Judicial Affidavit

Republic of the Philippines
REGIONAL TRIAL COURT

National Capital Judicial Region
City of Muntinlupa
Branch 45
PEOPLE OF THE PHILIPPINES,
Plaintiff,
-versus- Criminal Case No. 12345
For: Estafa Art. 315 (1) (b)
JOHN TRAVOLTA SMITH
Accused,
x------------------------------------------x
JUDICIAL AFFIDAVIT
I, PEDRO ONG, 35 years old, employed as Operations Manager in ABC Corporation, single,
residing at Lot 1 Block 1, Sampaguita St. Muntinlupa City, am testifying as one of the witnesses for
the prosecution in the above entitled case, after having been duly sworn in accordance with law,
hereby depose and state:
PRELIMINARY STATEMENT
That the person examining me is ATTY. JUAN LANGCASO, with law office address at Lot 2,
Block 2, Mango St. Muntinlupa City. My Judicial Affidavit is being taken at the above-mentioned
place in the presence of KENNETH ANG.
That the questions are asked in English Language but are translated in the Tagalog Dialect
which I speak and fully understand and I am giving my answers fully conscious that I do so under
oath and I am aware that I may face criminal liability for false testimony or perjury for false
statements made or given by me.
OFFER OF TESTIMONY
The testimony of the witness PEDRO ONG is being offered to prove the following:
1. That he knows the accused personally;

2. That he has personal knowledge of the accused in the act of receiving and acknowledging
the demand letter;
3. That he has personal knowledge of the demeanor of the accused after receiving and
acknowledging the demand letter;
4. That the witness will identify the accused in open court as the one who received the demand
letter.
JUDICIAL AFFIDAVIT PROPER
1. Q: Mr. Witness, will you please tell the Honourable Court your name, age and other personal
circumstances?
A: I am Pedro Ong, 35 years old, an Operations Manager at ABC Corporation and a resident
of Lot 1, Block 1, Sampaguita St. Muntinlupa City.
2. Q: How do you know the accused?

A: I know the accused because he is my boss. He is the General Manager of ABC Corporation.
3. Q: For how long have you been working at ABC Corporation?

A: For 3 years.
4. Q: For how many years have you had the accused as your boss?
A: For 2 months.
5. Q: Mr. Witness, can you please state what happened in the hours of 10:00AM-12:00PM at
Feb. 6, 2019?
A: I was asked by the accused to check if there is a mail downstairs.
6. Q: What did you do?

A: I went down and checked if there is a mail.
7. Q: What did you find out?

A: There are several mails addressed to ABC Corporation and one mail addressed to my boss,
the accused.
8. Q: How sure are you that the mail is addressed to the accused?
A: Because I double checked it as it is a protocol taught by my boss, the accused.
9. Q: Do you know what is the content of the mail addressed to the accused?
A: Upon receiving the mail, I don’t know what it is. All I know at that time was it was
addressed to the accused.
10. Q: What did you do upon receiving the mail?
A: I gave the mails I received to the accused and notably told that there is one mail
addressed to you sir.
11. Q: What did the accused do after you said that?

A: My boss opened it instantly.
12. Q: What happened after that?

A: My boss shouted saying “Putangina talaga nitong mga to. Ayaw talaga ako tantanan
nitong mga to ah”.
13. Q: How do you remember this clearly?

A: Because I was in front of my boss when he shouted and I was surprised and got scared by
his tone of voice.
14. Q: What did you do after that?

A: I reviewed the document.
15. Q: Why did you do that?

A: Because my boss said to me “Oh basahin mo yan. Baka gawin rin sayo yan ng kumpanyang
ito”
16. Q: What did you do after that?

A: I read the document.
17. Q: What is the document all about?

A: It is a demand letter from a company demanding the return of the Company Properties
that my boss has possession.
18. Q: How can you remember it?

A: Because my boss shouted while I was reading “Basahin mo maigi yan. Ganyan na ganyan
rin kalagayan mo. Dapat alam mo Karapatan mo pag mga ganyang situasyon. Mga
putanginang mga gahaman yang mga yan.” And after hearing him shouting, I empathize
myself in my boss’ shoes as he told.
Manifestation: Your Honour, presenting this document to this honourable court, a document for the
witness to identify.
19. Q. Mr. Witness, presenting to you this document, dated Feb 6, 2019, can you please state
what is the relation of this document to the one you are referring to?
A: It is the same demand letter sir.
20. Q: How sure are you?

A: Because I still remember the one who sent it and the one whom the letter is addressed to.
21. Q: And who sent it and to whom is it addressed?

