Judicial-affidavit.docx

REPUBLIC OF THE PHILIPPINES METROPOLITAN TRIAL COURT ________ Judicial Region Tuguegarao City Branch ___ BANK OF NOWHERE Plaintiff, -versus-

CIVIL CASE NO. 0000321 FOR: COLLECTION OF SUM OF MONEY

JOHN REYES Customer No. 000222277778888 Defendant X-------------------------------X

JUDICIAL AFFIDAVIT (of Plaintiff’s witness JUAN DELA CRUZ in lieu of Direct Testimony) PRELIMINARY STATEMENT The person examining me is ATTY. JOSE SANTOS of SANTOS & ASSOCIATES law office with address #715 Maharlika Highway, Carig Sur, Tuguegarao City. My Judicial Affidavit is being taken at the above mentioned place in the presence of LAURA PINEDA, a legal secretary at said law office, and STEVEN GAMBOA, my friend and companion. The questions are asked in the English language which I speak and fully understand. And I am giving my answers fully conscious that I do so under oath and I am aware that I may face criminal liability for false testimony or perjury for false statements made or given by me. OFFER OF TESTIMONY Plaintiff, BANK OF NOWHERE, is presenting the testimony of JUAN DELA CRUZ, to prove that defendant JOHN REYES personally received the demand letter sent by SANTOS & ASSOCIATES on behalf of plaintiff bank sometime last 30 July 2018.

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JUDICIAL AFFIDAVIT PROPER Q1:

Mr. Witness, will you please state to the Honorable Court your name, age, and other personal circumstances?

A:

I am Juan Dela Cruz, 25 years old, single, and living at #4 Apple St. Airport Subdivision, Pengue Ruyu, Tuguegarao City. I work at SANTOS & ASSOCIATES law office as a Liaison Staff.

Q2:

You mentioned that you are a Liaison staff at SANTOS & ASSOCIATES; as such, what your duties and responsibilities?

A:

I am assigned to coordinate with various private companies as well as, government agencies and undertake the delivery of demand letters of our clients, Bank of Nowhere being one of them. In addition, I also monitor the results of the delivery of said letters to our clients’ customers, such as delinquent credit cardholders, and our office maintains records of it.

Q3:

In the course of your monitoring letters delivered to delinquent cardholders and maintaining records of it, do you recall the name of John Reyes in your records?

A:

Yes, Sir.

Q4:

What information do you have in your records regarding said John Reyes?

A:

According to our records, by personal service I served a demand letter to John Reyes sometime last 30 July 2018. I have the Field Visit Checklist which was filled up at the end of the day and I request that it be marked as Exhibit “G”.

Q5:

I am showing to you a demand letter dated 25 July 2018 addressed to John Reyes of Washington St., Tuguegarao City, marked as Exh. “F-2”. Are you familiar with this letter?

A:

Yes Sir, that’s the receiving copy of the letter which was delivered to John Reyes.

Q6:

In the receiving copy, a name J Reyes and signature are indicated. Do you know whose name and signature this belongs to?

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A:

Yes Sir, it is John Reyes’.

Q7:

How did you know that he is John Reyes?

A:

When he received the said letter, he signed it in front of me.

Nothing Follows. Tuguegarao City, 4 March 2019

IN WITNESS WHEREOF, I have hereunto set my hand this 4th day of March 2019 at Tuguegarao City. JUAN DELA CRUZ Affiant EXHIBITS ATTACHED Exh. “A” to Exh. “AAA”, supra. ATTESTATION The undersigned ATTY. JOSE SANTOS, of legal age and married, under oath, deposes and states: 1.

He is the Legal Counsel for the plaintiff in the above-entitled case;

2. He faithfully recorded or caused to be recorded the questions he asked and the corresponding answers that the above-named witness gave; 3. Neither he nor any other person then present or assisting him coached the witness regarding the latter's answers; and 4. He conducted the examination of the witness at his law office located at #715 Maharlika Highway, Carig Sur, Tuguegarao City. Tuguegarao City, 4 March 2019

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IN WITNESS WHEREOF, I have hereunto set my hand this 4th day of March 2019 at Tuguegarao City. ATTY. JOSE SANTOS Roll No. 12345-6789 IBP No. 123456-1/3/2019 PTR No. 123456-1/3/2019; Tuguegarao MCLE Compliance III No. 001234 issued 4/4/2018 SUBCRIBED AND SWORN to before me this 4th day of March 2019, at Tuguegarao City, affiants exhibiting to me their respective competent evidences of identity: JUAN DELA CRUZ, his SSS No. 1234567 and JOSE SANTOS, his Driver’s License No. 45678900, thus satisfactorily having proven their identities to me. Administering Officer/Notary Public ATTY. ROS SANDOVAL Roll No. 12345-2006 IBP No. 123456-1/3/2019 TR No. 42222222-1/3/2019; Tuguegarao MCLE Compliance III No. 00678900 issued 8/22/2018 DOC NO: _____ PAGE NO: _____ BOOK NO: _____ SERIES OF 2019 Copy Furnished: ATTY. XAVIER DIMASALANG Counsel for Defendant JOHN REYES X LAW OFFICES 3rd Floor Laserna Building Washington St., Tuguegarao City Tuguegarao City Reg. Rec. No. Date

PO

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