REPUBLIC OF THE PHILIPPINES

Fifth Judicial Region

REGIONAL TRIAL COURT
Branch ______
Daet, Camarines Norte

HEIRS OF FRANCISCO CIVIL CASE No.

FERRER represented by JOEL _____________________
FERRER, For: EX-PARTE PETITION FOR
Petitioners, REVIVAL OF JUDGMENT

-versus-

SIEGFREDO MAGANA and

ALL PERSONS CLAIMING
RIGHTS UNDER HER,
Respondent/s
x------------------------------------x

COMPLAINT
COMES NOW, the petitioner, by and through the undersigned
counsels and unto this Honorable Court, respectfully states:

PARTIES

1] That the petitioner, is of legal age, married, Filipino citizen and a

resident of 145 Diamond St., Francis Subdivision, Meycauayan, Bulacan at
which given address all Honorable Court’s legal orders, notices and
processes may be served at which given address all Honorable Court’s
summons, orders and processes may be served, has been constituted as
attorney-in-fact of the Heirs of Francisco Ferrer, and authorized to institute
this instant complaint. Machine copy of his Special Power of Attorney is
hereto attached as ANNEX “A” and form an integral part hereof.

2] That the respondent Siegfredo Magana is likewise of legal age,

Filipino, and may be served with summons, orders and other processes of
this Honorable Court at his last known address in Brgy. Del Carmen,
Talisay, Camarines Norte;

FACTUAL ANTECEDENTS

3] That a suit for Ejectment was filed by the petitioners against the
respondent which was lodged before the Municipal Trial Court of Talisay,
Camarines Norte and docketed as Civil Case No. 172 involving a parcel of

Page 1 of 17
land situated in Brgy. Del Carmen, Talisay, Camarines Norte containing an
area of 40,000 Square Meters embraced under Transfer Certificate of Title
No. T-10945 under the name of petitioners’ predecessors-in-interest,
Francisco D. Ferrer; Machine copy of Transfer Certificate of Title No. T-
10945 is hereto attached as ANNEX “B”;

4] That on September 7, 2006, the Honorable Municipal Trial Court of

Talisay, Camarines Norte rendered a Decision, the dispositive portion of
which is as follows:

“WHEREFORE, premises considered, judgment is hereby

rendered in favor of the plaintiff, ordering the defendant and
all persons claiming rights under him to:

a) Vacate and surrender the subject land to the plaintiff;

b) Pay reasonable monthly rental of P1,000.00 from the date
of the decision until they vacate the property;
c) Pay P2,000.00 by way of reasonable attorney’s fees; and
d) pay the cost of suit.

SO ORDERED

Machine copy of the Decision dated September 7, 2006 is attached herewith

and marked as ANNEX “C”, and made an integral part hereof.

5] Displeased, they appealed the adverse Decision before the

Honorable Regional Trial Court Branch 38, Daet, Camarines Norte docketed
as Civil Case No. 7565, however, the appellate court was not persuaded, and
on June 26, 2008, it issued its Decision which dispositive portions read as
follows:

“WHEREFORE, the instant appeal is hereby DENIED. The

September 7, 2006 Decision of the Municipal Trial Court of
Talisay, Camarines Norte, in Civil Case No. 172 is
AFFIRMED in toto.

SO ORDERED”

Machine copy of the said Decision is attached herewith and marked as

ANNEX “D”, and made an integral part hereof.

6] That the petitioners moved for the execution of the Decision of the
court a quo pending appeal which was granted by the appellate court -
Regional Trial Court Branch 38, Daet, Camarines Norte, in the Order dated
January 2, 2007.

Page 2 of 17
 7] On January 18, 2007, Hon. Leo L. Intia, Judge designated of
Regional Trial Court Branch 38, Daet, Camarines Norte issued a Writ of
Execution. Machine copy thereof is hereto attached as ANNEX “E”, and
form an integral part hereof.

