Republic of the Philippines

Fourth Judicial Region

MUNICIPAL TRIAL COURT IN CITIES
Bacoor, Cavite

CALSONS GLOBALINK INC.,

Plaintiff,

Civil Case No. BCCV 19-325

-versus- For: Recovery of Possession
and Damages

RIZA HUANG and/or any other

persons claiming rights under
her,
Defendant.
x-----------------------------------------x

Republic of the Philippines )

City of Bacoor, Cavite ) S.S.

JUDICIAL AFFIDAVIT OF
RIZA HUANG

Witness Ms. Riza Huang is a Filipino, of legal age, with

residential address at ______________.

Atty. Dorothy Dale D. Orial conducted the examination of the

Plaintiff in Bacoor City.

Witness answered the following questions, fully conscious that

she does so under oath and that she may face criminal liability for
False Testimony or Perjury.

OFFER OF TESTIMONY

The testimony of Ms. Huang is being offered to prove the

following:
a) That she is a current resident of Malipay Phase 3, Molino
IV;
b) That she built their family home in good faith;
c) That she is willing to enter into an amicable settlement
with the Plaintiff;
d) That she is willing to vacate the premises after the Plaintiff
pays proper indemnity for the necessary and useful
expenses;
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 e) That she is not liable for any form of damages.

TESTIMONY

1. Q: Why are you here today?

A: I am one of the defendants in the case filed by Calsons
Globalink.

2. Q: How did you know about this case?

A: Around August 31, 2019, I received a copy of the
Summons for the instant case.

3. Q: How do you know the Plaintiffs in this case?

A: Around end of 2017, I met a certain engineer of Calsons
Global seeking to buy portions of our properties. At that
time, we sold to them our store for Ninety Thousand
Pesos (PhP90,000.00). Sometime in June 2019, the
representative of Calsons Globalink approached us and
claimed that Calsons Globalink is the owner of the lot
where our properties are built.

4. Q: Who is the representative of Calsons Globalink that

approached you?
A: At first it was a different engineer. Then sometime last
year in early 2019, it was Engineer Patrick Stephen C.
Marasigan who met with us.

5. Q: What happened next, if any, after Engineer Marasigan

approached you?
A: He asked us how much we will be asking as indemnity for
our properties in exchange for vacating the premises. We
told him that we will settle for Two Million Five Hundred
Thousand Pesos (PhP2,500,00.00). Afterwards, he told
us that he will relay the message to his superiors.

6. Q: You mentioned that they offered for you to vacate your

property. What property is this?
A: The property we are occupying in Malipay 3 covers a Two
Thousand square meter lot (2,000sqm) where we built our
duplex house, underground office, a store, gate, the
roads, and necessary rights of way.

7. Q: What happened next, if any?

A: Later on, Engineer Marasigan did not get back with us.

8. Q: How did you learn about the property?

A: Sometime in 2001, my cousin Nora Montanes approached
me and told me that we can operate a junkshop beside
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 the dumpsite near Malipay 3. And so, we built a small
junkshop.

9. Q: What happened next, if any?

A: A certain Fedel Arcon approached me in the junkshop
offering the sale of lots nearby, located in Malipay 3. Fidel
Arcon later on introduced to us a certain Amy Bahian, who
was then the President of the Samahan ng Mga
Magsasaka & Settlers Association Inc.

10. Q: What is your relationship with Amy Bahian?

A: Amy Bahian is the person who offered to sell us the lots in
Malipay 3.

11. Q: What happened during the sale of the lots in Malipay 3?

A: Amy Bahian sold to us several lots which we bought from
her in a span of several years.

12. Q: What proof do you have, if any, of such sale of lots?

A: I have with me the original documents entitled Certificate
of Lot Right Transfer.

13. Q: If shown to you, will you be able to identify the said

Certificate of Lot Right Transfer?
A: Yes.

14. Q: I am showing to you five documents, all entitled Certificate

of Lot Right Transfer. Are these the documents you were
referring to?
A: Yes.

(The documents entitled as Certificate of Lot Right Transfer are

requested to be marked as follows:
Exhibit “A” – Certificate of Lot Right Transfer dated 30 April
2001;
Exhibit “B” – Certificate of Lot Right Transfer dated 30 March
2001;
Exhibit “C” – Certificate of Lot Right Transfer dated 03 July
2001;
Exhibit “D” – Certificate of Lot Right Transfer dated 24 June
2006;
Exhibit “E” – Certificate of Lot Right Transfer dated 04 April
2006.)

15. Q: What did you do next, if any, after you were offered to buy
the rights to the lot?

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 A: We paid for it and, after about two (2) years, we built
roads and structures made of concrete. The construction
lasted for two (2) years. The other houses we built on our
property, we leased to others who eventually resided
therein.

16. Q: Since when have you been residing in the property?

A: We have been here in Malipay 3 for about twenty (20)
years already.

17. Q: What is your basis in saying that you have been residing
in Malipay 3 for about twenty (20) years?
A: I have six children, the eldest being eighteen (18) years
old and the youngest being seven (7) years old. All of
them were born here.

18. Q: If you can recall, how much did you spend for the
construction of your property?
A: Roughly Four Million pesos (Php4,000,000.00) in total.

