Republic of the Philippines}

PROVINCE OF LEYTE } S.S.

City of Tacloban }
x------------------------------------x

JUDICIAL AFFIDAVIT
(of Prosecution witness LUNA SANCHEZ in lieu of Direct Testimony)
PRELIMINARY STATEMENT

The person examining me is _____________. My Judicial affidavit is

being taken at the above mentioned place in the presence of LUNA
SANCHEZ and my companions. 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

The testimony of the witness Luna Sanchez is being offered to prove

that she is a witness to the crime of Murder. She will testify on what she
heard on July 1, 2019 regarding the identity of the accused and the
reward/consideration for the killing of the victim.

1. Q. Why are you here?

A. I voluntarily appeared before you because my conscience is
haunting me about the death of Atty. Vito dela Cuesta.

2. Q: Ms. Witness, will you please tell the Honorable Court your name,
age and other personal circumstances?
A: I am Luna Sanchez, Filipino, 34 years old, married and a
resident of Barangay 6A, Tacloban City, Leyte.
2. Q. What is the nature of your business?
A. I am the Executive Assistant of Ms. Camila dela Torre for three
years already.

3. Q. How did you know Atty. Vito dela Cuesta?

A. I personally know Atty. Vito dela Cuesta because we were

childhood friends.

4. Q. How did you know Mrs. Tatyana dela Cuesta?

A.I personally know Atty. Tatyana dela Cuesta because we were also
childhood friends.

5. Q. Where were you on July 1, 2019?

A. I was in the office with Ms. Camila dela Torre.

6. Q. Do you remember what transpired on July 1, 2019?

A. Yes.

7. Q. What happened on that day when you were in the office with Ms. Dela
Torre?

A. In the afternoon of July 1, 2019, I saw Pedro y Santos entered the

office of Ms. Camila dela Torre. While I was about to enter the office,
I overheard the agreement of Ms. Camila dela Torre and Mr. Pedro y
Santos, “Kill Atty. Vito dela Cuesta through whatever means, in
exchange of One Million Pesos (Php 1,000,000.00) payable in
installment. Forty Percent (40%) will be paid today and the remaining
will be given upon execution.“

8. Q. How did you know Pedro y Santos?

A. Upon arriving in the office, he introduced himself as Pedro y Santos

and he said that he has an appointment with Ms. Camila dela Torre.

9. Q. How far were you from the two when you overheard this
conversation?
A. I was two (2) meters away from them.

10. Q. Where were you at this point?

A. I was at a counter behind a bookshelf preparing for the coffee of Pedro y
Santos inside the office of Ms. Camila dela Torre.

11. Q. What happened next?

A. I served the coffee and went out of the office.

12. Q. Did you tell anyone about what you have heard?
A. I told no one.

13. Q. What happened next, if any?

A. On July 9, 2019, I got a call from Ms. Tatyana dela Cuesta and said
that his husband died on July 7, 2019.

14. Q. What did you do, if any?

A. Upon knowledge of the death of Atty.Vito dela Cuesta, I reported to
the Tacloban City Police Station 2 about what I have heard on July 1, 2019.

15. Q. Do you have more to say?

A. No more.

THAT WILL BE ALL FOR THE WITNESS YOUR HONOR.

IN WITNESS WHEREOF, I have hereunto set my hand this day of 17th of
August 2019, at Tacoban City, Leyte.

LUNA SANCHEZ
Affiant
 ATTESTATION CLAUSE

I, ATTY JOVEN S BAUTISTA, hereby attest that I faithfully

recorded the questions propounded and the corresponding answers given
by the witness LUNA SANCHEZ. I asked the questions in English
Language, which she speaks and understand. I did not in any way coach or
taught or instruct the witness on how to answer or any other person or
persons then present or assisting the witness regarding the latter’s
answers.

ATTY. JOVEN S. BAUTISTA

Roll No. 51379-2006
IBP No. 808787-1/3/19
PTR No. 4128464- 1/3/19; Tacloban
MCLE Compliance III No. 0013601
Issued on April 22, 2019

SUBSCRIBED AND SWORN to before me this 17th day of August

2019 at Tacloban City, Leyte, Philippines.

Administering Officer/Notary Public

ATTY. ROB S. BAYAN
Roll No. 54579-2006
IBP No. 808797-1/3/12
TR No. 4228364- 1/3/12;Manila
MCLE Compliance III No. 0013821
Issued on April 22, 2014