8] That the implementing Sheriff Reynor F. Ubalde of Regional Trial

Court Branch 38, Daet, Camarines Norte exerted efforts to implement the
Writ of Execution of the said Honorable Court, however, for causes
independent of his will, exclusively attributable to the respondents, the
former failed to fully execute the said Writ of Execution, thereby
recommending the issuance of Writ of Demolition. Copy of Sheriff’s
Reports dated February 02, 2007 and March 21, 2007. Machine copies
thereof are hereto attached as ANNEX “F” to “G”.

9] On February 12, 2009, the Honorable Municipal Trial Court of

Talisay, Camarines Norte issued a Writ of Demolition upon motion of the
petitioners. Machine copy thereof is hereto attached as ANNEX “H” and
form an integral thereof.

10] That on March 5, 2014, implementing Sheriff Bonifacio C.

Reynaldo, Jr. of Office of the Clerk of Court-Regional Trial Court, Daet,
Camarines Norte filed his Sheriff’s Report explaining that the Writ of
Execution and Demolition had already expired, and the same was returned
unsatisfied. Machine copy of the said Sheriff’s Report is hereto attached as
ANNEX “I” forming an integral part hereof.

11] Simultaneously, the respondents even filed for Annulment of

Judgment with prayer for TRO and motion to litigate as indigent party before
the Honorable Court of Appeal which was DISMISS and DENIED,
accordingly. Machine copy of the CA’s resolution dated July 23, 2009 is
hereto attached as ANNEX “J” forming an integral part hereof.

12] Its been nine (9) years since the last Sheriff’s Report involving the
execution of the case above-described, the Decisions of the Honorable trial
court and appellate court remains unsatisfied and the respondents enjoyingly
savoring their indirect victory in their legal battle with the petitioners.

13] That the petitioners have the right of action to demand satisfaction
of the Decisions of the Municipal Trial Court of Talisay, Camarines Norte
and Regional Trial Court, Branch 38, Daet, Camarines Norte within ten (10)
years from March 5, 20141;

CAUSE OF ACTION

14] That as provided under Sec. 6, Rule 39 of the Rules of Court, “a

final and executory judgment or order may be executed on motion within
1
Art. 1144, New Civil Code of the Philippines

Page 3 of 17
five (5) years from the date of its entry. After the lapse of such time, and
before it is barred by the statute of limitations, a judgment may be
enforced by action.

15] In the case at hand, there is a final and executory judgment

rendered by the appellate court which remain unsatisfied despite the same
being ordered executed by the trial court and appellate court. To such failure
the petitioners lacks any participation.

16] Guiding is the case of QUILO AND VILLAHERMOSA VS.

BAJAO, G.R. No. 186199. September 07, 2016, where the Supreme Court
made the pronouncement that:

xxx In the case at bar, the Decision, despite the timely

motion to execute the same, was not implemented by the
court. The failure to implement the Decision impelled Bajao to
again file another motion to execute. However, Bajao's course
of action to execute the Decision is not in accordance with
Section 6, Rule 39. xxx

xxx In such a case, where a strict enforcement of the rules will

not serve the ends of justice and manifest wrong or injustice
would result, the courts, under the principle of equity, may
liberally apply the rules.[29] Rules of procedure, after all, should
promote, not frustrate, substantial justice. [30] Therefore, in
pursuit of equity justice, this Court resolves to regard the second
motion for execution as a complaint for revival of judgment to
allow this Court to rule on the merits of the case. Apparently, the
failure to execute the Decision is not Bajao's fault. In fact,
Bajao timely filed a motion to execute within the 5-year
reglementary period. The delay in the execution, caused by
some reasons unknown to this Court, should not penalize an
otherwise zealous litigant. xxx

17] Preceding from the foregoing, it is only but right and just that the
petitioners be allowed to fully taste their triumph after years of endeavor and
hardship to again occupy the subject property of the above-described
property free from intervention of the respondents.