19. Q: If you know, how much of the subject lot does the
structured property occupy?
A: The lot area of our house and office occupies roughly 200
square meters in total of the subject lot.

20. Q: Do you have proof showing the size of your property?

A: I have pictures, Ma’am.

(At this juncture, the witness presents printed photos of

their office and house, which is requested to be marked
as Exhibit “F”, for the defendant.)

21. Q: If you know, what is the floor area of your house?

A: Given that our house has 2 stories, it’s floor area is
around 140 square meters.

22. Q: Do you have proof showing the size of your house?

A: I have pictures, Ma’am.

(At this juncture, the witness presents printed photos of

their house, which is requested to be marked as Exhibit
“G”, for the defendant.)

23. Q: Can you describe to us the first floor of your house?

A: When you enter the main door, there are built-in cabinets
and the stairs leading to the second floor.

24. Q: Can you describe to us the second floor of your house?

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 A: When you go up the stairs, there are four rooms in total,
two of which have comfort rooms. The balcony which
stretches out to the entire side of the house is the one
connecting the duplex together.

25. Q: Can you describe to us the area where there is a

balcony?
A: The balcony area is tiled and the railings are made of
steel. The doors leading to the balcony are big sliding
doors.

26. Q: What proof do you have that the balcony is made of steel
and that the floor is tiled?
A: I have photos of the balcony area.

(At this juncture, the witness presents printed photos of

their house, which is requested to be marked as Exhibit
“H”, for the defendant.)

27. Q: What were the materials used to construct your house?

A: Our house is made of hard and solid materials such as
concrete and steel. The roof uses insulated steel panels.
The floors are made of concrete and topped up with tiles.

28. Q: You mentioned earlier that the Plaintiff, through its

representative Engineer Marasigan, approached you and
offered to indemnify you in exchange for vacating the
property. What did you do next, if any, after the initial offer
of Calsons Globalink?
A: When we presented to Engineer Marasignan that we will
settle for PhP2,500,000.00, he told us that he will relay it
to his superiors. However, after a month, he met with us
with Amy Bahian and told us that their counter-offer is
only Four Hundred Thousand Pesos (PhP400,000.00).

29. Q: What was your reaction to the counter-offer?

A: We were surprised and felt aggrieved that our concrete
house, office, and the roads we built on the property are
just valued at PhP400,000.00.

30. Q: What did you do next, if any, after you learned about the
new offer in the amount of Php400,000.00?
A: We declined the offer since we know and believe that our
property is of more value than what they are willing to
indemnify us for.

31. Q: What happened next, if any?

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 A: Sometime in June 18, 2019, representatives of Calsons
Globalink, together with security guards entered the
premises of the subject lot for their clearing operations.

32. Q: Where were you on June 18, 2019?

A: I left the house for work at 7:15am and got home in the
evening at around 10:00pm.

33. Q: How did you know about the clearing operations on the
day of June 18, 2019?
A: It was only when I got home in the evening that our
children who were then coming from school, told me that
there was a clearing operations in Malipay 3 that day. Our
children found out about the clearing operations from the
Facebook Group of Malipay 3. I confirmed it to my
husband, who was then the only person staying at home
that day. He told me that he knew of it only through the
local news television, as he did not leave the house
despite hearing noises.

34. Q: What happened after that, if any?

A: As our family was not involved in the commotion that we
saw in the news and on Facebook, we did not bother to
ask our neighbors about it.

35. Q: Why did you not bother to ask your neighbors?

A: Given my busy schedule at work, and considering that our
children are all minors of young age, we kept to ourselves
and refused to join the commotions.

36. Q: What happened next, if any?

A: After a month, we were surprised to receive Summons on
the instant case alleging that we were part of the
commotions during the clearing operations.

37. Q: What did you do thereafter, if any?

A: We immediately sought the assistance of a lawyer to
vindicate our rights.

38. Q: How do you wish to go about this instant case?

A: My family and I just want peace. We are willing to vacate
the property so long as we are given proper indemnity for
the structures we built in the last twenty (20) years.

FURTHER AFFIANT SAYETH NAUGHT.

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 IN WITNESS WHEREOF, I hereby affix my signature this 03
day of November 2020 in Bacoor, Cavite.

RIZA HUANG
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME this 03

November 2020 affiant exhibiting to me her _________ expiring on
_________.

NOTARY PUBLIC
Doc No.: ______;
Book No.:______;
Page No.:______;
Series of 2020.

CERTIFICATION

I hereby certify under oath that I conducted the examination of

the above-named witness and that I faithfully recorded or caused to
be recorded the questions I asked and the corresponding answers
that the witness gave; and that neither I nor any other person then
present or assisting me coached the witness regarding the latter’s
answers.

IN WITNESS WHEREOF, I have hereunto affixed my signature

this 03 November 2020 in Bacoor, Cavite.

DOROTHY DALE D. ORIAL

SUBSCRIBED AND SWORN TO BEFORE ME this 03

November 2020, affiant exhibiting to me her _________ expiring on
_________.

NOTARY PUBLIC

Doc No.: ______;

Page No.:______;

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Book No.:______;
Series of 2020.