Republic of the Philippines

First Judicial Region

Branch No. 05
Regional Trial Court
Baguio City

Dianne J. Bugayong Civil

Case No. 172
Plaintiff, For: Collection of
Sum of Money
Vs.
Aileen S. Gamboa
Defendant.
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COMMENT/OBJECTIONS
(To the Prosecution’s Formal Offer of Object and
Documentary Evidence)

The DEFENDANT by the undersigned counsel and unto

this Honorable Court, most respectfully comments to
the purpose of the offer as follows:

“A” Contract of Loan Defendant through undersigned

counsel, has no objection as the purpose
of the exhibit but reserves his right to
cross-examine such on all points.

Defendant through undersigned counsel

“B” BPI Check No. P3A-012345 objects to the admissibility of the exhibit
on the ground that the Plaintiff failed to
prove its genuiness and due execution
and its existence in fact.

Defendant through undersigned counsel

“B-1” “DAIF” stamped on the objects to the admissibility of the exhibit
check on the ground that the Plaintiff failed to
prove its genuiness.

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“C” BPI Deposit Slip The defendant admits the issuance of
the check but objects to the purpose of
the offer which is to prove that the check
was dishonored since no notice was
given to the former.
“D” Notice of Dishonor Defendant through the undersigned
counsel admits the existence of the
document but objects to the purpose as
it does not prove anything and thus
immaterial to the case.

COUNTERCLAIM

Due to this case, defendant expects to incur or spend

attorney’s fees of not less than TWENTY THOUSAND PESOS
(P20,000.00).

PRAYER

WHEREFORE, it is respectfully prayed of the Honorable

Court that after hearing, it shall issue an order decreeing:

1. That CIVIL CASE NO. 172 be dismissed.

2. Order plaintiff to pay defendant actual attorney’s

fees incurred in the amount of not less than TWENTY
THOUSAND PESOS (P20,000.00).

RESPECTFULLY SUBMITTED.

In the City of Baguio, Philippines, this 25th day of

August, 2018.

TABANDA LAW OFFICE

Suite 308 3/F Laperal Building
Session Road, Baguio City
2600 Philippines
Telefax (083)552-5627
Email: mikotabanda@gmail.com

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 ________________
________________
ATTY. MIKAEL LORENZO
TABANDA
Roll No. 51814
IBP No. 021828-08/05/2017,
Baguio City
PTR No. 082818-08/06/2017,
Baguio City

VERIFICATION

I, Aileen S. Gamboa, single, of legal age and resides

at No. No. 231 Aurora Hill, Philippines, after having been duly
sworn in accordance with law, do hereby depose and state
that:

1. I am the defendant in this case;

2. I have caused the filing of the above answer;

3. I have read the contents thereof and the facts

thereon are true and correct according to my
personal knowledge and on the basis of the copies of
the documents and records I hold in my possession;

4. I have not commenced any action or proceeding

involving the same issues before the Supreme Court,
Court of Appeals or before any tribunal or agency;

5. To the best of my knowledge, there is no such

pending action or proceeding before the Supreme
Court, Court of Appeals or before any tribunal or
agency;

6. If I should thereafter learn that a similar action or

proceeding has been filed or is pending before the
Supreme Court, Court of Appeals or any other
tribunal or agency, I undertake to report that fact
within five (5) days therefrom, to this Honorable
Court.

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IN WITNESS WHEREOF, I hereunto sign my hand this 14th
day of September, 2018.

AILEEN S. GAMBOA

Subscribed and sworn to me this 14th day of September,

2018, in the City of Baguio, Philippines.

WITNESS MY HAND AND NOTARIAL SEAL.

Doc. No. 29 ATTY. SAUL ARIES MARCK

ORTIZ
Page No. 32 Roll No. 5551: 03-02-10
Book No. XVII IBP Lifetime: 3356
Series of 2018 MCLE Compliance: II 12345
PTR No. 86710

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