Republic of the Philippines

Fifth Judicial Region

REGIONAL TRIAL COURT
Branch ___
Sorsogon City

THE LOCAL GOVERNMENT OF

SAN PASCUAL, BACON DISTRICT,
SORSOGON CITY, as represented
by its punong barangay, ARMANDO
D. DETERA,
Plaintiff,
- versus - CIVIL CASE No. 2020-______
For: RECONVEYANCE OF TITLE
MSGR. JOSE ALLAN V. DIALOGO, and ANNULMENT OF TITLE; etc.
Roman Catholic Bishop of Sorsogon;
The DEPARTMENT OF EDUCATION
DepEd), represented by DR. WILLIAM
E. GANDO, Sorsogon City Division
Superintendent of Schools; and
others,
Defendants,
x -------------------------------------------------x

JUDICIAL AFFIDAVIT
OF ARMANDO D. DETERA, PUNONG BARANGAY OF SAN PASCUAL,
BACON DISTRICT, SORSOGON CITY, AS TAKEN BY THE PLAINTIFF’S
COUNSEL, ATTY. ROBERTO T. LABITAG, SORSOGON CITY LEGAL
OFFICER, IN HIS OFFICE AT THE SORSOGON CITY HALL ON JUNE 19,
2020
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01. Q: As stated in the complaint in this case, your good self, sir, as the incumbent
punong barangay, is the legal representative of the plaintiff in this case, the
Barangay of San Pascual, Bacon District, Sorsogon City. Is this correct?
A: Yes, sir. That is correct.
02. Q: For the record, please state your full name, age, civil status,
occupation/official public position and place of residence.
A: ARMANDO D. DETERA, 53 years of age, married, a farmer and incumbent
Punong Barangay of San Pascual, Bacon District, Sorsogon City, and a
resident thereof.
03: Q: Has the Sangguniang Barangay of San Pascual passed and approved a
resolution empowering you to represent this local government unit (LGU)
as the plaintiff in this case?
A: Yes, sir. A duplicate original copy of such a resolution is appended as Annex
“A” to the complaint in this case.
04. Q: We will mark this duplicate original copy of this Resolution as our Exhibit
“A”. Do you agree?
A: Yes, sir. Please mark it accordingly.
05. Q: As stated in the complaint in this case, what is known as the barrio site of
San Pascual, Bacon District, Sorsogon City, originally belonged to Juiian
Detera, its primitive owner and long-time teniente del barrio of San Pascual.
Sometime in 1911, he ceded this property to become such a barrio site where
the barrio hall, the Roman Catholic Chapel and the elementary school, along
with the people of San Pascual were to be located. Is this true and correct?
 A: Yes, sir.
Page 2 of 9 pages