MONETARY CLAIMS

18] In addition to the obligations imposed by the Decision dated

September 7, 2006 of the Honorable Municipal Trial Court of Talisay, Daet,
Camarines Norte. The Respondents, despite due notice of the said Decision,
and knowledge that their appeals to appropriate appellate courts were either
DENIED or DISMISS, failed and refused to honor their obligation as
consequence thereof. The Petitioner was constrained to institute this instant
Page 4 of 17
action and secure the services of the undersigned counsels in the amount of
Php 100,000.00 as acceptance fees, plus Php 6,000.00 as appearance fee for
every court hearing; and

26] Moreover, Petitioners also incurred litigation expenses which

Respondents must be order to pay.

SUMMARY OF EVIDENCES

DOCUMENTARY/ PURPOSE/S
OBJECT
ANNEX “A” Special Power of To prove that Joel
Attorney Ferrer, one of the
Heirs of the late
Francisco Ferrer, has
authority to institute
this instant complaint,
the scope of and limits
of the authority
granted.

ANNEX “B” Certified true copy of To prove that the

Transfer Certificate of identity including its
Title No. T-10945 metes and bounds and
registered owner of
the subject property;
that it has an official
record with Registry
of Deeds for
Camarines Norte.

ANNEX “C” Decision dated To prove that there

September 7, 2006 of was a civil case for
the Honorable ejectment involving
Municipal Trial Court the property subject of
of Talisay, Camarines this case, and between
Norte the Petitioners and
Respondents, in which
the respondents were
ordered to vacate and
surrender the peaceful
possession of the
subject property;

ANNEX “D” Decision dated June 26, To prove that the

2008 of the Honorable Decision dated
Regional Trial Court, September 7, 2006 of

Page 5 of 17
 Branch 38, Daet, the Municipal Trial
Camarines Norte. Court of Talisay,
Camarines Norte was
appealed by the
respondents but the
same was upheld and
affirmed by the
appellate court and the
appeal was denied.

ANNEX “E” Writ of Execution dated To prove the Decision

January 18, 2007 issued dated September 7,
by the Regional Trial 2006 of the Municipal
Court Branch 38, Daet, Trial Court of Talisay,
Camarines Norte Camarines Norte was
ordered executed
pending appeal by the
appellate Regional
Trial Court Branch
38, Daet, Camarines
Norte.

ANNEX “F” and “G” Sheriff’s Reports dated To prove that the
February 02, 2007 and Decision dated
March 21, 2007 September 7, 2006
was not successfully
satisfied by reason of
causes attributable to
the Respondents; and
to prove other facts
surrounding the
implementation of
said Decision.

ANNEX “H” Writ of Demolition To prove that the

dated February 12, 2009 Petitioners complied
from the Honorable with the
Municipal Trial Court recommendation of
of Talisay, Camarines the the implementing
Norte. Sheriff Reynor F.
Ubalde for issuance of
Writ of Demolition.

ANNEX “I” Sheriff’s Report dated To prove that the

March 5, 2014 of Decision dated
implementing Sheriff September 7, 2006 of
Bonifacio C. Reynaldo, the Municipal Trial
Jr. of Office of the Court of Talisay,
Page 6 of 17
 Clerk of Court-
Camarines Norte
Regional Trial Court, remained unsatisfied
Daet, Camarines Norte and the Writ of
filed his explaining that
Demolition and
the Writ of Execution Execution already
and Demolition had expired; and to prove
already expired, and the
other facts
same was returned surrounding the
unsatisfied implementation of
said Decision.
ANNEX “J” Court of Appeals’ To prove that the
resolution dated July respondents filed an
23, 2009 Action for annulment
of judgment involving
the Decision dated
September 7, 2006 of
the Municipal Trial
Court of Talisay,
Camarines Norte,
which action was
DENIED/DISMISSE
D, accordingly
TESTIMONIAL/
JUDICIAL
AFFIDAVITS

ANNEX “K” 1] JOEL FERRER To prove all material

allegations of this
complaint as well as
to identify and
authenticate evidences
in support thereof.

