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REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION


MUNICIPAL TRIAL COURT IN CITIES
BRANCH 2
Hall of Justice, Pallocan West
Batangas City

MLM FINANCE CORPORATION


Plaintiff, CIVIL CASE NOS. 4580- 4582

- versus - For:

REPLEVIN WITH DAMAGES


ELENOR F. ANONUEVO and
JOHN DOE/S,
Defendants.

x------------------------------------------------------------x

JUDICIAL AFFIDAVIT OF
MANILYN M. RAMIREZ

The examination of the witness in this Judicial Affidavit was conducted or


supervised by ATTY. JOSELITO M. DIMAYACYAC at his office at Rm. 3,
Golden Luck Building, Apacible Street, Batangas City. The witness answered the
questions asked of her fully conscious that she did so under oath and that she may
face criminal liability for false testimony or perjury.

OFFER OF THE TESTIMONY:

The testimony of MANILYN M. RAMIREZ is being offered to prove that


defendant ELENOR F. ANONUEVO obtained a loan from MLM Finance
Corporation in the amount of Seven Hundred Fifty Thousand Pesos
(P750,000.00), Philippine Currency on May 26, 2015 as shown by the Chattel
Mortgage with Promissory Note. That the said loan with Chattel Mortgage will
mature on August 24, 2015 or three (3) months after the amount was taken by the
mortgagor from the mortgagee. That the said loan was secured by Toyota SUV
Fortuner 4x4 bearing plate number EPA09 and that the said Chattel Mortgage with
Promissory Note was registered with the Office of the Registry of Deeds for the
City of Batangas as shown by the stamp marking made by the Registry of Deeds
appearing on the second page of the said document.

That despite the lapse of the period to pay the said loan, the mortgagor failed to
pay the same, hence, a complaint was filed against the mortgagor as evidenced by
Complaint in Civil Case No. 4580 for Replevin with Damages. That the
mortgaged property was taken by the mortgagee after the filing and approval of
the replevin bond wherein a writ of replevin was issued by the Honorable Court.
That this witness will identify the documents and also the signatures appearing on
the said document and will testify on other matters related thereto.

That aside from the May 26, 2015 loan, the mortgagor obtained a loan from the
mortgagee on October 9, 2015 in the amount of One Million Two Hundred Fifty
Thousand Pesos (1,250,000.00) as shown by the Chattel Mortgage with
Promissory Note dated November 17, 2015. That to secure the payment of said
loan, the mortgagor mortgaged a Toyota Camry Sedan Car bearing plate number
EFA08. That the said loan will mature on January 7, 2016 or three (3) months
after the proceeds has been received by the mortgagor. That the said Chattel
Mortgage with Promissory Note was registered with the Registry of Deeds for the
City of Batangas as evidenced by the stamp marking made by the said office
appearing on the second page of the document dated November 17, 2015.

That despite the lapse or the maturity date, the mortgagor failed to pay her
obligation with the mortgagee which resulted to the filing of the Complaint against
the mortgagor by the mortgagee and this is shown by the Complaint docketed as
Civil Case No. 4582.

That after the submission and approval of the bond, a writ of replevin has been
issued by the Honorable Court, however, the mortgagor and/or defendant hid the
said Toyota Camry Sedan Car and up to now, the said loan has not been paid by
the mortgagor. That this witness will identify the documents and also the
signatures appearing on the said document and will testify on other matters related
thereto.

That on October 12, 2015, the mortgagor obtained a loan from the mortgagee
in the amount of One Million Five Hundred Thousand Pesos (1,500,000.00) as
shown by the Chattel Mortgage with Promissory Note dated December 8, 2015.
That to secure the payment of said loan, the mortgagor mortgaged a Ford
Expedition E L Wagon bearing plate number EFA888. That the said loan will
mature on January 11, 2016 or three (3) months after the proceeds has been
received by the mortgagor. That the said Chattel Mortgage with Promissory Note
was registered with the Registry of Deeds for the City of Batangas as evidenced by
the stamp marking made by the said office appearing on the second page of the
document dated December 10, 2015.

That despite the lapse of the maturity date, the mortgagor failed to pay her
obligation with the mortgagee which resulted to the filing of the Complaint against
the mortgagor by the mortgagee and this is shown by the Complaint docketed as
Civil Case No. 4581.