06 Q: How did you come to know the fact that the original owner of the San Pascual
barrio site was the long-time teniente del barrio Julian Detera and that he
turned it into such a barrio site sometime in 1911?
A: This fact has been handed down to us by our parents and grandparents. This
fact is also known to the native residents of San Pascual and has thus
become the common reputation of the San Pascual barrio site as to its
historical origin. Such a fact has thus become a matter of public or general
interest among the people of our locality.
07. Q: How did you become a direct descendant of the then teniente del barrio
Julian Detera?
A: The then teniente del barrio Julian Detera was my great grandfather. My
biological father was Benjamin Desalisa Detera who was the son of Mateo
Detera whose biological father was Julian Detera.
08. Q: Upon being turned into the barrio site of San Pascual, what did the people of
San Pascual do?
A: At the behest of teniente del barrio Julian Detera, a good number of native
residents of Barrio San Pascual relocated their households in the said barrio
site. Per my latest count, there are thirty-nine (39) households existing in our
barrio site, free of charge, as was the legacy to them by the then teniente del
barrio Julian Detera.
09. Q: How about the Roman Catholic Church, what did it do?
A: The Roman Catholic Church also occupied a portion of our barrio site and
built its modest chapel therein.
10. Q: How about the barrio of San Pascual appreciate the generosity of Julian
Detera.
A: Barrio San Pascual also built its barrio hall within the premises of the land
ceded by teniente del barrio Julian Detera.
11. Q: And the Department of Education, what did it do?
A: Sometime in 1948, the Department of Education (DepEd) built its elementary
school near our barrio hall at the behest of teniente del barrio Julian Detera.
12. Q: As regards the Roman Catholic Church, what else, if any, did it do with the
barrio site vouchsafed by teniente del barrio Julian Detera to the people of
Barrio San Pascual?
A: Unbeknownst to the then nonliterate people of Barrio San Pascual, the
Roman Catholic Bishop of Nueva Caceres judicially registered our barrio site
in its entirety and was issued Original Certificate of Title (OCT) No. 228 on
June 03, 1927.
13. Q: The barrio site, in its entirety?
A: Yes, sir. The whole of it.
14. Q: How big was the subject barrio site?
A: As registered in 1927, it has an area of Fifteen thousand two hundred and
sixty-six (15,266) square meters. sir.
15. Q: Do you have a duly certified copy of OCT No. 228 in the name of the Roman
Catholic Bishop of Nueva Caceres?
A: No, sir. What I have here is the duly certified copy of its derivative― Transfer
Certificate of Title (TCT) No. T-5054 that was issued on March 30, 1988 in
the name of the Roman Catholic Bishop of Sorsogon... Here is it. (Witness
handing over to his interlocutor the document.)
16. Q: A copy of this document is attached to the complaint as Annex “A”. However,
we will mark this duly certified machine copy of Transfer Certificate of Title
(TCT) No. T-5054 issued by the Register of Deeds as our Exhibit “B”. Do
you have any objection?
A: None, sir. Please mark the same accordingly.
17. Q: Why was it that this property, 15,266 square meters in area, was originally
 Page 3 of 9 pages

registered in the name of the Roman Catholic Bishop of Nueva Caceres, and
not in the name of the Roman Catholic Bishop of Sorsogon.
A: It must be because in the 1920s, the Province of Sorsogon was just a parish
of the Roman Catholic Diocese of Nueva Caceres (Camarines Sur). This
explains why our barrio site, due to ecclesiastical acquisitiveness, was
originally registered in the name of the Roman Catholic Bishop of Nueva
Caceres. It was years after the Province of Sorsogon became a diocese, that
OCT No. 228 was caused to be cancelled and in lieu of it TCT No. T-5054
was issued by the Register of Deeds in the name of the Roman Catholic
Bishop of Sorsogon.
18. Q: Does the Roman Catholic Diocese of Sorsogon, thru its bishop, possess the
whole area of the San Pascual barrio site, 15,266 square meters, all told?
A: No, sir. It only possesses the area occupied by the Roman Catholic chapel
and its patio. In fact, the Roman Catholic Diocese of Sorsogon has only
declared as its own for taxation purposes just a portion of our barrio site with
an area of 1,760 square meters, even though the Church itself is exempt
from taxation.
19. Q: Are you sure of what you are saying?
A: Yes, sir. The portion of the barrio site truly owned and possessed by the
Roman Catholic Bishop of Sorsogon is the area occupied by the chapel and
patio with a declared area of 1,760 square meters. The remainder, which is
more than 13,000 square meters, rightfully belongs to the Barangay of San
Pascual, including the 3,491 square meters which our Barangay, on February
02, 2016, donated to the San Pascual Elementary School-DepEd.
19. Q: Do you have a duly certified copy of the Roman Catholic Diocese of
Sorsogon’s Tax Declaration over the portion of the San Pascual barrio site it
is occupying?
A: Yes, sir. It is appended to the complaint as Annex “B”.
20. Q: We will mark this ARP No. 2011-01-0019-00310 issued in the name of the
Roman Catholic Church, San Pascual, Bacon, Sorsogon, over a 1,760-
square meter parcel of land as our Exhibit “C”. Are you agreeable?
A: Yes, sir. Please mark the same accordingly.
21. Q: As far as you know, is there any other parcel of land in San Pascual that the
Roman Catholic Diocese of Sorsogon has declared as its own?
A: Of my own knowledge, sir, other than the 1,760-square meter portion of our
barrio site, there is no parcel of land within the vicinity of San Pascual, Bacon
District, Sorsogon City, that is declared in the name of the Roman Catholic
Church, thru its diocesan bishop.
22. Q: Has the Roman Catholic Diocese of Sorsogon ever asserted its certificate of
title against the Barangay of San Pascual or against the private residents of
the said barrio site?
A: After a period of ninety-three (93) years counted from the issuance of OCT
No. 228 on June 03, 1927, the Roman Catholic Church has kept mum about
its certificate of title to our barrio.. At present, it has yet to assert such a
certificate of title against Barangay San Pascual as a local government unit.
Recently, however, the priest in charge of the Roman Catholic Chapel of San
Pascual has exhorted the residents of our barrio site to either pay rent or buy
from the Church the portions of the barrio site occupied by their respective
households.
23. Q: And how did the residents of San Pascual barrio site react to the priest’s
exhortation?
A: They protested by telling the priest that the barrio site rightfully belongs to the
Barangay of San Pascual and not to the Catholic Church. Hence, it should be
to the Barangay, and definitely not to the Church, that they should either pay
the rent or pay the purchase price. The priest was silenced by a motley group
of the faithful of Barangay San Pascual.
 Page 4 of 9 pages