(RESERVED) 2] AT LEAST TWO To corroborate

(2) WITNESSESS ultimate facts relied
upon by the plaintiff
and to identify and
authenticate
evidences.

PRAYER

WHEREFORE, in light of the foregoing, it is most respectfully

prayed from the Honorable Court that after due notice and hearing judgment
be rendered ordering the Respondents to:

Page 7 of 17
 a] Immediately vacate and surrender the premises in dispute to
the Petitioners;

b] Pay at least P100,000.00 by way of acceptance fees and

appearance fees in the amount of P6,000.00 in every appearance;

c] Pay at least 5,000.00 by way of monthly rental until they have

fully vacated the premises; and

d] Pay costs of suit.

Other reliefs just and equitable under the premises are likewise prayed
for.

Daet, Camarines Norte, _____________.

ATTY. CHRISTOPHER S. CADAG

Counsel for the Petitioner
Gov. Panotes Ave., Brgy. VIII, Daet, Camarines
Norte
(In front of Mabini Colleges Inc.)
Email Add.: [email protected]
PTR No. 7339877-1/3/2023-D.C.N
IBP No. 257529-1/2/2023
Attorney’s Roll No. 73436
MCLE Compliance No. VII-0003540
Until Dec. 31, 2025

ATTY. ADRIAN B. MAYORES

Collaborating Counsel for the Petitioner
Gov. Panotes Ave., Brgy. VIII, Daet, Camarines
Norte
(In front of Mabini Colleges Inc.)
Email Add.: [email protected]
PTR No. 7371347-5/5/2023-D.C.N.
IBP No. 338049-5/5/2023
Attorney’s Roll No. 86508

Page 8 of 17
Republic of the Philippines)
Daet, Camarines Norte) S.S.

VERIFICATION WITH CERTIFICATION OF

NON-FORUM SHOPPING

          I, JOEL FERRER, of legal age, single/married and with postal address
at 145 Diamond Drive, St. Francis Subd., Phase 1, Pandayan, Meycauayan,
Bulacan, after having been duly sworn to in accordance with law do hereby
depose and state that:

1] That I am the petitioners’ representative in the above-entitled case.

2] That I have caused the above complaint to be prepared and have read
and known the contents thereof.

3] That all the allegations made therein are true and correct based on my
personal knowledge and authentic documents, supported by sufficient evidence
or will be supported by sufficient evidence after due opportunity for discovery;
and

4] That this petition is filed not to harass, cause unnecessary delay, or

needlessly increase the cost of litigation but solely for purpose above-
established.

Page 9 of 17
 FURTHER, I hereby certify that I have not commenced any other
action or proceeding involving the same issues in the Supreme Court, Court of
Appeals, or any other tribunal or agency; to the best of my knowledge, no such
action or proceeding pending in the Supreme Court, the Court of Appeals or
any other tribunal or agency; that if I should thereafter learn that a similar
action or Proceeding has been filed or is pending before the Supreme Court,
Court of Appeals or any other tribunal or agency, I undertake to report such
fact within five (5) calendar days therefrom to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

_______________________ at Daet, Camarines Norte.

JOEL FERRER
Affiant

SUBSCRIBED AND SWORN to before me, this _________________

in Daet, Camarines Norte, by the affiant who exhibited to me her
___________________, that she is the same person who executed and
voluntarily signed the foregoing Verification with Certification of Non-Forum
Shopping before me and acknowledged that she executed the same.

Doc. No. ______

Page No. ______
Book No. ______
Series of 2023.
REPUBLIC OF THE PHILIPPINES
Fifth Judicial Region
REGIONAL TRIAL COURT
Branch ______
Daet, Camarines Norte

HEIRS OF FRANCISCO CIVIL CASE No.