A: It was sent by CAPIZ LAW FIRM, legal counsel of DEF Corporation, the latter being the
Parent Company of ABC Corporation. And it was addressed to my boss, the accused sir.
22. Q: How sure are you that CAPIZ LAW FIRM is the legal counsel of DEF Corporation?
A: Because it was stated in the letter sir.
23. Q: How sure are you that DEF Corporation is the Parent Company of ABC Corporation?
A: Because it was stated in the letter sir.
24. Q: Lastly Mr. Witness, can you identify your boss here inside this court?
A: Yes sir. He is the accused sitting in front of me.
Manifestation: Your Honour, I would like to emphasis in the stenographic notes that the witness is
pointing to the accused as his boss and that I hereby introduce for marking purposes that the
document attached in this Judicial Affidavit referred to by the witness be marked as Exhibit A.
Nothing further, your honour.
IN WITNESS WHEREOF, I have hereunto set my hand this 17 th day of April 2019 at
Muntinlupa City, Philippines.
PEDRO ONG
JURAT
REPUBLIC OF THE PHILIPPINES)
PROVINCE OF RIZAL)
CITY/MUNICIPALITY OF MUNTINLUPA) S.S
SUBSCRIBED AND SWORN to before me, in the municipality/city of Muntinlupa this 16th day
of April 2019, the affiant PEDRO ONG, personally appeared before me, with residence at Lot 1 Block
1, Sampaguita St. Muntinlupa City, and B.I.R Tax Account No. 1234567, known to me to be the same
person who executed the foregoing instrument, and he acknowledged to me that the same is his
free act and deed.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed my notarial seal, the day,
year, and place above written.
NOTARY PUBLIC
My Commission expires Dec. 31, 2021
IBP No. 1234567, 1/2/2019, Muntinlupa City
P.T.R. No. 567890, 1/2/2019, Muntinlupa City
Doc. No _______;
Page No_______;
Book No_______;
Series of 20____
ATTESTATION
The undersigned, ATTY. JUAN LANGKASO, of legal age, with office address at Lot 2, Block 2,
Mango St. Muntinlupa City, do hereby certify that:
I propounded questions to PEDRO ONG and faithfully recorded, or caused to be recorded,

the questions I have asked and the corresponding answers that PEDRO ONG gave, as above stated.
Neither I nor any other person then present or assisting the witness coached the latter
regarding his answers.
I conducted the examination of the witness at my law office located at Lot 2, Block 2, Mango
St. Muntinlupa City.
IN WITNESS WHEREOF, I have hereunto set my hand this 17 th day of April 2019 at
Muntinlupa City, Philippines.
ATTY. JUAN LANGKASO
Affiant
SUBSCRIBED and sworn to before me in Muntinlupa City on April 16, 2019, affiant showing
his competent proof of identity, to wit: SSS Member, IBP No, Roll No.
NOTARY PUBLIC
My Commission expires Dec. 31, 2021
IBP No. 1234567, 1/2/2019, Muntinlupa City
P.T.R. No. 567890, 1/2/2019, Muntinlupa City
Doc. No _______;
Page No_______;
Book No_______;
Series of 20____
EXHIBITS ATTACHED TO THE JUDICIAL AFFIDAVIT
EXHBIT A - DEMAND LETTER

Judicial Affidavit

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Republic of the Philippines

REGIONAL TRIAL COURT

PEOPLE OF THE PHILIPPINES,

-versus- Criminal Case No. 12345

For: Estafa Art. 315 (1) (b)

JOHN TRAVOLTA SMITH

1. That he knows the accused personally;

JUDICIAL AFFIDAVIT PROPER

2. Q: How do you know the accused?

3. Q: For how long have you been working at ABC Corporation?

6. Q: What did you do?

7. Q: What did you find out?

11. Q: What did the accused do after you said that?

12. Q: What happened after that?

13. Q: How do you remember this clearly?

14. Q: What did you do after that?

15. Q: Why did you do that?

16. Q: What did you do after that?

17. Q: What is the document all about?

18. Q: How can you remember it?

20. Q: How sure are you?

21. Q: And who sent it and to whom is it addressed?

REPUBLIC OF THE PHILIPPINES)

CITY/MUNICIPALITY OF MUNTINLUPA) S.S

My Commission expires Dec. 31, 2021

IBP No. 1234567, 1/2/2019, Muntinlupa City

P.T.R. No. 567890, 1/2/2019, Muntinlupa City

I propounded questions to PEDRO ONG and faithfully recorded, or caused to be recorded,

ATTY. JUAN LANGKASO

My Commission expires Dec. 31, 2021

IBP No. 1234567, 1/2/2019, Muntinlupa City

P.T.R. No. 567890, 1/2/2019, Muntinlupa City

EXHIBITS ATTACHED TO THE JUDICIAL AFFIDAVIT

EXHBIT A - DEMAND LETTER

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