24. Q: Incidentally, when did you come to know that the San Pascual barrio site is
actually registered under the Torrens system in the name of the Roman
Catholic Bishop of Nueva Caceres, and then later in the name of the Roman
Catholic Bishop of Sorsogon?
A: Only in August 2019, sir, when I was impelled to do some painstaking
research on the historical events and circumstances of our barrio site due to
the deceit perpetrated against our Barangay San Pascual by Ms. Nympha D.
Guemo, former Sorsogon City Schools Division Superintendent, and his
subalterns, particularly Joevic Elquiero. the schoolhead of San Pascual.
25. Q: Please briefly describe the deceit committed against Barangay San Pascual
by the persons you mentioned.
A: Instead of simply obtaining a special patent for the 3,491-square meter
portion of our barrio site as donated by our barangay to the San Pascual
Elementary School-DepEd, Ms. Nympha D. Guemo and her subalterns
willfully registered, thru such a special patent an portion of our barrio site
containing an area of 5,491 square meters, which now included the portion
occupied by our Barangay Hall and Rural Health Center. It was now the
donee, the DepEd, in manifest ingratitude, which is demanding of the donor,
the Barangay of San Pascual, to vacate its own premises. In the course of my
research, I stumbled on the most dismaying fact that our barrio site is unduly
registered in the name of the Roman Catholic Bishop of Nueva Caceres and
later, in the name of the Roman Catholic Bishop of Sorsogon.
26. Q: Which agency or instrumentality of the Government issued the special patent
you just mentioned?
A: The DENR-PENRO, sir.
27. Q: You have just stated that Barangay San Pascual donated a 3,491-square
meter portion of its barrio site to the San Pascual Elementary School-DepEd.
When did this happen?
A: The donation happened on February 02, 2016, sir.
28. Q: Do you have any document to prove the fact that Barangay San Pascual
indeed donated a 3,491-square meter portion of its barrio site to the San
Pascual Elementary School-DepEd?
A: Yes, sir. Attached to the complaint as Annex “D” is a duly certified copy of an
unnumbered Resolution of the Sangguniang Barangay of San Pascual dated
February 02, 2016, effectually donating such 3,491-square meter portion of
its barrio site to the San Pascual Elementary School-DepEd. The donation
was formalized in a public document on July 15, 2016, a certified copy of
which is attached to the complaint as Annex “E”.
29. Q: We will mark this certified copy of an unnumbered Resolution of the
Sangguniang Barangay of San Pascual, donating 3,491-square meter portion
of its barrio site to the San Pascual Elementary School-DepEd, as our
Exhibit “E”, and the Deed of Donation subsequently executed by the
parties, as our Exhibit “F”. Do you have any comment?
A: None, sir. Please mark them accordingly.
30. Q: Do you have a duly certified copy of the original certificate of title issued on
the basis of such special patent in the name of the San Pascual Elementary
School?
A: Yes, sir. A duly certified copy of Original Certificate of Title (OCT) No.
2017000098 issued to San Pascual Elementary School-DepEd on the
strength of Special Patent No. SP-Sch-SOR-0003 over a 5,491-square
meter portion of the barrio site is attached to the complaint as Annex “F”.
31. Q: We will mark this certified copy of Original Certificate of Title (OCT) No.
2017000098 attached to the complaint as our Exhibit “G”. Do you agree?
A: Yes, sir. Please mark it accordingly.
32. Q: Is the 5,491-square meter portion of the San Pascual bario site, as registered
in the name of San Pascual Elementary School-DepEd, included in TCT No.
 Page 5 of 9 pages

