Republic of the Philippines )

Province of Southern Leyte )

CITY OF MAASIN )
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JUDICIAL COMPLAINT AFFIDAVIT OF LUIS SANTOS MANZANO

Preliminary Matters:

LUIS SANTOS MANZANO is 29 years old, Filipino, single and a

resident of Brgy. Rizal, Macrohon, Southern Leyte. He is a businessman.

Atty. Juan dela Cruz, with office address at Bgy. Tunga-tunga,

Maasin City, Southern Leyte is the one conducting/supervising the
examination of the witness held at his law office in the above-given
address.

Affiant is answering the questions asked, fully conscious of being

under oath and aware of being under pain of criminal liability for false
testimony or perjury.

========================================================

1. Q: For the record, Mr. witness, may I know why are you in my
office today?
A: I am here, attorney, to request you to take my judicial
affidavit because I want to file a case for estafa against Angel B.
Locsin.

2. Q: Who is this Angel B. Locsin are you talking about?

A: Angel B. Locsin is a resident of Bgy. Sto. Rosario, Macrohon,
Southern Leyte.

3 Q: Why do you want to file a case for estafa against Angel

Locsin?
A: Because she did not return the jewelries she got from me.
She also did not give to me the purchase price of the said jewelries.

4. Q: What do you mean by that?

A: I am a businessman, attorney. About a year ago, Angel

came to my jewelry shop and asked if she could sell some of my
 jewelries for me. I agreed and right then and there, she got from
me five sets of jewelry in the total amount of P1,000,000.00.

6. Do you have evidence to prove your claim?

A: Yes. I have a copy of the Trust Receipt Agreement. I had

already given it to you.

5. Q: I am showing to you a document entitled Trust Receipt

Agreement, please tell what relation has this to the one you
mentioned earlier.

A: This is the one I was referring to earlier.

(The document identified by the witness is marked as Annex “A”

hereof.)

6. Q: What happened next, if any?

A: For several times, I had called and texted Angel Locsin about
her financial obligations to me. She would keep telling me that
she would just visit me in my shop. I kept waiting for her but
she never came.

7. Q: What did you do next, if any?

A: I went to your office last June 29, 2017 and requested you
to send a demand letter on my behalf.

8. Q: Do you have a copy of that demand letter?

A: Yes, I kept one for my file. Here it is, attorney.

9. Q: Would you be willing to attach this as an annex of your

judicial affidavit?
A: Yes.

(The document identified by the witness is marked as Annex “B”

hereof.)

10. Q: Do you know if Ms. Locsin had received the demand letter?
A: Yes, ma’am. I have a copy of the registry return card.

11. Q: Would you be willing to attach this as an annex in this case?

A: Yes, ma’am.
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 (The document identified by the witness is marked as Annex “C”
hereof.)

12. Q: Now, did Ms. Locsin visit you after she received the demand
letter?
A: She never did. My text messages, my calls and your demand
letter all fell on deaf ears that is why I am compelled to file this
legal action.

13. Do you have anything more to say?

A: No more, attorney.

14. Q: Do you affirm and confirm the veracity of your statements

herein?
A: Yes I do.

IN WITNESS WHEREOF, I have hereunto set my hands this 12th

day of August, 2017 at Maasin City, Southern Leyte, Philippines.

LUIS SANTOS MANZANO

Affiant
TIN 123-456-789
Issued on January 8, 2010

JURAT

ATTESTATION

I, Atty. Juan dela Cruz with the above-mentioned Law Office address,
hereby depose and state, that:

1. I was the one who conducted/supervised the examination of the

witness;
2. I have faithfully recorded or caused to be recorded the questions I
asked and the corresponding answers that witness gave;
3. No one has coached the witness in giving his answers; and
4. I attest to the truth of the foregoing and for whatever legal purpose
it may serve, under the pain of legal consequences and disciplinary
action including disbarment.

Done in the day and place abovementioned.

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JUAN DELA CRUZ
TIN 258-564-887
Issued on November 10, 2005

JURAT