That after the submission and approval of the bond, a writ of replevin has been
issued by the Honorable Court, however, the mortgagor and/or defendant hid the
said Ford Expedition E L Wagon and up to now, the said loan has not been paid by
the mortgagor. That this witness will identify the documents and also the
signatures appearing on the said document and will testify on other matters related
thereto.

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I, MANILYN M. RAMIREZ, of legal age, Filipino, married and with
business address at MLM Building, Villa Celia Subdivision, Kumintang Ilaya,
Batangas City, under oath, depose and say:

1. Q: Madam Witness, do you know this MLM Finance Corporation with


business address at MLM Building, Villa Celia Subdivision, Kumintang
Ilaya, Batangas City?
A.: Yes, Sir.

2. Q. Why do you know this MLM Finance Corporation?


A.: MLM Finance Corporation is my employer Sir.

3. Q. Can you tell us what position are you occupying in the said
corporation?
A.: Operation Manager, Sir.

4. Q. As Operation Manager of MLM Finance Corporation, can you tell us


your duties?
A.: Yes Sir and one of my duties is to manage the corporation.

5. Q. What else are your duties as Operation Manager of the said


corporation?

A.: I signed documents like Chattel Mortgage with Promissory Note,


Real Estate Mortgage, Promissory Note and Verification and
Certification of Complaints which the corporation filed against
borrowers who failed and refused to pay their obligation.

6. Q. Do you know defendant ELENOR F. ANONUEVO, the defendant in


Civil Case No. 4580 for replevin with damages?
A.: .Yes sir.

7. Q. Why do you know her?

A.: Because she borrowed from MLM Finance Corporation in the


amount of Seven Hundred Fifty Thousand Pesos (P750,000.00) on May
26, 2015.

8. Q. And what is your proof that defendant ELENOR F. ANONUEVO


borrowed the amount of P750,000.00 from MLM Finance Corporation?
A.: The Chattel Mortgage with Promissory Note, Sir.

MANIFESTATION: Witness producing the documents with heading


Chattel Mortgage with Promissory Note dated May 26, 2015 which
we pray your Honor that the same be marked as our Exhibit “A”.

9. Q. Do you know if this loan is secured?


A.: Yes sir.

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10. Q. And what is the security for the payment of this loan?
A: TOYOTA SUV Fortuner 4x4 bearing plate number EFA 09.

11. Q: Do you know if defendant Elenor F. Anonuevo is the absolute and


registered owner of the said vehicle?
A.: Yes Sir.

12. Q. And what is your proof that the said TOYOTA SUV Fortuner 4x4 is
owned by the defendant?
A.: The Certificate of Registration Sir and the Official Receipt issued by
the Land Transportation Office.

13. Q. Do you have the copy of the said two (2) documents?
A.: Yes Sir.

MANIFESTATION: Witness producing the Certificate of


Registration and the Official Receipt of the Toyota SUV Fortuner
which we pray your honor to be marked as our Exhibit “B” and “B-1”.

14. Q: By the way, are you authorized to represent the MLM Finance
Corporation in this case?
A.: Yes Sir.

15. Q: And what is your proof showing your authority?


A.: The Secretary’s Certificate Sir.

MANIFESTATION: Witness submitting the copy of the Secretary’s


Certificate dated 27 January 2016 signed by Sheryl Macalalad,
Corporate Secretary and notarized by Atty. Joselito M. Dimayacyac
of Batangas City which we pray your honor that the said Secretary’s
Certificate be marked as our Exhibit “C”.

16. Q: You made mention of Chattel Mortgage with Promissory Note dated
May 26, 2015 marked as Exhibit “A”, there are signatures appearing on
the said document, please look at this document and tell us the
signatures appearing therein.
A: Regarding the signature appearing on the face of the Chattel
Mortgage with Promissory Note above the name MACARIO L.
MACALALAD, that is the signature of our President and General
Manager. Regarding the signature appearing above the name ELENOR
FRIALDE ANONUEVO, Mortgagor, that is the signature of defendant
named ELENOR FRIALDE ANONUEVO.

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17. Q. How about the signature appearing above the name CARLITO
ANONUEVO, do you know this signature?
A. Yes Sir. That is the signature of CARLITO ANONUEVO, the
brother of ELENOR F. ANONUEVO.

18. Q. How about the signature above the name MANILYN M. RAMIREZ,
whose signature is that?
A.: That is my signature, Sir.

