REPUBLIC OF THE PHILIPPINES

NATIONAL JUDICIAL CAPITAL REGION

METROPOLITAN TRIAL COURT
Branch 66, City of Makati

CRUELLA DE VIL,
plaintiff,

CIVIL CASE No. 513

-versus- For: Damages based on
Quasi-Delict

JAMES P. SULLIVAN,
defendant.

x------------------------------------------------x

FORMAL OFFER
OF DOCUMENTARY EVIDENCE

PLAINTIFF, through the undersigned Counsel, unto this Honorable

Court, most respectfully submits and files this FORMAL OFFER OF
DOCUMENTARY EVIDENCE for marking and admission of the following:

EXHIBIT DESCRIPTION PURPOSE

A Photo of the Motor showing To support and prove
the Plate Number plaintiff ’s claim on the identity
of the motorcycle involved in
this case as testified by the
plaintiff in her Judicial
Affidavit Question and Answer
(Q&A) No. 5.

B Land Transportation Office 1. To establish the plaintiff ’s

Certification No. 216243 dated
11 March 2019 issued to
Cruella de Vil
justification in filing this case
against the defendant as
testified by the plaintiff in her
Judicial Affidavit Q&A No. 4;
2. To establish the connection
of the motorcycle and the

B-1 LTO Official Receipt No. To support and substantiate
2312305912 dated 11 March the
2019 reflecting Php150.00 genuineness of the LTO
Certification.
C Traffic Accident Investigation
Report issued by PNP-Taguig
dated 4 January 2019, signed by
PO1 Cardo Dalisay
D St. Luke’s Hospital, BGC
Taguig Official Receipt No. 026
dated 7 January 2019 reflecting
Twenty Thousand pesos
(20,000.00).
E Original Copy of the Official
Receipt No. 091741586615
dated 4 January 2019 reflecting
sale of medicine amounting
Php6,000.00 issued by Mercury
Drugs
F Photo of the Karat World
Official Receipt No. 00017
dated 4 January 2019 reflecting 1. To support the testimony of
defendant in this case as
testified by the plaintiff in her
Judicial Affidavit Q&A No. 4
and 9; and
3. To support the plaintiff ’s
testimony in her Judicial
Affidavit Q&A No. 9, and
prove that the defendant is the
registered owner of the
motorcycle pursuant to the
records of the Land
Transportation Office (LTO).
authenticity and
1. To support the testimony of
the plaintiff with respect to,
and prove the accident she
testified on in her Judicial
Affidavit Q&A No. 3, 4 and
10.
1. To support the testimony of
the plaintiff respecting her
hospitalization after the
accident as she testified in her
Judicial Affidavit Q&A No.3,
11, 12, and 13; and
2. To prove and substantiate
the amount claimed as cost of
hospitalization as testified by
the plaintiff in her Judicial
Affidavit Q&A No. 11 and 13.
To support and substantiate
the amount claimed as cost of
medicine as testified to by the
plaintiff in her Judicial
Affidavit Q&A No. 20.
 sale of Marisse WG 0.50ct the plaintiff respecting her
14KT Diamond Ring to Cruela purchase of a diamond ring in
de Vil for Php205,900.00 her Judicial Affidavit Q&A No.
3;
F-1 Photocopy of the Karat World 2. To prove that the diamond
Official Receipt No. 00017 ring was purchased on the day
dated 4 January 2019 reflecting the plaintiff was involved in
sale of Marisse WG 0.50ct the accident; and
14KT Diamond Ring to 3. To establish and substantiate
Cruella de Vil for the plaintiff ’s claim as to the
Php205,900.00 cost of the diamond ring as
testified to in her Judicial
F-2 Original Copy of Certification Affidavit Q&A No. 16 and 17.
of Authenticity issued by Karat
World Philippines to Cruella de
Vil

G Original Copy of Official 1. To prove and substantiate

Receipt No. 053610 dated 16
December 2018 issued by
Apple Center Philippines, Inc.
To buyer Cruela de Vil
reflecting sale of iPhone xs for
amount of Php84,274.00
the testimony of the plaintiff
respecting the cost of the
iPhone in her Judicial Affidavit
Q&A No. 18.

H Screenshot of website showing To support plaintiff ’s

Account History of BDO testimony regarding the cash
Savings Account No. she had on her at the time of
00728006969239 for period of the accident on her Judicial
January 1 – March 1, 2019 Affidavit Q&A No. 20 and 21.

With the submission and admission of the above documentary evidence,

together with the testimony of the plaintiff, the plaintiff rests its case.

Makati City, Philippines, 4 April 2019.

Karen Ann Torres-Laverinto

Counsel for the Plaintiff
301 – 306, 32nd and 5th Building, 32nd Street,
cor. 5th Avenue, BGC, Taguig, Philippines
PTR No. 123456 / 01-05-2019 Taguig City
IBP No. 123456 / 09-05-2017 Taguig Chapter
Attorney Roll No. 15130
MCLE Compliance Certificate No.: NCR-0123456 January 15, 2019
COPY FURNISHED:

Atty. Andrew Lastrollo

Counsel for the Defendant
8F Pacific Star Building, Sen Gil J. Puyat Ave.
cor. Makati Ave., Makati City, Philippines