Republic of the Philippines

Department of Justice
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
Trece Martires City

MA. VICTORIA SASI PELOQUERO, NPS DOCKET NO.

Complainant, IV-23-INV-20B-00035
FOR: ESTAFA
---VERSUS---

JIM PATRICK GOYONOCHEA,

Respondent.
x…………………………………………..x

COUNTER-AFFIDAVIT

I, JIM PATRICK GOYONOCHEA, of legal age, Filipino and residing at

BLOCK 2, LOT 12 Bonafice St., Windward Subdivision, Dasmarinas City,
Cavite, under oath hereby deposes and states that:

1. I am the Respondent in the above-captioned case and on the Complaint

by one MA. VICTORIA SASI PALOQUERO of ESTAFA.

2. I vehemently deny the charges and allegations of the Complaint, as the

Complaint for ESTAFA has no basis in fact and in law and the truth of
the matter being as set forth and stated herein below.

3. I came to know Complainant through social media. This came about

when Complainant messaged me through Facebook Messenger at around
9:00 AM on 17 July 2019 which she, the Complainant followed through
with a voice call. ANNEX A hereof is the scanned copy of the screen
shot of the messages sent by Complainant to me.

4. Complainant is asking me how she could join the business I entered into
and she wants to earn income. I replied to her queries and explained to
her the business of the company to which I invested and how things
work with said company.

5. Thereafter, Complainant asked for my Bank Account Details through

which she will course the money intended to be put to the business of the
company which she wished to join and invest.

6. Subsequently and from this point, Complainant started putting money to

my bank account with the instruction that I will put her money to the

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 business and companies which she wishes that the money will be placed
for her to earn income from these businesses.

7. She too told me that she had already joined many businesses advertised
and promoted in Facebook and she and her friends have losses in the
businesses they have ventured into.

8. Due to my sincere desire to help Complainant, I proposed to her personal

income-generating means aside from the business or trade that she
invested with the company she entered into.

9. Complainant then introduced her sister to me, VANNESSA JEAN SASI

also known as VJS SASI. At this juncture, Complainant asked me if I
could meet personally here sister, VJS SASI, for which reason I
messaged VJS SASI through facebook for us two to meet.

10. Consequently we met at Starbucks SM Trece Martires and we have

agreed that VJS SASI would hand me the amount of FIVE HUNDRED
THOUSAND PESOS, PHILIPPINE CURRENCY which amount I
would personally managed as FUND MANAGER and to trade it at
FOREX.

11. Pursuant to this agreement, we have executed a written contract a copy

of which is hereto attached as ANNEX B of this Counter-Affidavit.

12. On 07 September 2019, I deposited the amount of EIGHTY

THOUSAND PESOS to the BDO account of Complainant’s sister VJS
SASI representing earnings of the FIVE HUNDRED THOUSAND
PESOS they gave me earlier and for me to manage and invest at
FOREX. Appended herewith as ANNEX C is a copy of the deposit slip
showing that I deposited the amount to the account of VJS SASI,
particularly BDO Account No. 0063804400825.

13. Our personal transactions are all well in order and they have no
grievances.

14. This is separate and apart from the transactions they have entered into
with the business/company they entered into or joined with. All amounts
coursed through my account were all accounted for as having put to all
the business ventures or companies which they joined with.

15. Things however took a downturn when the business ventures or

companies they invested with started suffering losses and Complainant,
her sister and even their friends started blaming me, harassing me and
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 intimidating me on the representation made by Complainant that it was
me who is running or managing their money .

16. This is pure canard. The truth is that all their money went to the
bussinesses which they have knowingly, freely and voluntarily joined
and I have not forced them to make their business judgments and
decisions. It was complainant’s decision to choose which business they
will invest their money and such purely personal decision has nothing to
do with me.

17. Later, Complainant and her sister instructed me to return the amount of
FIVE HUNDRED THOUSAND PESOS to a person they referred and
named as BLISS SAMEON. Since things have turned sour and for my
peace of mind I agreed and returned the amount through BLISS
SAMEON.

18. As a proof of this, attached herewith is a copy of the BDO online

transaction which is hereto marked as ANNEX D hereof.

19. After everything is said and done, the issue is whether I am going to
accede to their outrageous demand to pay them the amount of THREE
MILLION PESOS which they are now claiming is an amount intended
to pay several individuals.

20. As of press time I am continually bullied and pilloried through social

media and continually received threats because Complainant is insisting
on monetary obligations I am never, under the law, is accountable or
liable for.

21. AFFIANT FURTHER SAYET NAUGHT.

I am executing this Counter-Affidavit to attest to the truth and veracity of the

foregoing statements, in support of the DISMISSAL of the baseless Complaint for
Estafa and for whatever legal ends this COUNTER-AFFIDAVIT may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 11 th day of

March 2020 at Trece Martires City, Cavite, Philippines.

_____________________________________
JIM PATRICK GOYONOCHEA
Respondent-Affiant

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 SUBSCRIBED AND SWORN TO before me this 11th day of March 2020
at Trece Martires City, Cavite, Philippines. This is to further certify that I have
personally examined the Affiant and I am fully satisfied that he executed the
foregoing Counter-Affidavit knowingly, freely and voluntarily.