19. Q.: Why do you know that the signatures appearing above the name
MACARIO MACALALAD, the signature above the name ELENOR
FRIALDE ANONUEVO and the signature above the name CARLITO
ANONUEVO are the signatures of the persons I have mentioned?
A. I was present when they affixed their respective signatures Sir.

MANIFESTATION: We pray your Honor that the signature of


MACARIO L. MACALALAD identified by this witness be marked as our
Exhibit “A-1”, the signature of ELENOR F. ANONUEVO identified by
this witness as Exhibit “A-2” and the signature of CARLITO F.
ANONUEVO as Exhibit “A-3”. The signature appearing on the second
page of Exhibit “A” particularly the signature above the name
ELENOR F. ANONUEVO, we pray that the same be bracketed and
marked as our Exhibit “A-4”.

20. Q.: You said that the document “Exhibit A” is registered with the Registry
of Deeds for the City of Batangas, what is your proof to that?
A.: The stamp marking made by the said office on the second page of
Exhibit “A”.
MANIFESTATION: We pray you Honor that the stamp marking
made by the Registry of Deeds for the City of Batangas be bracketed and be
marked as our Exhibit “A-5”.

21. Q.: Regarding this loan, can you tell us the maturity date of this loan?
A.: Yes Sir. The said loan will mature on August 24, 2015.

22. Q.: Can you tell us if the mortgagor was able to pay this loan?
A. No Sir.

23. Q.: So what did your office do when the mortgagor failed and refused to
pay her obligation, the amount of which is Seven Hundred Fifty
Thousand Pesos (P750,000.00).
A.: Our lawyer sent a demand letter to defendant ELENOR F.
ANONUEVO.

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24. Q.: And what happened when your lawyer sent a demand letter to
defendant?
A.: The defendant ignored the said Demand Letter.

MANIFESTATION: We pray your Honor that the Demand Letter dated


January 22, 2016 addressed to ELENOR F. ANONUEVO be marked as our
Exhibit “D”.

25. Q.: After the sending of the Demand Letter and after the same has been
ignored by the defendant Elenor F. Anonuevo, what happen next if any?
A.: We filed a Complaint against defendant Elenor F. Anonuevo.

26.Q.: I noticed that in your Complaint, the amount you are claiming
against defendant is One Million Five Hundred Ninety Nine Thousand
One Sixty Two Pesos and Six Centavos (P1,599,162.06), my question is
how did you arrive in this figure?
A.: The Statement of Account prepared by our office is the evidence
proving that the amount of the obligation of the defendant is One
Million Five Hundred Ninety Nine Thousand One Sixty Two Pesos and
Six Centavos (P1,599,162.06).

MANIFESTATION: Witness producing the Statement of Account


which we pray Your Honor that the same be marked as Exhibit “E” and
the amount of One Million Five Hundred Ninety Nine Thousand
One Sixty Two Pesos and Six Centavos (P1,599,162.06) be encircled
and be marked as our Exhibit “E-1”.

26.Q.: Now, Madam Witness, we go back to your Complaint, can you


tell us if a writ of replevin was issued by this Honorable Court in
connection with your Complaint?
A.: Yes Sir. A writ of replevin was issued by the Honorable Court after
the approval of our bond.

26. Q.: And what happen to that writ of replevin which the Honorable Court
issued in favor of the plaintiff?
A.: The Toyota SUV Fortuner 4x4 bearing plate number EFA09 was
seized by the Sheriff of this Honorable Court and since no one is paying
the obligation in favor of MLM Finance Corporation, the Toyota SUV
Fortuner 4x4 was given to MLM Finance Corporation.

27. Q: Since your company is already in possession of the Toyota SUV


Fortuner, what is your purpose now in continuing and/or proceeding
with this case?
A: We pray that the Honorable Court issued an Order allowing us to
register the Toyota SUV Fortuner in the name of the corporation with the
Land Transportation Office.

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28. Q: Regarding the second loan Madam Witness, which according to you
was taken on October 9, 2015 by the defendant Elenor F. Anonuevo,
what is your proof that the defendant Elenor F. Anonuevo obtained a
loan from your company on said date?
A: The Chattel Mortgage with Promissory Note, Sir.

