Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION

Regional Trial Court
Branch 69
Taguig City

GLORIA MACAPUGA-ARROYO, Civil Case No. 123456

Plaintiff FOR: COLLECTION FOR A SUM OF
MONEY WITH DAMAGES
- versus -

ARNULFO SANIDAD,
Defendant
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

PLAINTIFF by the undersigned counsel and unto this Honorable Court, most
respectfully offers in evidence the following documentary exhibits for the above titled case, to wit:

EXHIBIT DESCRIPTION PURPOSE/S

“1” Contract of loan entered into To prove the fact and
by Plaintiff Gloria Macapugo- existence of the Contract of
Arroyo and Defendant Loan as basis the civil case
Arnulfo Sanidad - consisting
of two (2) pages
“2” Demand Letter sent by To prove the fact that
Plaintiff Mrs. Gloria defendant Arulfo Sanidad
Macapugo – Arroyo to defaulted in the payment of
Defendant Mr. Arnulfo his obligation despite demand
Sanidad - consisting of one (1)
page
“3” Judicial affidavit of Gloria To prove the truthfulness of
Macapugo- Arroyo – her allegations in the
consisting of five (5) pages complaint, particularly as to
the circumstances related to
the loan extended to herein
defendant, as provided in the
Contract of Loan.
“4” Judicial affidavit of Hairy To prove the fact that the
Roque – consisting of four (4) driver of the plaintiff Arroyo
pages will testify as to the latter’s
whereabouts on April 30,
2018, the date when Mr.
Roman Esguerra claims to
have tendered the payment at
the plaintiff’s residence on
behalf of the defendant,
Arnulfo Sanidad.
“5” Judicial Affidavit of Teri De To prove the fact that there
Castro – consisting of five (5) was no consignation made by
pages. Mr. Arnulfo Sanidad. The
Branch Clerk of Court of
Taguig City RTC Branch 69
testified as to the
circumstances of the alleged
consignation made by the
defendant.
 With the above-enumerated exhibits, the defense is resting its case.

WHEREFORE, premises considered, it is most respectfully prayed to this

Honorable Court that the foregoing documentary exhibits be admitted for all
purposes for which each and all said exhibits were being offered in proving the
claims of the complainant/s, and with the formal submission of the aforesaid exhibits
coupled with the testimonies of the witnesses who testified thereon.

Taguig City, Metro Manila

November 4, 2018

ATTY. REJOUREL CHRISTIAN ADOBO

Counsel for Plaintiff

NOTICE

The Hon Clerk of Court

RTC Branch 69 Taguig City

GREETINGS:

Please submit the foregoing Formal Offer for the consideration and approval
of the Honorable Court immediately upon receipt hereof.

ATTY. REJOUREL CHRISTIAN ADOBO

Counsel for Plaintiff

EXPLAINATION OF SERVICE

Copies of the foregoing Formal Offer are served upon counsel of the
defendant ARNULFO SANIDAD and filed with the Court by personal service.

ADOBO CLEMENTE & MONJE LAW OFFICES

Counsel for Plaintiff
T. Amad Law Office, #1 Lasingan St.,
Brgy. Walang Trabaho, Taguig City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/18, Taguig City
IBP NO. 123456, 01/04/18, Taguig City
MCLE Comp. No. IV-0009876, 01/02/18

Filed by:
ATTY. REJOUREL CHRISTIAN ADOBO
COUNSEL FOR PLAINTIFF
Copy furnished:

Regional Trial Court

Branch 69
Taguig City

DELGADO GARCIA RAYOS DEL SOL & TANG LAW OFFICES

Counsel for Defendant
38th Drive, DLSU Rufino Campus
Bonifacio Global City, Taguig City

AFFIDAVIT OF SERVICE BY REGISTERED MAIL

I, JOSE RIZAL, of legal age and having been duly sworn depose and say:

That I am the MESSENGER of D ADOBO CLEMENTE & MONJE LAW

OFFICES, counsels for Plaintiff in the case of “Macapuga-Arroyo v. Sanidad”,
Civil Case No. 123456, and as such messenger I served upon the counsels of the
adverse party, the petition filed in said case:

By depositing the copy in the post office in sealed envelope, plainly addressed
to the counsels at their office, with postage fully prepaid, and with instruction to the
postmaster to return the mail to the sender after ten days if undelivered, this 8th day
of November 2018, as shown by Registry No. 54321 dated 8 November 2018 of the
post office of Taguig City.

IN WITNESS WHEREOF, I have signed this affidavit this 8th day of

November 2018 at Taguig City.

(SGD.) JOSE RIZAL

Affiant

SUBSCRIBED AND SWORN to before me on this 8th day of November 2018 at

Taguig City, affiant exhibiting to me his Philippine COMELEC ID NO. 1234567
which will expire on December 31, 2020.

ATTY. EMILIO AGUINALDO

NOTARY PUBLIC for Taguig City
05 Araneta Ave. Taguig City
IBP No. 33333 05/05/18-Taguig City
PTR No. 0000, 05/05/18-Taguig City
Roll No. 56787; 09/5/18

Doc. No. _____

Page No. _____
Book No. _____
Series of 2018.