FERRER represented by JOEL _____________________
FERRER, For: EX-PARTE PETITION FOR
Petitioners, REVIVAL OF JUDGMENT

-versus-

SIEGFREDO MAGANA and

ALL PERSONS CLAIMING
RIGHTS UNDER HER,

Respondent/s

Page 10 of 17
x--------------------------------------
x

JUDICIAL AFFIDAVIT
(PANG-HUKUMAN SINUMPAANG SALAYSAY)

I, JOEL FERRER, of legal age, Filipino, single, and a resident of

Brgy. Camagsaan, Capalonga, Camarines Norte, the plaintiffs’
representative in this case, state under oath as follows:

PREPARATORY STATEMENT

The person examining me is ATTY. CHRISTOPHER S. CADAG, held in

his office located at Gov. Panotes Ave. Brgy. VIII, Daet, Camarines Norte. I
am answering his question fully conscious, free from coaching or
intervention of any third person especially the examiner, that I do so oath
and may face criminal liability for false testimony and perjury.

ATTY. CADAG: We are offering the testimony of the witness in

order to prove:

a] That he is the representative of Heirs of Francisco Ferrer;

b] That the late Francisco Ferrer is the registered owner of a parcel of land
situated in Brgy. Del Carmen, Talisay, Camarines Norte containing an area
of 40,000 Square Meters embraced under Transfer Certificate of Title No. T-
10945.

c] That the petitioners sued the respondents for ejectment before the
Municipal Trial Court of Talisay, Talisay Camarines Norte docketed as
Civil Case No. 172 involving the property subject of this case.

d] That on September 07, 2006, the Honorable MTC-Talisay, Talisay,

Camarines Norte rendered a Decision in favor of the petitioners ordering the
respondents to vacate and surrender the subject land of this case to the
petitioners, among others.

e] That the aforementioned Decision of the MTC-Talisay was appealed by

the respondents before the Regional Trial Court Branch 38, Daet, Camarines
Norte docketed as Civil Case No. 7565 but the appellate court affirmed
through its Decision dated June 26, 2008 the appealed Decision;

f] That the Decision of MTC-Talisay was ordered executed pending appeal,

at the instance of the Petitioners, through Writ of Execution dated January
18, 2007 issued by RTC Branch 38, Daet, Camarines Norte;

Page 11 of 17
g] That the Writ of Execution and Writ of Demolition implementing the
Decision of MTC-Talisay, Camarines Norte was never implemented due to
causes attributable to the Respondents;

h] That the witness has capacity to sue, be sued, and he will identify and
authenticate evidences supporting his claim against the Respondents.

ATTY. CADAG: With the kind permission of the Honorable Court.

Q1: Alam mo po ba at labis na A1: Opo sir.

nauunawaan at naiintindihan na ang
mga sagot o salita mo sa
eksaminasyon, at pagtatanung na ito
at sinumpaan na ikaw ay maaring
sampahan ng kasong “perjury” o
pagsisinungaling kung ikaw ay
magbubulaan?

Q2: Pakitaas po ang inyong kanang A2: Opo sir.

kamay at saguting ang tanong ko:
”Sumusumpa ka ba na magsasabi ng
katotohanan at pawang katotohanan
lamang sa eksaminasyon o
patatanungang ito?”

ATTY. CADAG: The witness answered “OPO” sir after raising his right
hand

Q3: Sa anong linggwahe o salita mo A3: Sa english po.

nais gawin ang eksaminasyon na ito?

Q4: Could you please tell me why A4: Yes sir, I am here now sir to
are you here in my law office? give statements regarding my
complaint against Siegfredo
Magana and all persons claiming
rights under him, the herein
Respondents.

Q5: What is this complaint you are A4: This complaint is about the Ex-
referring to? Parte Petition for Revival of
Judgment sir.

Q6: So you are reviving a particular A6: Yes, sir. The Decision dated
judgment, am I right? September 7, 2006 of the
Municipal Trial Court of Talisay,
Camarines Norte in Civil Case No.
172.