MANIFESTATION: Witness producing the copy of the Chattel


Mortgage with Promissory Note dated November 17, 2015 which
we pray your Honor that the same be marked as our Exhibit “F”

29. Q: Can you tell us Madam Witness, how much is the loan obtained from
your company on October 9, 2015 by the defendant?
A: One Million Two Hundred Fifty Thousand Pesos, (P1,250,000.00)
Sir.

30. Q: Can you tell us if this loan is secured:


Yes Sir. The same is secured by Toyota Camry Sedan Car bearing plate
Number EPA 08.

31. Q: What is your proof that the Toyota Camry Sedan Car bearing plate
Number EPA 08 belongs to the defendant Elenor F. ANonuevo?
A: The Certificate of Registration and the Official Receipt.

MANIFESTATION: Witness producing the copy of the Certificate of


Registration and the Official Receipt of Toyota Camry Sedan
which we pray your honor that the same be marked as Exhibit “G” and
“G-1”.

32. . Q: Now, we go back to the Chattel Mortgage with Promissory Note,


there are signatures appearing on the said document, please look at said
document and tell us whose signature is that appearing above the name
MANILYN M. RAMIREZ, Manager.?
A: That is my signature Sir.

33. Q: How about the signature appearing above the name ELENOR F.
ANONUEVO?
A: That is the signature of ELENOR F. ANONUEVO Sir.

34. Q; Why did you say that it is the signature of ELENOR F.


ANONUEVO?
A: I was present when she signed it.

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35. Q: There is also a signature appearing on the second page of Exhibit “F”
and the signature is above the name ELENOR F. ANONUEVO, whose
signature is that?
A: That is the signature of defendant ELENOR F. ANONUEVO.

36. Q: Why did you say that it is the signature of ELENOR F.


ANONUEVO?
A; I was present when she affixed her signature thereat.

37. Q: Can you tell us if this Exhibit “F’ is registered with the Office of the
Registry of Deeds for the City of Batangas?
A: Yes Sir.

38. Q: What is your proof?


A: The stamp marking made by the said office appearing on the second
page of Exhibit “F”.

MANIFESTATION: We pray your honor that the signature


appearing above the name MANILYN M. RAMILEZ be bracketed
and be marked as Exhibit “F-1”, the signature appearing above the
name Elenor F. Anonuevo be bracketed and be marked as Exhibit
“F-2”, the signature appearing on the second page of Exhibit “F”,
which signature appears above the name Elenor F. Anonuevo be
marked as our Exhibit F-3 and the stamp marking made by the
Office of the Registry of Deeds on the lower portion of page of
Exhibit F be marked as our Exhibit “F-4”

39. Q: Madam Witness, do you have any authority to represent the company
in this case?
A: Yes Sir. I have the Secretary Certificate Sir dated January 27, 2016.

MANIFESTATION: Witness producing the Secretary Certificate dated


January 27, 2016, which we pray to be marked as our Exhibit “H”, the
signature of Sheryll Macalalad, the Corporate Secretary be
marked as our Exhibit H-1”

40. Q: Madam Witness, can you tell us the maturity date of this loan?
A: January 7, 2016 Sir.

41. Q: Can you tell us if defendant Elenor F. Anonuevo paid this loan in
favor of the company?
A: No Sir.

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42. Q: So what did your office do when Elenor F. Anonuevo failed and
refused to pay her loan with the company?
A: Our lawyer sent a Demand Letter to Elenor F. Anonuevo demanding
payment in the amount of One Million Three Hundred Thirty Six
Thousand Six Hundred Sixty Six Pesos and Sixty Seven Centavos
(P1,336,666.67).

43. Q: And what happened to this Demand Letter?


A: Despite receipt of defendant Anonuevo, she failed and refused to pay
her loan.

MANIFESTATION: Witness producing the demand letter dated


January 29, 2016 which we pray that the same be marked as our
Exhibit “I”

43 Q: When defendant failed and refused to pay her loan despite receipt
of the demand letter from your lawyer, what did your office do in
connection with this loan?
A: We filed a Complaint against the defendant which complaint is
docketed as Civil Case No. 4582.

44. Q: Do you know if after the filing of your complaint, the court issued a
writ of replevin in this case?
A: Yes Sir after the approval of our bond, the Honorable Court issued a
writ of Replevin.

45. Q: And what happened to this writ of replevin, if you know?


A: The Sheriff was not able to seize the Toyota Camry Sedan Car
because according to him defendant Elenor F. Anonuevo hid the said
car.

