JUDICIAL AFFIDAVIT OF

EARL AARON P. REYES

I. Name, Age, Residence or Business Address and Occupation of Witness (sec 3 (a)
AM No. 12-8-8-SC)
MR. EARL AARON P. REYES is of legal age, single, and the Parochial
Administrator of St. Anne Parish Church, Molo, Iloilo City. Authorized
Representative of Bowing Airtech Inc. in the Project: Remodelling of
Bowing AX-010712. Also an employee in the Business and General Aviation
Department, Bowing Global Services

II. Name and Address of the lawyer who conducts or supervises the examination of
the witness and the place where the examination is being held. (Sec. 3 (b) AM No.12-
8-8-SC)
I am giving my statements to ATTY. RAIZA D. DAYOT, with office address
at 6811, 15TH FLOOR, AYALA FGU BUILDING AYALA AVE., MAKATI CITY.
The examination was done at A&D & Associates office, 6811, 15th floor,
Ayala FGU building Ayala Ave., Makati City on January 24, 2019.
III. A statement that the witness is answering the questions asked of him, fully
conscious that he does so under oath and that he may face criminal liability for false
testimony or perjury (Sec. 3 (c) AM No. 12-8-8-SC)
Q- Sir, do you understand that you have to tell the truth, the whole truth
and nothing but the truth, and that if you fail to do so you could be
charged with false testimony or perjury?
A- Yes, Maam.
IV. Questions asked of the witness and his corresponding answers consecutively
numbered that: (1) Show circumstances under which the witness acquired the
facts upon which he testifies (2) elicit from him those facts which are relevant to
the issues that the case presents (3) Identify the attached documentary and object
evidence and establish their authenticity in accordance with the rules of court (4)
Signature of witness over his printed name; and (5) A jurat with the signature of
the notary public who administers the oath or an officer who is authorized by law
to administer oath. (Sec. 3 (d) AM No. 12-8-8-SC).
4.1 Q: Can you please state your name and other personal circumstances.
A: I am Earl Aaron P. Reyes, an employee of Bowing Airtech Inc.,
particularly the secretary in Business and General Aviation Department,
Global Services. Presently, I am also the authorized representative of
Bowing in the Project Business with PhilPa, entitled: Remodelling of
Bowing AX-010712.
4.2 Q: Sir, when did you start working in Bowing Airtech Inc.?

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 A: I started working as an official employee of Bowing Airtech Inc. on July
15, 2016, two months after my major training in the company. Then,
sometime in November 2016, I received my appointment as secretary of
the Business and General Aviation Department, from the Vice President of
said Department, William A. Ampofo II.
4.3 Q: Is this your first time to be authorized as business representative of
Bowing?
A: No, Maam. I had once represented Bowing in its transaction with Thai
Airways International at some time in March 2017.
4.4 Q: As the authorized representative of Bowing in its major transactions,
what do you normally do?
A: I act on behalf of the Company and for that reason, I act as the primary
contact point in such business transaction between the company and its
concerned customer. I am responsible before the higher officers and
authorities of the company as regards any business-related transaction
which is designated within my authority is concerned.
4.5 Q: When you speak of communication, is it limited to personal meetings
and negotiations?
A: No, Maam. For there are instances in which communication with the
clients/customers is via letters or email.
4.6 Q: What email are you using then?
A: I have been authorized to use an email for work purposes,
bgags.sec@bowing.com.
4.7 Q: Is the email to be used exclusively for the business transaction with
Philpa in the Remodelling of Bowing AX-010712?
A: No, Maam. I also use this email for any office-related matters, even
when dealing with my main work as Secretary of the Business and General
Aviation Department of Bowing Airtech Inc.
4.8 Q: When did you start using the email?
A: I have been authorized to use this office/business email when I was
appointed as Secretary of the Business and General Aviation Department.
4.9 Q: Earlier you mentioned that you act as being the main point of
communication between Bowing and PhilPa in the Remodelling of Bowing
AX-010712, can you enlighten us more about this?
A: Yes, since being the representative, the Company is in effect
authorizing me to be responsible for all the communications of Bowing to
PhilPa regarding questions, clarifications, issues, and all other related
concerns with the Remodelling of Bowing AX-010712.
4.10 Q: So you are saying that all other heads of departments, officers and
authorities does not communicate with PhilPa as regards the Remodelling
of Bowing AX-010712?