Page 12 of 17
Q7: Do you have a copy of the said A7: Yes, sir. I have sir. this
Decision you are describing? (witness giving a copy of the said
Decision to Atty. Cadag)

ATTY. CADAG: At this juncture, we respectfully mark the Decision dated

September 7, 2006 of the Municipal Trial Court of Talisay, Camarines Norte
identified as EXHIBIT “C”

Q8: Now, Mr. Witness, can you A8: Yes, sir. It is about the case I
please tell us what is this Decision have filed in behalf of the Heirs of
all about? Francisco Ferrer against Siegfredo
Magana, and all persons claiming
rights under him.

Q9: What is this case you are A9: It is a case for ejectment in the
talking about? premises of the property registered
under the name of the late Francisco
Ferrer situated in Brgy. Del Carmen,
Talisay, Camarines Norte containing
an area of 40,000 Square Meters,
more or less.

Q10: You have said that it is A10: Yes sir. Here is the Owner’s
registered in the name of late Duplicate Copy of Transfer
Francisco Ferrer, do you have any Certificate of Title No. T-10945 (The
document of such registration? witness showing the said title to Atty.
Cadag)

Atty. Cadag: At this juncture, we respectfully mark the Owner’s Duplicate

Copy of Transfer Certificate of Title No. T-10945 identified as EXHIBIT
“B”

Q11: What happened next, if any, A11: The respondents appeal the
after the MTC-Talisay, Talisay, aforementioned Decision before the
Camarines Norte rendered it Regional Trial Court, Branch 38,
Decision? Daet, Camarines Norte docketed
therein as Civil Case No. 7565. On
our part as Plaintiffs, we filed our
Motion for Execution Pending Appeal

Q12: What happened next, if any? A12: Our Motion for Execution
pending Appeal was granted, hence,
on January 18, 2007, a Writ of
Execution subject the Decision of the
MTC-Talisay was issued by the RTC-
Branch 38. Regarding their appeal, on
June 26, 2008, the Honorable RTC-
Branch 38, denied the same and

Page 13 of 17
 affirmed the Decision of MTC-
Talisay, Camarines Norte.

Q13: Any document regarding this A13: Yes, sir. Here is the Certified
fact, Mr. Witness? True copy of the Writ of Execution
dated January 18, 2007, and Decision
dated June 26, 2008 of the both the
RTC-Branch 38, Daet, Camarines
Norte. (Witness showing the same to
Atty. Cadag)

ATTY. CADAG: At this juncture, we respectfully mark the Writ of

Execution dated January 18, 2007 and Decision dated June 26, 2008
identified as EXHIBIT “E” and EXHIBIT “D”, respectively.

Q14: Aside from these, are there A14: Yes sir. They even file an action
any other actions taken by the for Annulment of Judgment before
Respondents? the Honorable Court of Appeals
subject of which is the Decision of
MTC-Talisay, Talisay, Camarines
Norte with Motion to Litigate as
Indigent party.

Q15: What happened to this action A15: It was also Dismiss and Denied
of the respondents, if any? accordingly in the Court of Appeals’
Resolution dated July 23, 2009. Here
is the copy of Court of Appeals’
Resolution I am referring to.

ATTY. CADAG: At this juncture, we respectfully mark the Court of

Appeals’ Resolution dated July 23, 2009 identified as EXHIBIT “J”

Q16: You have said earlier that the A16: Yes, sir. Unfortunately, it was
Writ of Execution dated January not implemented.
18, 2007 was issued by the
Honorable RTC-Branch 38, Daet,
Camarines Norte, what happened
to the implementation of the said
Writ of Execution, if any?
Q17: How can you say so? A17: It was stated in the Sheriff’s
Reports dated February 02, 2007 and
March 21, 2007 of Sheriff IV Reynor
F. Ubalde.

Q18: Do you have a copy of this A18: Yes, sir. These are the Sheriff’s
Sheriff’s Reports you are Report I was talking about. (Witness
identifying? showing a Sheriff’s Report)

ATTY. CADAG: At this juncture, may we respectfully mark the Sheriff’s

Page 14 of 17
Reports dated February 02, 2007 and March 21, 2007 of Sheriff IV Reynor F.
Ubalde of RTC-Branch 38, Daet, Camarines Norte identified as EXHIBIT
“F” and “G”, respectively.