46. Q: What is your basis in claiming the amount of One Million Three
Hundred Thirty Six Thousand Six Hundred Sixty Six Pesos and Sixty
Seven Centavos (P1,336,666.67) against defendant Elenor F. Anonuevo.
A: The Statement of Account Sir.

MANIFESTATION: Witness producing the Statement of Account


which we pray Your Honor that the same be marked as our Exhibit “J”
and the total amount due be encircled and be marked as our Exhibit
“J-1”.

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47. Q.: Now, Madam Witness, we go back to your Complaint, can you tell
us if a writ of replevin was issued by this Honorable Court in
connection with your Complaint?

A.: Yes Sir. A writ of replevin was issued by the Honorable Court after
the approval of our bond.

48. Q.: And what happen to that writ of replevin which the Honorable Court
issued in favor of the plaintiff?

A.: The Toyota SUV Fortuner 4x4 bearing plate number EFA09 was
seized by the Sheriff of this Honorable Court and since no one is paying
the obligation in favor of MLM Finance Corporation, the Toyota SUV
Fortuner was given to MLM Finance Corporation.

49. Q: Since your company is already in possession of the Toyota SUV


Fortuner, what is your purpose now in continuing and/or proceeding
with this case?
A: We pray that the Honorable Court issued an Order allowing us to
register the Toyota SUV Fortuner in the name of the corporation with the
Land Transportation Office.

50. Q: Regarding the second loan Madam Witness, which according to you
was taken on October 9, 2015 by the defendant Elenor F. Anonuevo,
what is your proof that the defendant Elenor F. Anonuevo obtained a
loan from your company on said date?
A: The Chattel Mortgage with Promissory Note, Sir.

MANIFESTATION: Witness producing the copy of the Chattel


Mortgage with Promissory Note dated November 17, 2015 which
we pray your honor that the same be marked as Exhibit “F”

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51. Q: Can you tell us Madam Witness, how much is the loan obtained from
your company on October 9, 2015 by the defendant?
A: 1,250,000.00 Sir.

52. Q: Can you tell us if this loan is secured:


Yes Sir The same is secured by Toyota Camry Sedan Car bearing plate
Number EPA 08.

53. Q: What is your proof that the Toyota Camry Sedan Car bearing plate
Number EPA 08 belongs to the defendant Elenor F. ANonuevo.
A: The Certificate of Registration and the Official Receipt.

MANIFESTATION: Witness producing the copy of the Certificate of


Registration and the Official Receipt of Toyota Camry Sedan which
we pray your honor that the same be marked as Exhibit “G” and “G-
1”.

54. . Q: now we go back to there are signatures appearing on the said


document, please look at said document and tell us whose signature
appearing above the name MANILYN M. RAMIREZ, Manager.?
A: That is my signature Sir.

55. Q: How about the signature appearing above the name ELENOR F.
ANONUEVO?
A: That is the signature of ELENOR F. ANONUEVO Sir.

56. Q; Why did you say that it is the signature of ELENOR F.


ANONUEVO?
A: I was present when she signed it.
57. Q: There is also a signature appearing on the second page of Exhibit “F”
and the signature is above the name ELENOR F. ANONUEVO, whose
signature is that?
A: That is the signature of defendant ELENOR F. ANONUEVO.

58. Q: Why did you say that it is the signature of ELENOR F.


ANONUEVO?
A; I was present when she affixed her signature thereat.

59. Q: Can you tell us if this Exhibit “F’ is registered with the Office of the
Registry of Deeds for the City of Batangas?
A: Yes Sir.

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60. Q: What is your proof?
A: The stamp marking made by the said office appearing on the second
page of Exhibit “F”.

We pray your honor that the signature appearing above the name
MANILYN M. RAMILEZ be bracketed and be marked as Exhibit “F-
1”, the signature appearing above the name Elenor F. Anonuevo be
bracketed and be marked as Exhibit “F-2”, the signature appearing on
the second page of Exhibit “F”, which signature appears above the name
Elenor F. Anonuevo be marked as our Exhibit F-3 and the stamp
marking made by the Office of the Registry of Deeds on the lower
portion of page of Exhibit F be marked as our Exhibit “F-4”

61. Q: Madam Witness, do you have any authority to represent the company
in this case?
A: Yes Sir. I have the Secretary Certificate Sir dated January 27, 2016.

