REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

4th Judicial Region
Branch 812
Bulwagan ng Katarungan
Pallocan West, Batangas City

JUAN DE LA CRUZ
Plaintiff,

-versus- Civil Case No. _______________

For: Collection of sum of money
with damages
PEDRO SANTOS
Defendant,

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JUDICIAL AFFIDAVIT OF
JUAN DE LA CRUZ
I, Juan de la Cruz, Filipino, of legal age, married, and a resident of
C. Tirona St., Batangas City, and with business located at C. Tirona St.,
Batangas City, hereby depose and state under oath as follows:

The examination for purposes of preparing my Judicial Affidavit

which is in English, a language known to the me, was conducted or
supervised by ATTY. RON JOSHUA MANIMTIM at his law office
with address at 4th floor Solis Building, Sampalucan, Alangilan,
Batangas City.

PURPOSE: The testimony of the witness-complainant is being offered to

prove the allegations contained in the complaint and, ultimately, to prove
the circumstances leading to the fact of unlawful failure to pay the
amount dues by defendant PEDRO SANTOS after repeated demands by
Plaintiff.

Q1: Please state your full name and other personal circumstances.
A1: I am Juan de la Cruz, Filipino, of legal age, married, a resident
of C. Tirona St., Batangas City, and a sole proprietor doing business
under the name Juan Poultry Supply, located at C. Tirona St.,
Batangas City.
Q2: Are you fully conscious and aware that you are under oath as you are
answering all questions being asked of you now and hereafter in
these proceedings, and that you may face criminal liability for false
testimony or perjury should you make deliberately give false
information or testimony?
A2: Yes, sir.

Q3: You said that you are a sole proprietor under the name Juan Poultry
Supply. What do you do as a sole proprietor ?
A3: I sell poultry feeds and supplies, either on cash or credit. Aside from
that, sir, I am also the Plaintiff in the Complaint. Attached to the
Complaint are the Verification and Certificate of Non-Forum
shopping of the subject Complaint.

Q4: Mr. Witness, I am showing you a copy of a Complaint which will be

submitted before the Honorable Court. Can you tell its relationship
with the complaint you are speaking of, if any?
A4: Yes, sir. It is the same complaint I am speaking of.

Q5: On the Verification and Certificate of Non-Forum Shopping bearing

the name Juan de la Cruz, a signature is affixed above the said name.
Can you tell whose signature it is?
Q5: Yes, Sir. It is mine.

Manifestation: Your Honor, the Complaint, the Verification and

Certificate of Non-Forum Shopping, and the signature of Juan de la
Cruz which were identified by the witness are requested to be
marked as Exhibits “A,” “A-1,” and “A-1-a.”

Q6: How did you come to know of defendant, Pedro Santos?

A6: He is one of my customers, sir.

Q7: When you say customer, what do you mean by that?

A7: On different occasions, Mr. Santos purchased poultry feeds and
supplies on credit from me.

Q8: Do you have any proof that he is your customer, if any?

A8: Yes, sir. I have on my record the sales invoices evidencing the
purchases on credit by defendant Santos. The sales invoices in my
possession are the following, to wit:

1. Sales Invoice No. 12301

2. Sales Invoice No. 12311
3. Sales Invoice No. 12315
4. Sales Invoice No. 12325
5. Sales Invoice No. 12335
6. Sales Invoice No. 12350

Q9: When did Mr. Santos purchase the poultry feeds and supplies
appearing on Sales Invoice No. 12301?
A9: He purchased them on October 2, 2020.

Q10: How much was the amount due on Sales Invoice No. 12301?
A10: The amount due is P50,000.00.

Q11: When did Mr. Santos purchase the poultry feeds and supplies
appearing on Sales Invoice No. 12311?
A11: He purchased them on November 6, 2020.

Q12: How much was the amount due on Sales Invoice No. 12311?
A12: The amount due is P100,000.00.

Q13: When did Mr. Santos purchase the poultry feeds and supplies
appearing on Sales Invoice No. 12315?
A13: He purchased them on December 5, 2020.

Q14: How much was the amount due on Sales Invoice No. 12315?
A14: The amount due is P100,000.00.

Q15: When did Mr. Santos purchase the poultry feeds and supplies
appearing on Sales Invoice No. 12325?
A15: He purchased them on January 5, 2021.

Q16: How much was the amount due on Sales Invoice No. 12325?
A16: The amount due is P150,000.00.

Q17: When did Mr. Santos purchase the poultry feeds and supplies
appearing on Sales Invoice No. 12335?
A17: He purchased them on February 9, 2021.

Q18: How much was the amount due on Sales Invoice No. 12335?
A18: The amount due is P50,000.00.

