Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 45, Quezon City

ALYANA C. DALISAY
Complainant,

-versus- CIVIL CASE NO. 81893

For: Damages based on Quasi-Delict

GERALDINO S. SALAY
Respondent
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FORMAL OFFER OF EVIDENCE

        THE RESPONDENT, by the undersigned counsel, respectfully offer their documentary exhibits in
support of their case-in-chief:

        1.  Exhibit 1, The Valid receipt of the renewal of the respondent’s driver’s license with an expiry
date on September 22, 2018, issued by the LTO main office located at East Ave., Quezon City and an OR
number of 117019815 and an amount of php 652.63 as paid

        2.  Exhibit 2, 2-A, and 2-B are pictures of the location where the accident happened. The pictures
shows the wall of Greenmeadows subdivision, Jollibee, a footbridge, and the road on C5 southbound.
The pictures were taken by the Metro Manila Development Authority or MMDA

3. Exhibit 3 is the affidavit of Japert Guapings to prove that respondent was neither driving
negligently nor recklesly as well as to prove that deceased was not in the proper place for crossing the
road at the time of the incident.

4. Exhibit 4 is the affidavit of Rocky Harry, an MMDA officer, to prove that there are pedestrian
bridges connecting both sides of the road; to the physical condition of the road in order to prove
that the defendant could not have possibly driven at such a fast speed as to be considered
negligent; and finally, as to the existence of a Jollibee right beside Eastwood, much closer to the
deceased’s alleged location prior to the incident, in order to prove that the deceased could not
have come from Eastwood as alleged.

5. Exhibit 5 is the Affidavit of Gong Bo to prove that his license was not actually expired on
August 5, 2018, or when the accident happened
 
        WHEREFORE, the respondent respectfully prays that the foregoing Exhibits be ADMITTED as
proof of the facts therein stated and in support of its case-in-chief and for all other relevant purposes.

        Quezon City; 7th November 2018.

ARTHUR ARCHIE TIU

Counsel for the defendant
Copy furnished:

CHEDELLE FLORIDO
Counsel for Accused