Witness producing the Secretary Certificate dated January 27, 2016,


which we pray to be marked as our Exhibit “H” , the signature of
Sheryll Macalalad, the Corporate Secretary be marked as our Exhibit
H-1”

62. Q: Madam Witness, can you tell us the maturity date of this loan?
A: January 7, 2016 Sir.

63. Q: Can you tell us if defendant Elenor F. Anonuevo paid this loan in
favor of the company?
A: No Sir.

64. Q: So what did your office do when Elenor F. Anonuevo failed and
refused to pay her loan with the company ?
A: Our lawyer sent a Demand Letter to Elenor F. Anonuevo demanding
payment, the amount of P1,336,666.67.

65. Q: And what happened to this Demand Letter?


A: Despite receipt of defendant Anonuevo, she failed and refused to pay
her loan.

Witness producing the demand letter dated January 29, 2016 which we
pray that the same be marked as our Exhibit “I”

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43 Q: When defendant failed and refused to pay her loan despite receipt
of the demand letter from your lawyer, what did your office do in
connection with this loan?
A: We filed a Complaint against the defendant which complaint is
docketed as Civil Case No. 4582.

66. Q: Do you know if after the filing of your complaint, the court issued a
writ of replevin in this case?
A: Yes Sir after the approval of our bond, the Honorable Court issued a
writ of Replevin.

67. Q: And what happened to this writ of replevin, if you know?


A: The Sheriff was not able to seize the Toyota Camry Sedan Car
because according to him defendant Elenor F. Anonuevo hid the said
car.

identified to by the witness appearing on Exhibit “F”

Q: Under your present oath, do you affirm and confirm the truthfulness
and veracity of your Judicial Affidavit?
A: Yes Sir.

We would like to request your honor that the Judicial Affidavit of MR.
BAYANI H. ANDAL be marked as our Exhibit “E” and his signature as our
Exhibit “E-1”.

That I executed this Judicial Affidavit to serve as my direct testimony in the


above-entitled case and further, for such other legal intents and purposes this may
serve.

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


May, 2017 at Batangas City.

13
MANILYN M. RAMIREZ
Affiant
ID No. _______________

SUBSCRIBED AND SWORN to before me this _____ day of May, 2017


at Batangas City, affiant exhibiting to me his proof of identity indicated below his
name.

Doc. No. _____ JOSELITO M. DIMAYACYAC


Page No. _____ Notary Public For & In The City of Batangas,
Book No. LXXXIII Municipalities of Tingloy, Mabini, Bauan,
Series of 2017 San Pascual and San Jose
Until December 31, 2018
Rm. 3, Golden Luck Bldg,
Apacible Street, Batangas City
Roll No. 26881
PTR No. 2802913/Batangas City/ 01-4-2017
IBP No. 1052877/Batangas City/1-5-2017
MCLE Compliance No. V-0015329/Valid Until:4-14-19

TIN: 114-010-980

ATTESTATION

I, ATTY. JOSELITO M. DIMAYACYAC, of legal age, under oath,


depose and state:

1. I am the lawyer who conducted or supervise the examination of the witness


in the foregoing Judicial Affidavit.

2. I faithfully recorded the questions I asked and the corresponding answers


that the witness gave; and;

3. Neither I nor any other person then present or assisting me coached the
witness regarding the latter’s answer.

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IN TRUTH WHEREOF, I hereunto set my hand this ___ day of May, 2017 at
Batangas City.

JOSELITO M. DIMAYACYAC
Affiant
TIN: 114-010-980

SUBSCRIBED AND SWORN TO before me this ____ day of March, 2013


in Batangas City.

Doc. No. ______


Page No.______ Notary Public
Book No. III
Series of 2013

Copy Furnished:

GUTIERREZ & NITURA LAW OFFICES


No. 668 Quirino Hi-way,
Brgy. Bagbag,
Novaliches, Quezon City

EXPLANATION

Because of the constraints of distance, copy hereof is being sent to


GUTIERREZ & NITURA LAW OFFICES of No. 668 Quirino Hi-way, Brgy.
Bagbag, Novaliches, Quezon City through registered mail with return card instead
of preferred personal service.

JOSELITO M. DIMAYACYAC

@ pang. mike _ elenor anonuevo

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