T-5054 in the name of the Catholic Bishop of Sorsogon, which is a derivative

of OCT No. 228 issued in the name of the Roman Catholic Bishop of Nueva
Caceres sometime in 1927?
A: Yes, sir... Without doubt, it is included in the certificates of title of the Roman
Catholic Church that harks back to 1927.
33. Q: Would I be correct to say that a portion of the San Pascual barrio site already
registered many years ago under the Torrens system in the name of the
Roman Catholic Bishop of Nueva Caceres as of 1927 is recently registered
all over again under the same system of land registration in the name of
another entity?
A: Yes, sir, you are correct. Special Patent No. SP-Sch-SOR-0003 was issued
by the DENR-PENRO to the San Pascual Elementary School without any
reference howsoever to the certificate of title to the San Pascual barrio site in
the name of the Roman Catholic Bishop of Nueva Caceres and subsequently
in the name of the Roman Catholic Bishop of Sorsogon. The said special
patent was thus issued as though the land covered thereby were stlll a public
land when in truth and in fact it is already registered in the name of a religious
entity; hence, no longer a public land disposable by the State thru a special
patent.
34. Q: Do you mean to say that OCT No. 2017000098, as issued on the basis of
Special Patent No. SP-Sch-SOR-0003 (Exhibit “G”), is null and void, having
been issued over a piece of land that is no longer a public land?
A: Yes, sir. You hit the nail right on the head. Our barangay is seeking a judicial
declaration of nullity of such a fake special patent and the original certificate
of title issued on the basis thereof.
35. Q: Do you have any proof that the 5,491-square meter parcel of land subject of
Special Patent No. SP-Sch-SOR-0003, and now covered by OCT No.
2017000098 of the San Pascual Elementary School, is indeed a part and
parcel of theSan Pascual barrio site already covered by TCT No. T-5054 in
the name of the Roman Catholic Bishop of Sorsogon?
A: Yes, sir. Attached to the complaint as Annex “G” is the Tax Declaration No.
2011-01-0019-00697 for the 5,491-square meter portion registered OCT No.
2017000098 in the name of the San Pascual Elementary School. It is stated
in this tax declaration that the previous owner of the real property so declared
is the “BARRIO OF SAN PASCUAL”.
36. Q: We will mark this Tax Declaration No. 2011-01-0019-00697 as our Exhibit
“H”. Any comment?
A: None, sir. Please mark it accordingly.
37. Q: Is there anything else about the barrio site of San Pascual that you have
uncovered or discovered in the course of your research?
A: Yes, sir. My great grandfather Julian Detera, primitive owner of our barrio site,
executed sometime in 1948 an Escritura de Donacion (Deed of Donation)
over a 5,625-square meter portion of the San Pascual barrio site for the
education of the children of San Pascual, Bacon, Sorsogon, naming the then
Municipal Mayor of Bacon, Hon. Juan D. Deocareza. as the representative of
the unnamed children of San Pascual, and the “bureau” of education as the
implementor thereof.
38. Q: What proof do you have about the existence of this Escritura de Donacion?
A: Attached to the complaint as Annex “C” is a certified notarial copy of the said
escritura de donacion, yellowed by age, and thus quite hard to decipher. But I
also have obtained in the course of my research a rough English translation
of this escritura, which is attached to the complaint as Annex “D”.
39. Q: We will mark this certified notarial copy of Escritura de Donacion as our
Exhibit “I” and rough English translation thereof as our Exhibit “I-1”. Any
comment?
A: None, sir. Please mark them accordingly.
 Page 6 of 9 pages

