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REPUBLIC OF THE PHILIPPINES

National Capital Region


Regional Trial Court
Branch 23
Naga City

Civil Case No. P2117


For: Damages for death,
earning Capacity, moral
damages and attorneys fees

NENA E. LANUZO
Plaintiff,

Versus -

BJDC CONSTRUCTION COMPANY,


REPRESENTED BY ITS MANAGER/PROPRIETOR
JANET S. DELA CRUZ
Defendant,
x-------------------------------------x

JUDICIAL AFFIDAVIT
OF
HONESTO CRUZ
This Judicial Affidavit of Honesto Cruz, who is working in the Barangay as a
Barangay Captain of San Agustin, Pili, Camarines Sur in the year 1997, is executed
to serve as his direct testimony in the instant case.
This Judicial Affidavit is being offered to prove the following:
A.) The allegation that the construction company did not provide adequate
lighting on the construction site.
B.) All other related matters, facts and circumstances relevant and material to
this case.

This Judicial Affidavit was taken at the office of Atty. Leila Desampu at #68 Tiwala
St., San Agustin, Pili, Camarines Sur.
Questions were propounded by Atty. Leila Desampu and questions are numbered
consecutively and each question is followed by an answer of the witness.
-

1. Do you swear to tell the truth and nothing but the truth?
I do.
2. Are you aware that you can face criminal liability for false testimony or

perjury if you will not tell the truth?


I am aware.
3. Please state your name, age, and address.
I am Honesto Cruz, 32 years old, #14 Magiting St., San Agustin, Pili, Camarines
Sur.

4. What is your job in the Barangay City Hall?


I am the Barangay Captain of Barangay San Agustin.

5. Do you know BJDC Construction company?


Yes.

6. How did you come to know Bjdc?


- They have a big tarpaulin in the construction site of the national high way.
-

7. What kind of construction are they doing?


A road re-blocking project.

8. Do they have warning signs and lights installed?


Yes.
9. I am showing you these pictures, herein referred to as Annex A. Do you

recognize this picture?


Yes.

10.What are these pictures?


These are the pictures of the construction site at night time.

11.Who took these pictures?


Me.

12.When did you take these pictures?


The first picture was on September 15, second was on September 28, third was
on October 16, fourth was on October 30 and the fifth was on November 11.
13.Why did you take these pictures?

Because there were several concerned citizens that went to my office on


different occasions and told me that the construction site was not adequately
lighted and might be dangerous for the motorists and nearby residents
especially at night.

14.Was the construction site adequately lighted?


No. It is very clear on the pictures I have taken.
15.What did you do when you confirmed that the construction site was not

adequately lighted?
I informed the Flagman on the construction site and the manager of BJDC Ms.
Janet Dela Cruz that there werent enough illumination on the construction site
and to add more light to adequately light the construction site.

16.Was there any improvement in the lighting of the construction site?


- No.
17.Did the BJDC Construction Company attempt to communicate to you
-

regarding the said issue?


No.

Further Affiant Sayeth None.


IN WITNESS WHEREOF, I have hereunto affixed my signature this ____ day of
___________, 1998 at San Agustin, Pili, Camarines Sur.
Honesto Cruz
Affiant
SUBSCRIBED AND SWORN to this _____ day of ___________, 1998 at San
Agustin, Pili, Camarines Sur, Philippines.
Mani Vargas
NOTARY PUBLIC
Until December 31, 1998
PTR No. 906670 - Jan. 3,
1999
IBP No. 938100
Roll No. 142366
SWORN ATTESTATION

The undersigned hereby attests that, as counsel of the witness, he faithfully


recorded the questions he asked and the corresponding answer of the witness
and that he did not coached the
Witness answers to the questions propounded.
Leila Desampu
Counsel for the Witness
Roll of Attorneys No. 512345
PTR No. 26-26-0-10, 04/23/07
IBP No. 910205, 4/11/07, Manila
Admitted to the Philippine Bar - April
11, 2009

SUBSCRIBED AND SWORN to this _____ day of ___________, 1998, at San


Agustin, Pili, Camarines Sur.