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 A: Yes, maam. It is for this purpose of designating and authorizing me as
the representative of Bowing, in order to fast track business transactions
entered into by Bowing Airtech Inc.
4.11 Q: In case of your unavailability, are there any other person in charge of
communicating with PhilPa as regards this business transaction?
A: Yes, only my private assistant, Ms. Desiree Jane Tubaon. But only with
regard to communications via email. My private assistant is not allowed to
attend personal meetings and negotiations on behalf of the company.
But, she had not yet tried to initiate any communication with them since I
am available at all times insofar as the conduct of negotiations with this
particular project is concerned.
4.12 Q: You have also mentioned that you have communicated with PhilPa thru
letters?
A: Yes, in fact, it was on April 4, 2018, the first time when we
communicated with PhilPa thru a letter of notification that Bowing will
embed an additional feature into the agreed three axis auto-pilot which is
technically called as the Advanced Relay Feature
(Counsel: the notification letter is attached as Annex B-1)
4.13 Q: Can you tell us more about your communications with PhilPa?
A: There was a letter of notification, dated April 2, 2018, sent to PhilPa as
regards the additional Ultraviolet LED light to be installed. Also, PhilPa has
communicated through me, on July 2, 2018, in line with their clarification
on the installed ‘advanced relay feature’. Immediately after, I replied on
July 3, 2018, stating Bowing’s assurances as regards to the safety of the
installed feature. The next letter was on September 4, 2018, informing
PhilPa of the delivery of Bowing AX-010712. And the last letter, concerning
my involvement in the communications with PhilPa was on Dec. 26, 2018,
issued to inform Philippine Pacific Airlines that Bowing Airtech will not
answer for any damages and/or losses incurred by the airline company.
4.14 Q: So your email account bgags.sec@bowing.com, has never been used
in communicating with PhilPa?
A: Yes, my bgags.sec@bowing.com office email has never been used to
communicate with PhilPa as per communications regarding the
Remodelling of Bowing AX-010712. As a matter of fact, said email was only
used in office related matters in the Business and General Aviation
Department throughout the year of 2018.
4.15 Q: Is there a prescribed form of communication between Bowing or Philpa
as pre agreed in your contract of agreement?
A: No, Maam. The discretion depends on me, the authorized
representative. However, I prefer the use of letters as instead of
communications thru office email to have at least a proper verification in
sending and receiving communication from customers/clients of Bowing

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4.16 Q: Going back to the communications you have mentioned above, so you
have not engaged in any communication with PhilPa in August, 2018?
A: There is a delivery of a progress report in that month, but as regards to
my contact with them, there was none.
4.17 Q: Only a progress report which communication was not facilitated by
you?
A: Yes, maam. Since that is beyond my task as the authorized
representative. Said delivery of progress reports are entrusted to the
engineering department.
4.18 Q: Now, as regards to the email account, aaronreyes@bowing.com, what
can you say about this?
A: I have no knowledge about the email account maam. Granting that it is
an existing email, it stands contrary to the standard of emails given to
officials in the Company. Names are not to be used as usernames for email
accounts in the company. It must be abbreviated with your current
position and in which department of Bowing you are assigned with. Thus,
bgags.sec@bowing.com, stands for, “Business and General Aviation,
Global Services, Secretary.”
4.19 Q: Do you have any proof of this?
A: Yes, Maam. I have brought here two printed screen captures of my
email transactions using the said email account stated above.
4.20 Q: You also mentioned that you were appointed as secretary of the
Business and General Aviation Department, by the Vice President of said
Department, William A. Ampofo II. Are there instances in which Sir William
A. Ampofo or other department heads will use your
bgags.sec@bowing.com for communicating business-related
transactions with clients/customers of bowing?
A: No, Maam. The email is exclusively and solely for my own use in dealing
with office-related matters.
4.21 Q: How about the letter prepared by the alleged “Li Anne Care Roth”?
What are your thoughts on this issue?
A: In my 3 years of working in the Company, I have never encountered nor
heard of that name. As even gleaned from the organizational chart of
officers of Bowing Airtech Inc., her name seems to be missing.
4.22 Q: Is that all you would like to say, Sir?
A: For the time being, Yes, Ma’am.

EARL AARON P. REYES

Affiant

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 SUBSCRIBED AND SWORN BEFORE ME, on __December 2018, at Iloilo City,
Philippines. Affiant is known to me and was identified by me through his
competent evidence of identity _____________________________________. I
further certify that I have fully examined the affiant and I am convinced that he
understood, read, and voluntarily executed his affidavit.

City Prosecutor

Doc. No.______
Page No.______
Book No. ______
Series of 2018.

ATTESTATION OF COUNSEL
I hereby certify that I have recorded or caused to be recorded the
questions I asked of the witness and his corresponding answers thereto, and I
further certify that I neither coached nor suggested any of the answers to him
and that no other person coached or suggested to him said answers.

ATTY. JOSEFA MARIA A. CASTRO

SUBSCRIBED AND SWORN BEFORE ME, on __December 2018, at Iloilo City,

Philippines. Affiant is known to me and was identified by me through his
competent evidence of identity _____________________________________. I
further certify that I have fully examined the affiant and I am convinced that he
understood, read, and voluntarily executed his affidavit.

City Prosecutor

Doc. No.______
Page No.______
Book No. ______
Series of 2018.