40. Q: Incidentally, where did you get this rough English translation of Julian
Detera’s Escritura de Donacion?
A: I was furnish with such English translation of the escritura by Mr. Joevic D.
Elquiero, the school head of San Pascual Elementary School, Bacon District,
Sorsogon City. He did so in one of our heated discussions about the subject
donation.
41. Q: What do you make out of this Escritura de Donacion.
A: It shows that my great grandfather Julian Detera was indeed the primitive
owner of our barrio site; otherwise, he would not have thought of donating a
portion thereof. But I daresay that such a donation was null and void, sir.
42. Q: Why do you say that such a donation is null and void?
A: In one of our brainstorming sessions for the preparation of the complaint in
this case, we have come to the conclusion that this 1948 deed of donation by
my great grandfather Julian Detera was a nullity; firstly, because the donation
had no express acceptance in writing by the children-donees who are not
named individually in the escritura itself. Secondly, the then Mayor of Bacon,
Sorsogon, Juan D. Deocareza does not appear to have been judicially
constituted as legal guardian of the unnamed children-donees, as to have
had the power to accept the donation on behalf of his supposed wards.
Thirdly, the bureau of education is not specifically named in the escritura as a
donee as to have had accepted the donacion.
43. Q: Was the DepEd, as represented then by Sorsogon City Schools Division
Superintendent Nympha D. Guemo aware of the nullity of this Escritura de
Donacion?
A: The probability is that she was very much aware, sir. For she, Nympha D.
Guemo, did her best to obtain from our barangay a latter-day Deed of
Donation (Exhibit “F”) of the premises occupied by the San Pascual
Elementary School. If she thought the escritura de donacion was valid, she
would have found no need for the donation that was executed by our
Barangay San Pascual in favor of her elementary school on July 15, 2016.
44. Q: What, if any, have you noticed in this July 15, 2016 Deed of Donation?
A: It does not specifically state the area of the portion of the barrio site so
donated, sir. In regard to this omission, you will have to refer to the 02
February 2016 unnumbered Resolution of the San Pascual Sangguniang
Barangay donating a portion of the said barrio site with an area of 3,491-
square meters, and definitely not 5,491 square meters.This omission, sir, is
deliberate and willful, calculated to deceive the unwary.
45. Q: How about OCT No. 2017000098 (Exhibit “G”), what can you say about it?
A: OCT No. 2017000098 (Exhibit “G”) has been issued in the name of San
Pascual Elementary School which has no legal personality of its own, and
cannot therefore own any real property.
46. Q: Who, if you know, prepared this Deed of Donation, as signed by the parties
and their instrumental witnesses?
A: This deed of donation was notarized by Atty. Maria Flor De Lis G.
Domasian, the legal counsel of the Sorsogon City Schools Division
Superintendent. It is thus safe to assume that she was the one who prepared
the said deed of donation that does not state the area of the portion of the
barrio site so donated by our barangay.
47. Q: Were you the incumbent punong barangay of San Pascual, Bacon District,
Sorsogon City on July 15, 2016?
A: No, sir. I was not yet the punong barangay at that time. The incumbent
punong barangay then was Mr. Alberto A. Deterala.
48. Q: Let us go to another point. Now one of the causes of action stated in the
complaint is for the revocation of the July 15, 2016 Deed of Donation by
reason of ingratitude. How do you justify this particular cause of action?
A: The DepEd, as represented by Ms. Nympha D. Guemo and her underflings
are ingrates. In spite of her being a doctor of education, she deceitfully
 Page 7 of 9 pages