Q19: When did Mr. Santos purchase the poultry feeds and supplies
appearing on Sales Invoice No. 12350?
A19: He purchased them on March 3, 2021.

Q20: How much was the amount due on Sales Invoice No. 12350?
A20: The amount due is 80,000.00.

Q21: Did Mr. Santos pay the amounts due appearing on the sales
invoices, if any ?
A21: No, sir. He has not paid the amounts. The purchases on credit shall
be payable after 10 days yet no payments were made. The total
amount due is P530,000.00 inclusive of interest.
Q22: How did you know that Mr, Santos has not paid them?
A22: I knew that he has not paid them when I looked at the record of
transactions of my business. On the said records, it appeared that he
has not paid any of them after the lapse of 10 days from each
purchase.

Q23: Mr. Witness, I am showing documents denominated as Sales

Invoices and attached to the complaint as Annex “A,” “B,” “C,”
D,” “E,” and “F.” Can you tell their relationship with the Sales
Invoices you mentioned, if any?
A23: Yes, Sir. They are the same Sales Invoices.

Manifestation: Your Honor, the Sales Invoices which were identified by

the witness are requested to be marked as Exhibits “B.”

Q24: Upon learning that he has not paid his accounts due, what did you
do, if any?
A24: Sir, the defendant was informed of his account dues and
outstanding obligations. However, he did not heed to the demands
and failed to pay.

Q25: What happened next, if any?

A25: Sir, aside from the demands which were orally made, a formal
demand letter dated October 13, 2021 was sent to defendant. He
received them and was informed of its contents.

Q26: What proof do you have that he has received the demand letter, if
any?
A26: I have in my possession a copy of the demand letter and
accompanying Registry Return Receipt in connection with the
demand letter, sir.
Q27: Sir, I am showing a letter and a Registry Return Receipt attached
to the complaint as Annex “G.” Can you say their relationship with
the documents you mentioned, if any?
A27: Yes, Sir. They are the same documents I mentioned.

Manifestation: Your Honor, the letter and Registry Return Receipt

which were identified by the witness are requested to be marked as
Exhibits “C” and “D.”

Q28: After sending the letter, what did you do, if any?
A28: Within 10 days after receipt of the demand letter, my credit
collector repeatedly went to Mr. Santos’ residence yet he did not
fulfill his obligation.

Q29: What did you do after, if any?

A29: I was forced to seek assistance of counsel to vindicate my rights.

Q30: What else do you want to say, if any?

A30: None, sir.

IN WITNESS WHEREOF, I have hereunto set my hand this 5th day

of November 2021 in Batangas City.

JUAN DE LA CRUZ
Affiant
PRC No. 00281 December 21, 2010 Lucena

SUBSCRIBED AND SWORN TO before me, a notary public, this 5th

day of November, 2021, in the City of Batangas. Affiant came personally
and appeared with his valid identification card, known to me as the same
person who personally signed the foregoing instrument before me and
avowed under the penalty of law to the whole truth of the contents of said
instrument.

Doc. No. 11;

Page No. 4;
Book No. 1;
Series of 2021
Atty. Ron Joshua Manimtim
NOTARY PUBLIC
Commission No. 12234
Valid until December 31, 2021
 Roll of Attorney No. 36000
IBP No. 36000 May 25, 2021 Batangas City
PTR No. 36000 May 25, 2021 Batangas City
Sampalucan, Alangilan, Batangas City

SWORN ATTESTATION OF THE COUNSEL

 I, RON JOSHUA MANIMTIM, Filipino citizen, of legal age, single
and with office at 4th Floor Solis Building, Sampalucan, Alangilan,
Batangas City, after having been sworn to in accordance with law hereby
depose and say that:

1. I am the lawyer who conducted and supervised the examination of the

above-named witness;

2. I faithfully recorded the questions I asked and the corresponding

answers that the said witness gave;

3. Neither I nor any other person coached said witness regarding the
latter’s answers.

IN WITNESS WHEREOF, I have hereunto set my hand this

November 5, 2021 in Batangas City, Philippines.

ATTY. RON JOSHUA MANIMTIM

Affiant
IBP ID Roll No. 36000

SUBSCRIBED AND SWORN to before me, a notary public, this

5 day of November, 2021 in Batangas City. Affiant personally known to
th

me came and appeared with his valid identification card, known to me as

the same person who personally signed the foregoing instrument before
me and avowed under penalty of law to the whole truth of the contents of
the said instrument.

Doc. No. 12;

Page No. 4;
Book No. 1;
Series of 2021
ATTY. JEM R. MONTEJO
Notary Public
Commission No. 00234
Valid until December 31, 2021
Roll of Attorney No. 55555
IBP No. 55555 DEC. 6, 2021 Batangas City
PTR No. 55555 DEC. 6, 2021 Batangas City
Batangas City