Republic of the Philippines

REGIONAL TRIAL COURT

FOURTH JUDICIAL REGION
Cavite City, Branch 16

YAYA DUB,
Plaintiff,

- versus - CIVIL CASE NO. 123456

For: Specific Performance with
Damages

ALDEN RICHARDS,
Defendant.
x----------------------x

FORMAL OFFER OF EVIDENCE

Plaintiff, through the undersigned counsel, most respectfully

submits this Formal Offer of Evidence as follows:

# Document Purpose
A Contract for the This Contract for the Repair of the House
Repair of the House dated October 11, 2017 with the contract
dated October 11, 2017 price of Php 582,000.95 is being offered to
with the contract price prove the existence, genuineness, and due
of Php 582,000.95 execution of the contract; to prove the
agreements made by the parties for the
repair of the house; to prove that the
repair of the house should be finished and
completed within 65 days.
B Contract for the This Contract for the Extension of the
Extension of the Kitchen dated November 12, 2017 with the
Kitchen dated contract price of Php 367,000 is being
November 12, 2017 offered to prove the existence,
with the contract price genuineness, and due execution of the
of Php 367,000 contract; to prove the agreements made
by the parties for the extension of the
kitchen; to prove that the extension of the
kitchen should be finished and completed
within 65 days.
C Receipt of Down This Receipt of Down Payment of Php
Payment of Php 174,600.29 is being offered to prove that
174,600.29 the Plaintiff has paid the down payment
as agreed upon in the first contract; to
prove that the Defendant received and
accepted the payment.
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 D Receipt of Down This Receipt of Down Payment of Php
Payment of Php 110,100 is being offered to prove that the
110,100 Plaintiff has paid the down payment as
agreed upon in the second contract; to
prove that the Defendant received and
accepted the payment.
E- Receipts for necessary These Receipts for necessary repairs of the
E-26 repairs of the house house worth Php 128, 672.68 are being
worth Php 128, 672.68 offered to prove the amount incurred by
the Plaintiff for repairing the house due to
some defective and unfinished
construction left by defendant.
F Demand Letter sent to This Demand Letter sent to Defendant
Defendant dated dated November 24, 2018 is being offered
November 24, 2018 to prove the Plaintiff’s earnest efforts to
demand the Defendant to finish the repair
of her house.
G Demand Letter sent to This Demand Letter sent to Defendant
Defendant dated dated December 16, 2018 is being offered
December 16, 2018 to show the Plaintiff’s earnest efforts to
demand the Defendant to finish the
extension of her kitchen.
H Reply of the Defendant This Reply of the Defendant is being
offered to prove that the Defendant
received the Demand letters and promised
to make the repairs and continue the
extension of the kitchen.
I- Photos of the These Photos of the unfinished repairs of
I-10 unfinished repairs of the house and incomplete extension of the
the house and kitchen to show the defective and
incomplete extension unfinished construction left by defendant
of the kitchen which caused serious damage to various
parts of the house.
J Judicial Affidavit of This Judicial Affidavit of Yaya Dub is
Yaya Dub being offered to serve as her direct
examination testimony.
K Judicial Affidavit of This Judicial Affidavit of Wall Anjoy Sia
Wall Anjoy Sia Sy- Sy-King is being offered to serve as his
King direct examination testimony.

PRAYER

WHEREFORE, premises considered, Plaintiff respectfully

prays:

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 1.) This Honorable Court to take notice of this Formal Offer of
Evidence;
2.) Exhibits A-K be submitted as evidence by Plaintiff for the
purposes for which they have been offered.

All just and equitable reliefs are likewise prayed for.

Respectfully submitted.

Cavite City, 22 March 2019.

(sgd.)
ATTY. LAKAS T. AMA
Unit 2, 3rd Flr., Gov. Drive Mangubat Avenue
Zone IV, Dasmarinas, Cavite
0932 754 9521
lakastama@gagmail.com
Roll of Attorney No. 53455
PTR No. 0416909/Taguig/01-25-2018
IBP No. 579372/4-8-04/Taguig
MCLE No. III-000560
August 20, 2017

Copy Furnished:

Atty. _______________
(Address of Counsel for Defendant)

EXPLANATION

This Formal Offer of Evidence is being filed with copy thereof

furnished to the other party by registered mail due to the
geographical distance of the undersigned from the other party
making personal service thereof not practicable.

(sgd.)

ATTY. LAKAS T. AMA

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