EXHIBIT H

REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT OF BALATAN
5th Judicial Region
Branch_____
Camarines Sur

MELLON FINANCIAL
CORPORATION

Plaintiff,

- versus -

Civil Case No.: 123467;

For: Forcible Entry with

Prayer for
Preliminary
Injunction

MARIO M. CRUZ

Defendant.
x------------------------------------------------x

JUDICIAL AFFIDAVIT

Name of Witness : Oliver E. Rodrigo

Address
Supervising Lawyer
Office Address
Place of Examination
: 521 Street, Balatan,
Camarines Sur
: Atty. Erika R. Alidio
: 3/F JR BuildinCamangahan,
Balatan, Camarines Sur
: 3/F JR BuildinCamangahan,
Balatan, Camarines Sur

I, OLIVER R. RODRIGO, after having been duly sworn to

in accordance with law, hereby respectfully states that I am
answering the following questions asked of me, fully conscious
that I do so under oath, and that I may face criminal liability
for false testimony or perjury, thus:
Q1: Please raise your right hand. Do you swear to tell the truth,
the whole truth, and nothing but the truth, so help you God?
A1: I do.

Q2: Please state your full name and other personal

circumstances.
A2: My name is Oliver E. Rodrigo, of legal age, single, Filipino
citizen, and a resident of 521 Street, Balatan, Camarines Sur.
I am currently employed as Area Operations Manager of Briggs
& Stratton Corp., with a principal address at 245 St. Brgy.,
Peñafrancia, Naga City;

Q3: Mr. Rodrigo, Can you tell me your reason for testifying in
the court in favor of the plaintiff?
A3: I am here to testify that there was indeed a sale of the
subject property and that ownership was transferred to the
MELLON FINANCIAL CORPORATION (‘Mellon’ for brevity)

Q4: You are handing me a deed of absolute sale between the

Plaintiff and Briggs & Stratton Corp. Do you have personal
knowledge about this sale?
A4: Yes, I do. I personally have the knowledge of the sale
between Briggs & Stratton Corp. and Mellon of the property
located at Brgy. Duran, Balatan, Camarines Sur.

Q5: I am marking this document as Exhibit C. Do you confirm

my action?
A5: Yes, I do.

Q6: Can you tell us how the sale happened?

A6: On November 13, 2021, I received from our main office an
order to make an offer to sell the subject property to Mellon.
The subject property used to be a prospect lot for our factory
in southern Luzon. However, due to changes in the company
management, the company decided to move the location of the
factory to a location near Metro Manila and decided to sell the
subject property.

Q7: And then what happened?

A7: I personally met with the operations manager of Mellon,
Ms. Ariana Grande last November 22, 2021, to talk about the
terms and conditions of the sale of the subject property. On
that same day, Ms. Grande and I went to the subject property
to conduct an ocular inspection. We toured the vicinity and we
saw that the area was empty and nothing was being built or
was built except for the woven wire fences surrounding the
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subject property. Ms. Grande even took photos of the area to
attach to her report. Afterwards, we parted with each other
and I was assured by Ms. Grande that a call will be made once
the offer has been accepted by their higher management.

Q8: Did you receive a call from Ms. Grande?

A8: Yes, I did.

Q9: When did you receive the call?

A9: On December 3, 2021, I received a call from Ms. Grande.
She requested me to finalize the offer to sell and to prepare the
deed of absolute sale together with the photocopies of the
latest tax declaration and Transfer Certificate of Title of the
subject property. I was asked to send the scanned copy to her
email.

Q10: When was the execution of the sale?

A10: The sale of the subject property was executed on 20
January 2022. Their company lawyer was present during the
sale to represent Mellon and to sign the deed of absolute sale
for and on behalf of their company.

Q11: What happened after the execution of the sale?

A11: That same day, 20 January 2022, the deed of absolute
sale was notarized by Atty. Howard B. Tuanqui, IBP Life
Member Roll No. 053356, PTR No. 123775/01-02-21, Roll No.
78142, MCLE Certificate of Compliance No.0009455/06-10-
18. A tour of the location was also conducted, there were no
improvements being made on the subject property;

Q12: Are you willing to narrate other relevant matters in court

should it become necessary?
Q12: Yes, Atty.

AFFIANT FURTHER SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto set my

signature this 13th day of APRIL, 2022 in Balatan, Camarines
Sur, Philippines.

OLIVER E. RODRIGO
Judicial Affiant

SUBSCRIBED AND SWORN TO, before me this 13 th day

of April 2022 in Balatan, Camarines Sur, Philippines by the
affiant, who exhibited to me his, Philippine Passport as
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competent evidence of identity, pursuant to the 2004 New
Rules on Notarial Practice, as amended.

Doc. No.  ______; ATTY. ERIKA R. ALIDIO

Page No. ______; NOTARY PUBLIC
Book No. ______; MCLE Compliance No. VI-0010196/06-10-18
Series of 2022. IBP Life Member Roll No. 092923

PTR No. 16545/01-02-20

Roll No. 89223
attyrikaret@gmail.com

ATTESTATION

I, ERIKA R. ALIDIO, a member of the Integrated Bar of

the Philippines, who conducted the examination of OLIVER E.
RODRIGO, hereby respectfully attest that I faithfully recorded
the questions I asked and the corresponding answers that the
witness gave, and that neither me nor any other person then
present or assisting me coached the witness regarding his
answers.

OLIVER E. RODRIGO

SUBSCRIBED AND SWORN TO, before me this 13 th day

of April, 2022 at Balatan, Camarines Sur, Philippines by the
affiant, who exhibited to me his Philippines Passport, as
competent evidence of identity, pursuant to the 2004 New
Rules on Notarial Practice, as amended.

Doc. No.  ______; ATTY. ERIKA R. ALIDIO

Page No. ______; NOTARY PUBLIC
Book No. ______; MCLE Compliance No. VI-0010196/06-10-18
Series of 2022. IBP Life Member Roll No. 092923

PTR No. 16545/01-02-20

Roll No. 89223
attyrikaret@gmail.com