caused the registration of the portion of the subject barrio site donated by our
barangay far in excess of the area so donated.
49. Q: What other acts of ingratitude did the DepEd, thru Ms. Guemo and her
subalterns commit against the San Pascual Barangay, the donor, as
represented by you as its incumbent punong barangay?
A: Sometime in August of 2019 when I, in my capacity as punong barangay
caused the renovation of our barangay hall under the auspices of the DPWH,
Ms. Guemo, thru her subalterns, particularly Joevic Elquiero, vehemently,
albeit unsuccessfully, opposed the project, to the great consternation and
embarrassment on my part as the punong barangay. Ms. Guemo’s underlings
led by Mr. Elquiero told me in public that our barangay no longer owns the
physical location of our barangay hall, because the same is now included in
the certificate of title of the elementary school of San Pascual.
50. Q: What acts of ingratitude did the DepEd representatives further commit
against the barangay donor?
A: Recently, our barangay embarked on the project of reconstructing its Health
Center. Elquiero once again opposed the implementation of the project by
asserting the bogus OCT of his school against our barangay. Elquiero even
went to the extent of sending a letter to the Sorsogon City Mayor to order the
stoppage of the project. He further accused me before the DILG Secretary
Año for some imagined offense in order to intimidate and prevent me from
further undertaking the project.
51. Q: Do you have a certified copy or a duplicate original copy of Elquiero’s letter to
the City Mayor, as well as the complaint filed against you with the DLIG
Secretary Año?
A: Elquiero’s letter to the City Mayor is attached as Annex “H” to the complaint in
this case, sir, while the complaint he filed against me with DILG Secretary is
attached to the same complaint as Annex “I”.
52. Q: We will mark this letter of Elquiero’s to the City Mayor as our Exhibit “J” and
this complaint of Elquiero’s with the DILG Secretary as our Exhibit “K”. Do
you agree?
A: Yes, sir. Please mark them accordingly.
53. Q: In opposing the reconstruction of your barangay’s health center what more
did Elquiero do?
A: Elquiero furthermore tried to cause the Department of Health (DOH) to
withhold the funds for our Barangay Health Center, ostensibly due the fact
that the physical location of our barangay health center is included in the
bogus certificate of title of his elementary school. He nevertheless did not
succeed to persuade the DOH in doing his malicious endeavor.
54. Q: Are these the reasons why you are seeking the revocation of the your
barangay’s July 15, 2016 Deed of Donation in favor of the San Pascual
Elementary School ― ingratidue committed by the donee as against the
property of the Donor?
A: Yes, sir. They are, indeed. The DepEd, thru Ms. Guemo and her subalterns
are now ousting our barangay from its very own real property.
55. Q: Now, in the complaint in this case, your barangay is claiming temperate or
moderate damages from Ms. Guemo, Mr. Elquiero in solidum, and nominal
damages from Elquiero alone, as well as nominal damages from the officer(s)
of the DENR-PENRO who facilitated the issuance of Special Patent No. SP-
Sch-SOR-0003. How do you justify these claims for damages.
A: Like I said, Nympha D. Guemo, in spite of her being an educator, deceitfully,
caused the registration of the portion of the subject barrio site donated by our
barangay far in excess of the area so donated, to the damage and injury of
our barangay. When the donor later caused the renovation of its barangay
hall, defendant Guemo, thru her subalterns, particularly defendant Elquiero,
vehemently, albeit unsuccessfully, opposed the same, to the great
 Page 7 of 9 pages

