Judicial Affidavit Antonio Luna

REPUBLIC OF THE PHILIPPINES
REGION IV-A
METROPOLITAN TRIAL COURT
Branch No. 143, Cabuyao City
UNITED GOAL CORPORATION
represented by Antonio Luna
Plaintiff,
-versus-
CIVIL CASE NO. Q-14344
ARIEL GO, JOSE SANCHEZ, and

DANIEL FLORES,
Defendants,
x----------------------------------------------x
PRELIMINARY STATEMENT
The person examining me is ATTY. JEMMANOEL B. MORA with
address at 12345 Rockwell Drive, Makati City. The examination is being
held at the same address. I am answering his questions fully conscious that I
do so under oath and may face criminal liability for false testimony and
perjury.
OFFER OF TESTIMONY
1.
2.
3.
4.
5.
6.
7.
8.
We are offering the testimony of the witness in order to prove that:

He represents the Plaintiff in the above-entitled case in his capacity as
President of UNITED GOAL CORPORATION;
The Plaintiff acquired the Property covered by Transfer Certificate of
Title No. T-175865 on January 1, 2010, and has been in actual
physical possession thereof since then;
The Plaintiff has been paying the real property taxes due thereon since
the year 2011;
The Property was a vacant lot as of May 1, 2016;
The Plaintiff built a wooden fence around the Property;
The Plaintiff employed Mr. Jonathan Strange as a security guard;
Mr. Strange was guarding the Property on that date; and
Mr. Strange vacated the Property on May 1, 2016.
JUDICIAL AFFIDAVIT PROPER

I, ANTONIO LUNA, of legal age, Filipino citizen, with postal
address at 67890 Rockwell Drive, Makati City after having duly sworn to in
accordance with law do hereby depose and say:
ATTY. MORA: With the kind permission of the Honorable Court.
Q1: Mr. Witness, do you know the Plaintiff in this case?
A1: Yes, sir.
Q2: How do you know the Plaintiff?
A2: I am the incumbent President of the Plaintiff.
Q3: Now, I am showing to you a document purporting to be a Board
Resolution Appointing Officers adopted by the Board of Directors of
the plaintiff marked as EXHIBIT A. It is dated April 23, 2009. What
can you say about this document?
A3: It is the document appointing me as President of plaintiffs company.
Q4: How about the signatures appearing on the resolution, whose
signatures are these?
ATTY. MORA: Witness is examining the signatures appearing on the
resolution.
A4:
Those are the signatures of the Members of the Board of Directors

then.
Q5: What is your basis for saying that those are the signatures of the
Members of the Board?
A5: I was present during the meeting. I personally saw each Director sign
the resolution.
Q6:
A6:
Showing to you a document purporting to be Minutes of the Meeting

of the Board of Directors of the plaintiff marked as EXHIBIT B. It is
dated April 23, 2009. What can you about this document?
It is the written record of the April 23, 2009 Board of Directors
meeting. It states that I was present during the meeting.
Q7: Do you know the defendants in this case by the name of Messrs. Ariel
Go, Jose Sanchez, and Daniel Flores?
A7: Yes, Sir.
Q8: How do you know the defendants?
A8: I know them because Mr. Strange informed me that they were the
three armed men who took possession of the plaintiffs property.
Q9: When did that happen?

A9: On May 1, 2016.
Q10: Do you know the property which is the subject matter of this case?
A10: Yes, sir.
Q11: How do you know the property?
A11: The plaintiff acquired the property from Sps. Florenz Regalado and
Leonor Boado on January 1, 2010. I was already the President of the
plaintiff then.
Q12: Can you briefly describe the property?
A12: The property is a vacant lot with an area of 10,000 square meters. A
wooden fence surrounded it. It is registered in the name of the
plaintiff.
Q13: Showing to you a document purporting to be a Transfer Certificate of
Title marked as EXHIBIT C issued by the Register of Deeds of
Cabuyao City, Laguna. It is dated January 1, 2010. What can you say
about this document?
A13: That is the Transfer Certificate of Title issued in the name of the
plaintiff.
Q14: Who was in physical possession of the property prior to and on May
1, 2016?
A14: The plaintiff, sir.
Q15: Could you explain how a corporation such as the plaintiff could
physically possess the property?
A15: The property was in the possession of Mr. Strange, who was acting in
behalf of the plaintiff. The plaintiff employed Mr. Strange as a
security guard of the corporation. He has been guarding the property
from the time of its purchase up to the evening of May 1, 2016.
Q16: Showing to you a document purported to be an Employment Contract
executed between the plaintiff and Mr. Strange marked as EXHIBIT
D. It is dated December 15, 2009. What can you say about this
document?
A16: It is the employment contract I signed in behalf of the plaintiff. It
states the terms and conditions of Mr. Stranges employment with the
plaintiff. It further states that the plaintiff is the employer of Mr.
Strange.
Q17: So since the evening of May 1, 2016, Mr. Strange has stopped
guarding the Property?
A17: Yes, sir.
Q18: Why is that?

