw the defendant went outside of his vehicle to seemingly check on the
plaintiff but immediately went back to his vehicle upon seeing people already closing in
and drove off in a hurry. Obviously the defendants claim is baseless and is a mere
statement to mislead the court of what is already well established in the complaint.
Furthermore, the Annex mentioned in the same paragraph refers to the death certificate
and not the same affidavit referred to in this paragraph.

4. The plaintiff also questions the date of notarization of the affidavit of KRISLYN Y.
MARIO. The date of the notarization was February 16, 2015 but the date of the
seminar was October 18 2016 to October 28 2016. Clearly, there is an impossibility of
the notarization being prior to the happening of the event and the making of the affidavit.

5. Lastly, the plaintiff questions the truth with regard the departure and return of the
defendant to the country, as no proof to support such a claim was ever provided. Rather
false and baseless documents were presented to prove the presence of the defendant to a
seemingly made up seminar in Miami, Florida.

DEFENSE TO COUNTERCLAIM

1. The plaintiff repeats his Statement of Claim.

2. By reason of the matters pleaded above, the defendant is not entitled to any of the
reliefs that are being claimed for.

I, CELIA SALAZAR, the plaintiff, believes that the facts that are stated in
this Reply and Defense to Counterclaim are true.

City of Baguio, March 19, 2016

ATTY. MAE ANN Y. BADUA

Notary Public
Notarial Commission No.331-2018
Roll No. 071015
PTR No.7313108, 1/3/18
IBP No. 785625, 1/2/18
BADUA-AGUILAR & Associates
Alviar Tower Building
Baguio City, Philippines