consternation and embarrassment of our barangay, as personified by me, its

incumbent punong barangay. I was told to my face that the physical location
of the barangay hall being renovated is included in the school’s certificate of
title. The deceit perpetrated against our barangay donor, the ingratitude by
them who represent the donee, and the most embarrassing words they
officially said to me in my capacity as punong barangay are, I daresay,
enough to warrant an award of temperate damages.
56. Q: How about your claim for nominal damages against schoolhead Esquiero.
How do you justify it?
A: Schoolhead Elquiero opposed the reconstruction of our barangay health
center when Ms. Guemo was no longer the Sorsogon City Schools Division
Superintendent. Elquiero did his opposition by his own lonesome, as I have
no knowledge that the new schools division superintendent egged on or
abetted Elquiero to oppose the project, thereby delaying considerably the
completion thereof at a time when it is most needed by our barangay due to
the corona virus pandemic. This, I do believe, justifies the award of nominal
damages in our favor.
57. Q: How about your barangay’s claim for nominal damages against the officer(s)
of the DENR-PENRO who recommended the issuance of Special Patent
No. SP-Sch-SOR-0003.
A: The officer(s) of the DENR-PENRO responsible for recommending the
issuance of such a special patent has been grossly negligent in doing so, for
the following reasons: (a) He/she/they did not first ascertain that the portion of
the barrio site donated by our barangay was included, albeit irregularly, in the
certificate of title of the Roman Catholic Bishop of Sorsogon; and (b)
He/She/They did not bother to determine the correct are so donated, thereby
causing damage and prejudice to the interests of our barangay. He/she/they
must therefore pay nominal damage to our barangay.
58. Q: In the meantime, I have no further questions to ask of you. Of your own free
will, are you going to subscribe and swear to the truth of the contents of this
judicial affidavit before a notary public or an officer duly authorized by law to
administer oaths?
A: Yes, sir.

ARMANDO D. DETERA
Witness-Affiant

SUBSCRIBED and sworn to before me personally by the above-named

witness-affiant this ___day of July, 2020, at Sorsogon City, Philippines. And I do
hereby certify that I have ascertained the identity of the said affiant to be no other
than Mr. Armando D. Detera, thru respective valid and subsisting DILG
Identification Card No. ___________ with colored pictures of their respective
likenesses and customary signatures embossed thereon.

WITNESS MY HAND AND SEAL.

Page 7 of 9 pages
 ATTESTATION
_______________________

I, ROBERTO T. LABITAG, am the plaintiff’s counsel in this case, and I do hereby

attest under oath that:

(1) I faithfully recorded the questions I asked and the

corresponding answers that the witness, Mr. Armando D.
Detera gave; and,
(2) Aside from this witness, I was the only person present in my
office where he and I had our interview for the purpose of
jointly taking his judicial affidavit, and I never did coach them
in regard to any of the answers he gave, as recorded.
IN WITNESS WHEREOF, I have hereunto subscribed my name, this ___ day of
July 2020, at Sorsogon City, Philippines.

ROBERTO T. LABITAG
Plaintiff’s’ Counsel

SUBSCRIBED and sworn to before me personally by the above-named

complainants’ counsel this ___ day of July, 2020, at Sorsogon City, Philippines.
And I do hereby certify that I have ascertained the identity of the said counsel to
be no other than Atty. Roberto T. Labitag, himself being personally known to me
as a fellow lawyer and fellow IBP member, Sorsogon Chapter. There is thus no
need of further ascertaining his identity through his valid and subsisting
identification card.

WITNESS MY HAND AND SEAL.