Republic of the Philippines

Province of Leyte
REGIONAL TRIAL COURT
Tacloban City
SPOUSES JOHN MARTYN and MARIA MARTYN
and JOMA MARTYN,
Plaintiffs,

Civil Case No: 100110

For: Damages

-versusDR. VICENTE SOTTO LAW SCHOOL,

represented by THEOANNE A. GARCIA,
ATTY. ACTO BIR and ATTY. HINDI N. LAB
Defendants,
x---------------------------------------------------------x

FORMAL OFFER OF PLAINTIFFS DOCUMENTARY EXHIBITS

PLAINTIFFS, by counsel unto this Honorable Court hereby offer the following
documentary exhibits in evidence, to prove their case and most respectfully aver;
1. EXHIBIT A is the Complaint in the above-entitled case consisting of 5
pages including the verification and certification of non-forum shopping. (On
record)
Purpose: To show and prove the fact that the Complaint was
initiated by the proper party-in-interest, within the jurisdictional
period and in compliance with the Rules.
2. EXHIBIT B Certified True Copy of the Deed of Mortgage marked in the
Complaint as Annex A
Purpose: This document is presented to show and prove that
plaintiff, Maria Martyn entered into a mortgage contract,
proceeds of such was used for the enrollment and advance
rentals of Coco Martyn.
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3. EXHIBIT C Official Receipt No. 25466 Dated 29 March 2015 in the amount
of SIXTY THOUSAND PESOS (P60,000.00) original copy is attached to the
records of the case.
Purpose: This document is presented to show and prove that
Coco Martyn made payment for the enrolment in law review.
4. EXHIBIT D and E Certified True Copy of Tenancy Contract and
Acknowledgment Receipt (On record)
Purpose: This document is presented to show and prove that
Coco Martyn contracted and made payment with Rex
Condominium for his advance non-refundable rentals.
5. EXHIBIT F and G Official Receipt No: 08375 Dated March 30, 2015
amounting to ONE HUNDRED THOUSAND PESOS (P100,000.00) and Official
Receipt No. 009364 dated May 1, 2015 amounting to EIGHTY FIVE
THOUSAND PESOS (P85,000.00) original copy is attached to the records of
the case.
Purpose: This document is presented to show and prove that
plaintiffs actually paid amounts therein in preparation for the
graduation of Coco Martyn
6. EXHIBIT H Official Receipt no: 123456, dated March 2, 2015 original copy
is attached to the records of the case.
Purpose: This document is presented to show and prove that
plaintiffs made actual payment to Hotel XYZ
7. EXHIBIT I Certified True Copy of TENTATIVE LIST OF GRADUATING
STUDENTS dated March 30, 2015
Purpose: This document is presented to prove that Coco Martyn
is one of the students whos qualified to graduate on May 30,
2015.
8. EXHIBIT J Official Receipt No. 654321, Dated April 28, 2015, original copy
is attached to the records of the case.
Purpose: This document is presented to prove that Joma Martyn
actually paid the roundtrip flight tickets from Manila-Tacloban
for the purpose of attending the graduation of Coco Martyn.
9. EXHIBIT K ANSWER by defendants dated July 30, 2015, original copy is
attached to the records of the case.
Purpose: This document is presented to show and prove the
judicial affirmation of the defendants regarding their negligent
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and willful disregard in informing Coco Martyn and the Plaintiffs

of his non-inclusion in the list of graduating students.
10. EXHIBIT L SUICIDE LETTER of COCO MARTYN dated June 29, 2015,
original copy is attached to the records of the case.
Purpose: This document is presented to show and prove that
Coco Martyn committed suicide out of depression caused by
herein defendants.
WHEREFORE, it is most respectfully prayed of this Honorable Court that it be
pleased to ADMIT in evidence all the above-mentioned documentary exhibits in
support of the Complaint, and thereafter, upon such admission, petitioners
respectfully rest their case.
Petitioners further pray for such other reliefs and remedies that are just and
equitable in the premises.
Tacloban City, April 1, 2011.

ATTY. MA. HUSAY N. DURO

Counsel for Plaintiff
45 Burgos St., Tacloban City
Attorneys Roll No. 76394
IBP No. 093748/ 01-08-2015/ Tacloban City
PTR No. 098374/01-09-2015/Tacloban City
MCLE No. 093648/ January 14, 2015

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