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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