REPUBLIC OF THE PHILIPPINES)

CITY OF Muntinlupa)s.s.

AFFIDAVIT
I, Karen Faye G. Garcia, of legal age, Filipino, with office address at G/F
Queensland Commercial Plaza, Dolores, City of San Fernando, Pampanga
Philippines after having been duly sworn according to law, hereby depose and
state that:
1. I was the Claims Assistant Processor under the Motor Car Claims
Processing Unit, of MAPFRE INSULAR INSURANCE CORPORATION (Defendant
Mapfre for brevity), a corporation duly organized and existing by virtue of the
laws of the Republic of the Philippines with principal address at MAPFRE
Insular Corporate Center, Acacia Ave., Madrigal Business Park, Ayala
Alabang, Muntinlupa City Philippines.
2. As claims assistant processor under the Motor Car Claims Processing
Unit, North Luzon Branch Operations, I was one of the processors in charge
with the processing of all motor car claims for or against Defendant Mapfre.
3. On November 23, 2015, I have issued the LOA amounting to 46,016.00, quoted
for surplas parts to Car Palace, assigned accredited non-casa shop. The same
was discussed to assured.
4. On December 8, 2015, it is verified with shop that they are having difficulty
looking for parts.
5. Two days after, assured requested for reimbursement instead and he will be the
one to find shop who can provide parts. It is clearly advised with assured
verbally that reimbursement will follow our approved rate or theirs whichever
is lower so he needs to inform us of his canvassed prices first for our further
review. Assured agreed that he will not commit to any shop.
6. Last December 14, 2015, assured through his agent submitted estimate from a
non-casa shop amounting to 106,000. I immediately called him that his
estimate is greater than casa rate so we cannot proceed with his chosen shop.
He then said that he already had his vehicle repaired there and parts were
already placed to order.
7. The next day, reimbursement was approved. I have advised him again that our
evaluation 46,016 will be the amount that he can reimburse with us.
8. On December 18, 2015, his agent went to the office and submitted Sales
Invoice for the parts and labor with invoice date 12/17/2015 and a letter
demanding us to pay 106,000. Mapfre conducted surprise inspection the same
day in the shop and found out that 2 parts (engine hood {17,500 price on the
invoice} and fender {6,500} ) were only repaired. Still assured is demanding us
to pay for the said parts.

9. Due to the findings, we revised our offer from 46,016 to 38,100 last December
23, 2015. This was discussed thoroughly to assured. He responded with a
letter from his attorney that I received last January 6, 2016 and forwarded the
same to Claims heads for further instructions.
I am executing this affidavit to attest to the truthfulness of the foregoing
statements and for whatever legal purpose it may serve.
IN TESTIMONY WHEREOF, I have hereunto set my hand this day of
March 8, 2016 at City of San Fernando.

Karen Faye G. Garcia

SUBSCRIBED AND SWORN to before me this ____________________ at

Cagayan de Oro City, affiant exhibiting to me her ____________________ issued at
______ on _____________.
Doc. No. _____;
Page No. _____;
Book No. _____;
Series of 2016