A18: Mr. Strange vacated the property.
ATTY. MORA: That will be all for the witness.
That I will keep the originals of the documents identified in this
affidavit. As such, I warrant that the copies of the documents attached to this
affidavit are faithful copies of the original documents.
That I will bring the original documents for comparison during the
preliminary conference with the attached copy, failing which the latter shall
not be admitted.
That this affidavit is being executed to attest to the truthfulness and
veracity of the foregoing facts which are based on my personal knowledge
and on authentic records.
IN WITNESS WHEREOF, I have hereunto affixed my signature this
14 day of June 2016, in Cabuyao City.
th
(sgd.)
ANTONIO LUNA
Plaintiff
SUBSCRIBED AND SWORN to before me this 14th of June, 2016,
in Cabuyao City, affiant exhibited to me SSS No. 01-2345678-9, issued on
January 25, 2014, at Cabuyao City, Laguna.
(Sgd.)
EMILIO AGUINALDO
Notary Public for Cabuyao City, Laguna
Appointment No. 12345 until December 31, 2016
4/F Heroes Building, Revolutionary Road
Cabuyao City, Laguna, 4025
Attorneys Roll No. 333444
IBP No. 333444 Lifetime Member; Laguna Chapter
PTR No. 333444; January 15, 2016; Cabuyao City, Laguna
Doc. No. 402;
Page No. 108;
Book No. 03;
Series of 2016
ATTESTATION
I, ATTY. JEMMANOEL B. MORA, of legal age, Filipino citizen,
after having duly sworn to in accordance with law do hereby depose and say
that:
1. I am the counsel of record for the plaintiff in the above-entitled
case;
2. I personally conducted the foregoing judicial affidavit of plaintiffs
representative, Antonio Luna;
3. I hereby certify that I faithfully recorded the questions I asked and
the answer of the witness;
4. I likewise certify that neither I nor any person then present had
coached the witness regarding the latters answer.
IN WITNESS WHEREOF, I have hereunto affixed my signature this
14 day of June 2016, in Cabuyao City.
th
ATTY. JEMMANOEL B. MORA

Counsel for Plaintiff
SUBSCRIBED AND SWORN to before me this June 14, 2016, in
Cabuyao City, affiant exhibited to me SSS No. 01-2345678-9, issued on
January 25, 2014, at Cabuyao City, Laguna.
(Sgd.)
EMILIO AGUINALDO
Notary Public for Cabuyao City, Laguna
Appointment No. 12345 until December 31, 2016
4/F Heroes Building, Revolutionary Road
Cabuyao City, Laguna, 4025
Attorneys Roll No. 333444
IBP No. 333444 Lifetime Member; Laguna Chapter
PTR No. 333444; January 15, 2016; Cabuyao City, Laguna
Doc. No. 403;

Page No. 109;
Book No. 03;
Series of 2016

Judicial Affidavit Antonio Luna

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REPUBLIC OF THE PHILIPPINES

CIVIL CASE NO. Q-14344

ARIEL GO, JOSE SANCHEZ, and

We are offering the testimony of the witness in order to prove that:

JUDICIAL AFFIDAVIT PROPER

Those are the signatures of the Members of the Board of Directors

Showing to you a document purporting to be Minutes of the Meeting

Q9: When did that happen?

Q18: Why is that?

ATTY. JEMMANOEL B. MORA

Doc. No. 403;

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