REPUBLIC OF THE PHILIPPINES

7TH JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 55
MANDAUE CITY

INCORPORATED,
Plaintiff,
CIVIL CASE. No. MAN-1234
-versus- FOR: COLLECTION OF
SUM OF MONEY
SPS. BANA & ASAWA
MANGUNGUTANG,
Defendants.
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JUDICIAL AFFIDAVIT OF
JOANNE EUKKI
(In form of Questions and Answers in
Lieu of Petitioners’ Direct Testimony)

WITNESS

Name: Joanne Eukki

Civil Status: Married
Residence: Pagtambayayong, Kalunasas, Cebu City, Philippines

COUNSEL
Name: Atty. Eusselle L. Talisic
Office Address: Sambag 2, Urgello Street,Cebu City
Venue: Counsel’s Office

VERIFIED STATEMENT
I, JOANNE EUKKI, of legal age, married, and a resident of
Pagtambayayong, Kalunasan, Cebu City, Philippines, hereby affirm that the
person interrogating me is Atty. Eusselle L. Talisic, with office address at
LIM and Associaties Law Firm, Sambag 2, Urgello Street,Cebu City. The
interrogation is being held at the same address.

I am answering her questions fully conscious that I do so under oath

and that I may face criminal liability for false testimony or perjury.
OFFER OF TESTIMONY: The testimony of witness, JOANNE EUKKI is
being offered as direct testimony of the above-mentioned case:
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1.) Q: Please state your name, age, civil status, occupation, and
address.
A: I am JOANNE EUKKI, of legal age, married, Filipino and
resident of Sta. Lucia Village, Banilad, Cebu, Guard
House.

2.) Q: What is your employment position in , Inc.?

A: I am a legal officer of , Inc.

3.) Q: When you say legal officer, could you explain to this
Honorable Court, briefly, your functions?
A: I am in charge of all customers with credit facilities and once
their accounts become delinquent, it is my job to collect from
them, either through extrajudicial or judicial means.

4.) Q: What’s your area of responsibility or jurisdiction?

A: I am covering Visayas area.

5.) Q: How did you come to know the defendants?

A: They were customers of LIM, Inc.

6.) Q: When you say customers of LIM, Inc., what do you mean by
that?
A: On several occasions they purchased chicken feeds and
other allied products from LIM, Inc., under their family owned
business know as Alkanse Farms.

7.) Q: Do you have proof that they were customers?

A: Yes. When they initially transacted with LIM, Inc., they issued
to us several documents as part of their requirements, like the
following already pre-marked documents in my possession:
Exh. “TT” – Tax Declaration No. 006471 in the name of
defendants.
Exh. “UU” – Credit Recommendation
Exh. “VV” – Credit Check Acceptance form with picture
Exh. “WW” – Specimen Signature Card
Exh. “XX” – Bank Authorization Form
Exh. “YY” – Account Profitability Analysis

8.) Q: How did defendants purchase chicken feeds and other allied
products from LIM, Inc.?
A: They were granted a credit line with LIM, Inc.

9.) Q: What happened to the credit or account of defendant

spouses?
A: It became delinquent.

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10.) Q: When you said it became delinquent, what do you mean?

A: Defendant spouses failed to pay LIM, Inc. its obligation when
it became due amounting to ONE MILLION PESOS AND ONE
CENTAVO (P1,000,000.01), exclusive of interests despite
repeated demands.

11.) Q: Why do you say defendants failed to pay their debt with LIM,
Inc.?
A: All of the checks issued by the defendant spouses bounced
or were dishonored.

12.) Q: Do you have the checks right now?

A: Yes, I do. These were pre-marked as Exhs. “P”, “Q”, “R”,
“S”, “T”, “U”, and “V”.

13.) Q: Aside from the checks, what other documents do you have to
prove defendants’ obligation?
A: We also have charge sales invoices and delivery receipts, in
my possession, which were pre-marked as Exhs. “W”, “X”,
“Y”, “Z”, “AA” through “SS”.

14.) Q: By the way, were defendants notified of their unpaid

obligation?
A: Yes.

15.) Q: Do you have any proof to that allegation?

A: Yes. In fact defendant-Asawa Mangungutang signed a
promissory note or written acknowledgment of their debt, dated
August 31, 2001, in my possession and which was pre-marked
as Exh. “A”.

16.) Q: After signing the document acknowledging their debt, did

defendants make any payment of their debt to LIM, Inc.?
A: No.

17.) Q: What did LIM, Inc. do, if any?

A: We had our lawyer send a demand letter to defendants. Said
letter is in my possession and pre-marked as Exh. “B”.

18.) Q: Were the defendants notified of their dishonored checks?

A: Yes through demand letter from our lawyer, which was
previously marked as Exh. “C”.

19.) Q: What did defendants-spouses do after they were sent with

said demand letters?
A: They still refused to pay their debt with LIM, Inc. until now.

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All the foregoing has been explained to me by the notary public, and I
fully understood the meaning and import of the averments above, and
I attest to its veracity.

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

____________________ 2017 in Cebu City, Philippines.

JOANNE EUKKI
Affiant
Competent Evidence of Identity
Expires on:

-SWORN ATTESTATION-

I hereby attest that I faithfully recorded the questions I asked and the
corresponding answers that the witness gave and neither she nor any
other person then present or assisting her coached the witness
regarding the latter’s answers.

ATTY. EUSSELLE LIM

SUBSCRIBED AND SWORN to before me this _____ day of

_______________ 2017 in the City of Cebu, Philippines.

Doc. No. _______;

Page No.________;
Book No._______;
Series of 2017

Copy furnished through registered mail:

ATTY. EUNICE U. WAN Registry Receipt

No.
69th Floor Dakong Bldg., Date:
Eskinita St.
Cebu City

(Explanation as to the mode of filing and service)

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Copy of the foregoing was furnished through registered mailing to the

above-named counsel because of the distance, which render
personal service impracticable.

ATTY. EUSSELLE LIM,