Q19: Do you have any idea why A19: Yes, sir. It was for reasons
the aforementioned Writ of attributable to the Respondents, which
Execution was not implemented? includes imposing conditions before
they leave and strongly resisting to
leave.

Q20: What happened next, if any,? A20: Sheriff Reynor F. Ubalde

recommended the issuance of Writ of
Demolition.

Q21: What happened next, if any? A21: On February 12, 2009, a Writ of
Demolition was issued by Presiding
Judge Wilfredo F. Herico of MTC-
Talisay, Talisay, Camarines Norte.
Here is a copy thereof. (Witness
showing the same to Atty. Cadag)

ATTY. CADAG: At this juncture, we respectfully mark the Writ of

Demolition dated February 12, 2009 identified as EXHIBIT “H”.

Q22: What happened to said Writ A22: It was likewise returned

of Demolition, if any? unsatisfied.

Q23: How can you say so? A23: It was stated in the Sheriff’s
Report of Sheriff IV Bonifacio C.
Reynaldo, Jr, RTC-OCC, Daet,
Camarines Norte.

Q24: Any document regarding this A24: Yes, sir. This is the Sheriff’s
fact? Report dated March 5, 2014 of Sheriff
IV Bonifacio C. Reynaldo, Jr,.
(Witness showing the same to Atty.
Cadag)

ATTY. CADAG: At this juncture, we respectfully mark the Sheriff’s Report

dated March 5, 2014 identified as EXHIBIT “I”.

Q25: After this, what happened A25: Up to this date, the Decision of
next, if any? the Municipal Trial Court of Talisay,
Talisay, Camarines Norte remains
unsatisfied.

Q26: What is your particular A26: I was duly constituted and

interest in this case, if any? authorized to file this case sir.

Page 15 of 17
Q27: Any document regarding this A27: Yes sir. This is my Special
fact? Power of Attorney dated February 6,
2005 acknowledged before Atty.
Arniel A. Dating.

ATTY. CADAG: At this juncture, we respectfully mark the Special Power of

Attorney identified as EXHIBIT “A”

Q28: Do you have anything to Q26: For now, no more. I will tell the
say? rest during the course of trial sir.

ATTY. CADAG: I have no further question, that will be all for the witness
your Honor.

IN WITNESS WHEREOF, affiant affixed her signature this ________

in Daet, Camarines Norte.

JOEL FERRER
Affiant
ID No. _______________

SUBSCRIBED AND SWORN to before me in Daet, Camarines Norte this

_________________ by the affiant who as satisfactorily proven to me her
identity and personally signed the foregoing Judicial Affidavit before me
and acknowledged that she executed the same.

Doc. No. _______;

Page No.________;
Book NO. _________;
Series of 2023.

ATTESTATION

I, ATTY. CHRISTOPHER S. CADAG, of legal age, a lawyer and

with office address at Gov. Panotes Ave., Brgy. VIII, Daet, Camarines
Norte, under oath state as follows:

Page 16 of 17
 That I am one of the counsels of record of the Petitioner in the above
entitled case;

That I personally examined Joel Ferrer, Petitioner-witness in Civil

Case NO. ___________ now pending before the Regional Trial Court,
Branch _______, Daet, Camarines Norte.;

That I hereby certify that I have faithfully recorded the questions I

asked on the said witness and the corresponding answers that he made; and

That I further certify that neither I nor any person then present
coached said witness regarding her answers.

IN WITNESS WHEREOF, I have hereunto set my hand this

_________________ at Daet, Camarines Norte.

ATTY. CHRISTOPHER S. CADAG

Affiant

SUBSCRIBED AND SWORN to before me on the date and place first

cited.

Doc. NO. ________;

Page NO. _________;
Book No. ________;
Series of 2023.

Page 17 of 17