Plaintiff, For: Collection of Sum of Money -versus- with Prayer of writ for the issuance of Preliminary DO C. TOR, Attachment Defendant.
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FORMAL OFFER OF EVIDENCE
PLAINTIFF, through counsel, most respectfully submits this Formal Offer
of Exhibits, to wit:
Exhibit Document Purpose
“A” Loan Agreement executed to prove that defendant borrowed by the plaintiff and from plaintiff an amount of defendant on 01 January, P5,000,000.00 and in return, 2017 defendant agreed and promised to pay the said loan within 12 months, plus an interest at the rate of 10% per annum and a 5% penalty for delay. Also, to prove that they executed the loan agreement in the presence of two witnesses in order to secure the genuineness and due execution of the contract
“B” BDO Check No. 123456 in to prove that defendant
the amount of FIVE acknowledged the existence of the MILLION PESOS loan by trying to satisfy his obligation (P5,000,000.00) under the contract through giving a check to plaintiff in the amount P5,800,000.00 but was dishonored due to insufficiency of funds
“C” Notice of Dishonor & to prove that due to failure of the
Demand Latter dated 01 defendant to settle his obligations, August 2019 which plaintiff caused the preparation of a Defendant received on 01 written demand to give defendant August 2019 sufficient opportunity to settle his obligation
“D” Certificate to File Action to prove that there was a prior
with Barangay Case No.01- conciliation and mediation between 001 executed at Second the parties but no settlement was Village, the barangay of the effected thereto which prompted the defendant, on 19 August, plaintiff to file this action 2019
“E” The Judicial Affidavit of to prove that the defendant willfully
Plaintiff’s principal witness and voluntary executed the loan agreement
With the submission and the admission of the above evidence, the plaintiff rests its case.
Baguio City, Philippines, September 07, 2019.
Most respectfully submitted.
DMO LAW OFFICE
Counsel for Defendant #1 Upper Session Rd., Baguio City 2600 Tel. No. (074) 420-0000 | e-mail: dmolawoffice@gmail.com
By:
KING ANTHONY M. MONTEREAL
#1 Upper Session Rd., Baguio City Roll No. 999999 IBP No. 09999999/June 13, 2018 Baguio-Benguet Chapter PTR No. 8888888/June 06, 2019 MCLE Certificate of Compliance No. 1111111
COPY FURNISHED
ATTY. CAMILA ANGELINE M. TAMULONG
Counsel for Defendant PPT Law Office 4th floor, CAP bldg., Post office loop, Baguio City
EXPLANATION
Service of pleading is done by registered mail to the office of the Counsel
of the Defendant, PPT Law Office 4th floor, CAP bldg., Post office loop, Baguio City, and the private respondent due to the distance and lack of office personnel to effect personal service.
KING ANTHONY M. MONTEREAL
#1 Upper Session Rd., Baguio City Roll No. 999999 IBP No. 09999999/June 13, 2018 Baguio-Benguet Chapter PTR No. 8888888/June 06, 2019 MCLE Certificate of Compliance No. 1111111