Republic of the Philippines

REGIONAL TRIAL COURT OF NEGROS OCCIDENTAL

6th Judicial Region
Branch 60, Bacolod City
-oOo-

ARYA A. STARK

Plaintiff,

-versus- CIVIL CASE NO. 1777-08

For: REPLEVIN

LANNISTER’S GARAGE;
JAMIE LANNISTER

Defendant,

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REPUBLIC OF THE PHILIPPINES…………….)

BACOLOD CITY……………………….) S.S

JUDICIAL AFFIDAVIT

I, SANDOR G. CLEGANE, of legal age, married, Filipino, and a resident of

Volantis, Negros Occidental, Region 6 , Philippines, after having been duly sworn to in
accordance with law do hereby depose and say;

PRELIMINARY STATEMENT

The person examining me is ATTY. LOURD V. ARYS. This examination is

being held at the National Bureau of Investigation (NBI), Bacolod City, Negros
Occidental. I am answering the examiner’s questions fully conscious and that I do so
under oath and I am aware that I may face criminal liability for the crimes of false
testimony and perjury.

Question 1: Mister witness, please state your name and other personal circumstances.

Answer 1: I am Sandor G. Clegane, of legal age, single, and residing at Bacolod City.

Question 2: What is your occupation, Mr. Clegane?

Answer 2: I am a mechanist and repairman in Lannister’s Garage; in – charge of the

mechanical and motor repairs.

Question 3: Were you the one handling the vehicle of Ms. Arya Stark at the time it had
caught on fire?

Answer 3: No. I did not handle the repairs of the vehicle. Mr. Jaime Lannister, the
manager and also a mechanist - repairman in the shop.
Question 4: How did the fire occur?

Answer 4: When Mr. Lannister tightened the fuel line to the fuel injector of the vehicle,
the gasoline leaked. This caused the engine to be engulfed in flames. I helped Mr.
Lannister in putting it out. Ms. Stark was there when it all happened.

Question 5: What was the action of Mr. Lannister on the burnt vehicle?
Answer 5: After the fire was extinguished completely, he covered the vehicle up, and
placed it another section of the repair bay.

Question 6: Did Mr. Lannister compensate for the repairs of the burnt vehicle?

Answer 6: Yes. He shouldered the repair expenses, and he deemed it not ready for
check out of the garage.

Question 7: Was there a target date in finishing the vehicle?

Answer 7: No, there was none. The vehicle was repeatedly transferred to different repair
bays in the garage for other repairs on the burnt parts, but, Mr. Lannister accepted other
projects to work on.

Question 8: Did Ms. Stark eventually get her vehicle?

Answer 8: No. When Ms. Stark went to our shop on the day she was supposed to pick up
the vehicle, she and Mr. Lannister had a lengthy conversation about the vehicle and the
damages sustained. Mr. Lannister told her to come back a week after, for the repairs were
not yet completed on her vehicle, and the damage to her vehicle has been shouldered by
the garage.

Question 9: Did Mr. Lannister update Ms. Stark of the progress of the vehicles repairs?

Answer 9: Yes. It was through a phone call that Mr. Lannister told Ms. Stark of the
updates about her vehicle. Mr. Lannister told her that the damage was not caused by his
own fault, and the fire would have occurred without him fixing the vehicle anyway, and
that Ms. Stark should have taken responsibility to check her vehicle for defects, before
she placed the vehicle for repairs. They argued for two hours over the phone.

Question 10: Did Mr. Lannister receive any addition demands from Ms. Stark, to return
the vehicle?

Answer 10: Yes. Days after their argument over the phone, Ms. Stark sent a letter. I
received the letter and gave it to Mr. Lannister.

Question 11: Did you open the letter?

Answer 11: No. I did not. However, Mr. Lannister mentioned that it was Ms. Stark,
demanding the return of her vehicle on January 1, 2017.

Question 12: Did Mr. Lannister return the vehicle after the letter was sent?

Answer 12: No. Mr. Lannister firmly stood his ground of not returning the vehicle to
Ms.Stark, and he told us that it was Ms. Stark’s fault for not informing him or any other
management staff of the potential damage.
Question 13: Did Ms. Stark go back to the garage and asked for the vehicle again?

Answer 13: No. She did not.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 28th day of January,
2018, at Bacolod City, Province of Negros Occidental, Philippines.

SANDOR G. CLEGANE
Affiant

SUBSCRIBED AND SWORN to before me this 25th day of October 2016,

the affiant, who has satisfactorily proven to me his identity through his COMELEC
Voter’s Identification Card, with I.D. no 1200078, issued on December 16, 2012. I
certify that I personally examined the affiant and that I am fully convinced and satisfied
that she voluntarily executed and understood the contents of his judicial affidavit.

ATTESTATION

I hereby certify, that I was the one who personally asked and recorded the
questions and the corresponding answers of the witness; that there is no other person
present when the questions were profounded; and that I did not coach or assist her in her
answers.

IN WITNESS WHEREOF, I have hereunto affix my signature this 28th day of

January, 2018, at Bacolod City, Negros Occidental, Philippines.

LOURD V. ARYS
Counsel for Plaintiff

SUBSCRIBED AND SWORN to before me this 28th day of January, 2018, at Bacolod
City, Negros Occidental, Philippines.