Presentation of Witness

1. May I call to the witness stand our first witness Your honor?

Kindly take the witness stand Mr./Ms. Witness… Then I-swear na ng court…

2. May I proceed with the direct examination Your Honor?

3. With the kind permission of the Honorable Court, I am presenting Lavioleta V.

Antrajenda as the first witness, the testimony of the witness is offered to prove the
allegations in the complaint, that plaintiffs are the lawful owners of the land, including
the portion usurped and to prove that plaintiffs have a better right of possession over
subject land and that to identify her Judicial Affidavit.

4. May I proceed your honor?

5. Madam Witness, kindly state your name, age, civil status, occupation if any, and your
address.

6. Madam Witness, do you remember executing a Judicial Affidavit in relation to this case?
YES

7. If it will be shown to you, would you be able to identify it? Yes

8. May I approach the witness Your Honor?

9. Ms. Witness, I am showing you a Judicial Affidavit, kindly look at said document. Is this
the Judicial Affidavit you are referring to?

10. And in this document, there is a signature above the name Lavioleta V. Antrajenda,
whose signature is this?

11. On the same page of this JA is the signature of one Atty. Odessa Reyes, do you know
her?

a. Yes, she was my former counsel in this case from PAO.

12. Why?

13. She helped me execute this Judicial Affidavit

14. Madam Witness do you affirm and confirm the truthfulness and veracity of the
statements in your judicial affidavit as well as the authenticity of the documents
attached thereto?

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 15. Your honor, the witness identified the JA and we move that this be marked as Exhibit K,
and we prayed that the signature of Lavioleta V. Antrajenda be marked as Exhibit K-1
and the signature of Atty. Odessa Reyes as Exhibit K-2 for the Plaintiff.

16. Your honor we move that this JA serve as the witness’ direct testimony.

17. Ms. Witness, I have here a Special Power of Attorney. Can you identify this as the Special
Power of Attorney authorizing you to file this case?

a. May I respectfully manifest your honor that the Special Power of Attorney
attached to the Judicial Affidavit be compared with the original which I have with
me?
b. May I manifest your honor that the copy of SPA be marked permanently as
Exhibit A.
18. Ms. Witness, I also have here a copy of the certificate of death of Sancho P. Villones with
registry No. 2001-068. Can you identify that this certificate of death is that of the late
Sancho P. Villones?

a. May I manifest Your Honor that the copy of the certificate of death be compared
with the original, and may I manifest your honor that the same be marked as
Exhibit B.

19. Ms. Witness, I have here an Original Certificate of Title No. M-2980, patent No. 004166
and Tax Declaration. Can you confirm the authenticity of these documents?

a. May I manifest Your Honor that the copies of OCT, Patent and Tax declaration be
duly compared with the original documents, and that these documents be
marked as Exhibits C, D, and E respectively.

20. Ms. Witness, I have here receipts of real property tax payment. Can you confirm that
authenticity of these receipts?

a. May I manifest your honor that the copies of the receipts of real property taxes
payments be duly compared with the original documents, and that these be
marked as Exhibits F and F-1.

21. Ms. Witness, I have here a survey plan of the subject land. Can you confirm the
authenticity of this document?
a. May I manifest Your Honor that the copy of the survey plan be duly compared
with the original document, and that this be permanently marked as Exhibit G.

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 22. Ms. Witness, I have here photographs of the fence erected by the defendant? Can you
identify the authenticity of these photographs? May I manifest your honor that these
photographs be marked as Exhibit H to H-3.

23. Ms. Witness, I have here a copy of a certificate to file action which you secured from the
Lupon Tagapamayapa when no compromise agreement between you and defendant
had been entered into. Can you confirm the authenticity of this certificate?

a. May I manifest Your Honor that the copy of the certificate to file action be duly
compared with the original document?

24. Ms. Witness, I have here a demand letter, return card, registry receipt? Can you confirm
the this is the demand letter that you sent the defendant?
a. May I manifest your honor that the demand letter, return card and registry
receipt be marked as Exhibits J, J-2, and J-3 which have been previously marked
as part of the record of the case.
b. May I also manifest your honor that the signature of the defendant in the return
card be submarked as Exhibit J-2.

*No questions for the witness Your Honor. Thank you.

May I call to the witness stand my second witness Your Honor?

25. With the kind permission of the Honorable Court, I am presenting Michelle Villones
Rosales as the second witness, the testimony of the witness is offered to prove the
allegations in the complaint, that plaintiffs are the lawful owners of the land, including
the portion usurped and to prove that plaintiffs have a better right of possession over
the land and to identify her Judicial Affidavit.

26. Madam Witness, do you remember executing a Judicial Affidavit in relation to this case?

Answer. YES

27. If it will be shown to you, would you be able to identify it? Answer: Yes

28. Ms. Witness, I am showing you a Judicial Affidavit, kindly look at said document. Is this
the Judicial Affidavit you are referring to? Answer: Yes
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 29. And in this document, there is a signature above the name Michelle L. Villones-Rosales,
whose signature is this? Answer: My Signature.

30. On the same page of this JA is the signature of one Atty. Odessa Reyes, do you know
her?

a. Yes, she was our former counsel in this case.

31. Why?

Answer: She helped me execute this Judicial Affidavit

32. Madam Witness do you affirm and confirm the truthfulness and veracity of the
statements in your judicial affidavit as well as the authenticity of the documents
attached thereto? Answer: YES

33. Your honor, the witness identified the JA and we move that this be marked as Exhibit L,
and we move that the signature of Michelle L. Villones-Rosales be marked as Exhibit L-1
and the signature of Atty. Odessa Reyes as Exhibit L-2 for the Plaintiff.

34. Your honor we move that this JA serve as the witness’ direct testimony

35. No more questions to the witness your honor.

After the presentation and marking – ORAL OFFER of Evidence

36. I have no more witness and evidence to present Your Honor, and I am now ready to
orally offer my evidence Your Honor.

ORAL OFFER OF EVIDENCE

37. Exhibit A is offered as evidence to prove that the Plaintiff has special power attorney to
file the instant case and
38. Exhibit B is offered to ……