Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Branch 3
Fourth Judicial Region
Lipa City, Batangas

LIMCOMA MULTI-PURPOSE
COOPERATIVE,
Represented by William M. Amazona
or Caroline M. Montante,
Plaintiff,
CIVIL CASE NO. 0026-2014
- versus- For: Collection of Sum of
Money and Damages

SPS. MARIA CRUZ and

JUAN CRUZ,
Defendants.

X------------------------------------------------X

FORMAL OFFER OF EXHIBITS

Plaintiff LIMCOMA MULTI-PURPOSE COOPERATIVE, by

the undersigned counsel, to this Honorable Court, most respectfully submits
its Formal Offer of Exhibits, to wit:

EXHIBIT DOCUMENT PURPOSE

Exhibit “A” Complaint consisting of
To prove that
seven (7) pages and LIMCOMA MULTI-
dated September 26, PURPOSE
2014 COOPERATIVE,
Represented by William
Exhibit “A-1” Signature of Caroline M. Amazona Or
M. Montante on the Caroline M. Montante
Verification and filed this case in court.
Certification of Non-
Forum Shopping page To prove that the
of the Complaint. Verification and
Certification of Non-
Forum Shopping was
signed by Caroline M.
Montante herself.
Exhibit “B” Judicial Affidavit of To prove the veracity
Caroline M. Montante and authenticity of the
consisting of ten (10) claims and allegations
pages and dated May of the plaintiff.
13, 2015

Exhibit “B-1” Signature of Caroline To prove that the

M. Montante, appearing Judicial Affidavit was
on the 9th page of the made by herself.
Judicial Affidavit
Exhibit “C” Secretary’s Certificate To prove that a board
issued by Myren D. resolution was passed
Sastado, dated allowing William M.
September 26, 2014 Amazona and/or
Caroline M. Montante
to file this case in behalf
of the plaintiff.
Exhibit “D” Feed Subsidy To prove that defendant
Application Form, dated Maria Cruz applied for
March 27, 2011, in the feed subsidy and was
name of Maria Cruz approved for 41 heads
and consisting of two on April 5, 2011
pages
Exhibit “E” Kasulatan ng To prove that the
Kasunduan Feed agreement were made
Subsidy Batch No. 11- wherein a total of 186
4077 bags of swine feeds will
be withdrawn by the
defendant from April
11, 2011 to July 25,
2011, who in turn will
deliver to plaintiff post-
dated checks every
withdrawal, as security
for the payment.
Exhibit “F” Feed Allocation To prove that Feed
Program Code F 11- Allocation Program was
4077, prepared by one executed in favor of the
Ajoy Javina and noted defendant herein.
by one Caroline
Montante
Exhibit “G” Sales Invoice No. To prove that defendant
048862, dated June 25, Maria Cruz, under Feed
2011, in the name of Subsidy Batch 11-4077
Maria Cruz and in the made feeds withdrawals
amount of P71,080.00 on account on June 25,
2011
Exhibit “H” Sales Invoice No. To prove that defendant
048939, dated July 19, Maria Cruz, under Feed
2011, in the name of Subsidy Batch 11-4077
Maria Cruz and in the made feeds withdrawal
amount of P71,960.00 on account on July 19,
2011
Exhibit “I” Letter of defendant To prove that defendant
Maria Cruz dated Maria Cruz sent a letter
August 20, 2011 and requested the
addressed and received plaintiff to allow her to
by the plaintiff pay on Sept. 30, 2011,
which the latter
accommodated.
Exhibit “J” Landbank Check No. To prove that said
0103239, dated October check was issued as
30, 2011 and in the replacement of the post-
amount of P71,080.00 dated check previously
issued.

Exhibit “J-1” Stamp marking “Stop To prove that the check

Payment Order” was dishonored by non-
appearing on the face of payment for a common
the check reason, “stop payment
order”
Exhibit “K” Landbank Check No. To prove that said
0103240, dated check was issued as
November 30, 2011 and replacement of the post-
in the amount of dated check previously
P71,960.00 issued.

Exhibit “K-1” Stamp marking “Stop To prove that the check

Payment Order” was dishonored by non-
appearing on the face of payment for a common
the check reason, “stop payment
order”
Exhibit “L” Demand Letter, dated Plaintiff, through
October 18, 2013 and counsel, sent a demand
signed by Atty. Ricardo letter to the defendant
 B. Manalo II demanding the payment
of the amount of
P241,291.89, inclusive
of interest and penalty
as of October 18, 2013.

Exhibit “L-1” Signature of defendant To prove that the

Maria Cruz dated demand letter was
October 22, 2013 received by defendant
appearing on the lower Maria Cruz.
right hand of the
demand letter
Exhibit “M” Statement of Account, To prove that the
as of October 18, 2013, amount due as of Oct.
in the name of Maria 18, 2013 amounted to
Cruz, with due date P241, 291,89 inclusive
August 1, 2011, with of interest and penalty.
total amount due
P241,291.89 and
prepared by Caroline
Montante

Exhibit “M-1” Signature of Caroline To prove that the

M. Montante appearing statement of account
on the Statement of was made by herself.
Account as of October
18, 2013

Exhibit “N” Statement of Account as To prove that the

of May 16, 2014, in the amount due as of May
name of Maria Cruz, 16, 2014 amounted to
with due date August 1, P269, 462.75 inclusive
2011, with total amount of interest and penalty.
due of P269,462.75 and
prepared by Caroline
Montante

Signature of Caroline To prove that the

Exhibit “N-1” M. Montante appearing statement of account
on the Statement of was made by herself.
Account as of May 16,
2014

Certified true copies of Exhibits “C” to “N” are attached to this

Formal Offer of Exhibits. The marked Exhibits “A” to “N” together with
their sub-markings are all attached to the records of the petition with the
Honorable Court.

PRAYER

PREMISES CONSIDERED, it is respectfully prayed that all exhibits

mentioned above be admitted in evidence, and thereafter the plaintiff be
considered to have rested its case.

Other just and equitable reliefs are likewise prayed for.

Batangas City for Lipa City. November 16, 2015.

MANALO & CLEMENO

LAW OFFICES
Counsel for Plaintiff
st
1 Flr. N. Sangalang Bldg.
C. Tirona St., Batangas City

By:

RICARDO B. MANALO II
Roll No. 43030
PTR No. 2336346 1/5/15 Batangas City
IBP No. 945063 1/5/15 Batangas City
Roll No. 43030
MCLE Exemption No. IV-00106
May 16, 2012
The Clerk of Court
Municipal Trial Court in Cities
Branch 3
Lipa City

Greetings:

Please submit the foregoing Formal Offer of Exhibits for the kind
consideration and approval of the Honorable Court immediately upon receipt
hereof.
 RICARDO B. MANALO II

Copy furnished:

Atty. Pedro Paterno

No. 2, Narra St., Liboton
Naga City

Copy of this Formal Offer of Exhibits is furnished to Atty. Pedro

Paterno by registered mail with return card due to distance constraints and
lack of manpower to effect personal service.

RICARDO B. MANALO II