Republic of the Philippines

REGIONAL TRIAL COURT

FOURTH JUDICIAL REGION
BRANCH 53, LUCENA CITY

NEW NORMAL BANK OF Civil Case No. 12345

THE PHILIPPINES,
Plaintiff,

– versus –
For: Action for Sum of Money
with Preliminary
SPOUSES JUDAS AND Attachment
SANTISIMA
MANDURUGAS,
Defendants.
x x

FORMAL OFFER OF EVIDENCE

Defendants, through the undersigned counsel, unto the

Honorable Court, most respectfully files this FORMAL OFFER
OF EVIDENCE for marking and admission of the following:

Exhibit Description Purpose

To prove that the loan
officer of New Normal
Bank of the Philippines
1 CCTV Footage
(NNBP) came to the
house of the Defendants
to offer the latter a loan.

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 To prove that the whole
Lucena were severely
2 Weather Report
ravaged by Typhoon
Imbento.
To prove that the
Province of Lucena was
Proclamation No.
3 placed under State of
88, Series of 2019
Calamity of December
26, 2019
To prove that there is
notice to Mr.
Screen Capture of
Dimaisahan about the
the message
inability to pay on the
4 between Defendant
due date and his
Spouses and
confirmation that
Dimaisahan
Defendants may pay on
the next banking day.
Notice by the
Defendant Spouses
To prove there is tender
of their intention to
of payment by
5 consign the
Defendants in favor of
amortization
Plaintiff
payments with the
court
Court Decision
dated March 14, To prove there is
2020 granting the consignation of the
6
Petition for amortization payments
Consignation of before the court.
Payment
To prove that the second
Second Notice on
notice requirement for
the consignation of
7–8 the consignation of
the payment and
payment have been
Proof of Delivery
complied with
9 Official receipts To prove deposit of the

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 from the Clerk of amortization payments
Court of Lucena for the subsequent
months
Notice of
Foreclosure, Notice To prove there is an
of Foreclosure ongoing foreclosure
10, 12, & 13 posted in three proceeding against the
public places, Cut- beach property exercised
out of the Ang by the plaintiff bank
Diyaryo Natin
Letter dated
To prove that the
September 2, 2020
plaintiff is properly
11 reiterating the
informed of the fact of
consignation of
consignation of payment
payment
To prove that the
Hospital Statement Defendants were
15
of Account confined in a hospital
due to COVID-19
To prove the dire
intention of the Plaintiff
18, 19, & 20 Letters of Intent
bank to take hold of the
properties.
To prove that the
Plaintiff acquired the
Deeds of Absolute
24, 25, & 26 beach properties
Sale
adjacent to the
Defendants’ estate
To prove the intent of the
Plaintiff of acquiring the
27, 28, & 29 Proofs of Payment beach resort property by
acquiring the adjacent
neighboring estates

With the submission and admission of the aboce evidence

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together with the oral testimony of defendants, defendants rest
its case.

Lucena City, Quezon Province. 07 December 2020.

RESPECTFULLY SUBMITTED.

jenyudespejo
ATTY. JENYUD J. EPSEJO
Legal Counsel
Belarmino, Calora, Espejo, Florentino & Hizola Law Office
3/F Pacific Star Building, Sampaguita St.,
Lucena, Quezon Province
Attorney’s Roll No. 56183
Lifetime IBP No. 12390
MCLE Comp. No. VI-0010591,
10/25/2019, Pasig City
PTR No. 0987654673
TIN No. 1257642

COPY FURNISHED:

EXPLANATION

Copy of this Formal Offer of Evidence is served to the

Plaintiff through electronic mail and filed in court through
electronic mail due to lack of office personnel and restrictions
brought about by the community quarantine due to the COVID-
19 pandemic.

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