MAE SHELL

1. Q. Could you tell the court your name.

A. I am the complainant Nadine R. Llustre.

2. Q. And your age.

A. I am 45 years old.

3. Q. Where do you live?

A. I am a resident of L-17, B-10, Blue Bells St., Malunggay Subdivision, Davao City.

4. Q. How long have you been a resident of Davao City?

A. For almost 35 years. I am born and raised in Davao City.

5. Q. What is your profession?

A. I am a business woman and had also licensed nurse.

6. Q. What is your business?

A. I have my own online business.

7. Q. What do you sell in your online business?

A. I sell second hand cars.

8. Q. Moving to your complaint, Do you know any Erich Gonzales?

A. Yes I know her. She was my classmate in highschool. And, she was the one who offered me to buy lands from
HUNGHONG HIKAP DEVELOPMENT CORPORATION.

9.Q. How long have you known her?

A. I have known her for almost 20 years already that’s why I trusted her already.

10. Q. What happened next if any?

A. Erich offered me to buy lands on the year October 2003.

11. Q. What is the relationship of Erich Gonzales with HUNGHONG HIKAP DEVELOPMENT CORPORATION?

A. She was an agent of such company.

JIMAY DABOAN
EDWARD

1. Can you please tell to this Honorable Court what transpired between you and Hunghong Hikap
Development Corporation(HHDC) on October 22, 2003?
A: We executed two(2) Deeds of Sale with Reservation of Title.

2. I am showing to you two documents entitled "Deed of Sale with Reservation of Title", are these the same
documents that you and HHDC executed?
A: Yes. They are the same document.

3. What were the Blocks covered under the two Deeds of Sale?
A: Blocks 9 and 11.

4. For Block 9, what were the lots covered?

A: Lots 6,7,8 and 9 covering a total area of 600 square meters more or less.

5. And how much was the consideration paid for the lots covered in Block 9?
A: It was P210,000.

6. For Block 11, what were the lots covered?

A: Only Lot 9 covering an area of 171 sqaure meters more or less.

7. And how much was the consideration paid for the lot covered in Block 11?
A: It was P59, 850.

EVIOTA

1. When respondent delivered the TCTs to you what did you observed?

A. They are not the same subdivision lots that I purchased.

2. How did you know that it was not the same?

A. I inspected the title and I noticed that the TCT nos. and the description of the lots were different.

3. What happened next if any?

A. the other title for the 5th lot was not delivered to me despite repeated demands.

4. In what way did you demanded for the title?

A. I called them and reminded them to deliver the title (og pag mention lang og mga ways na nagdemand ka para
ihatag tong title)

5. What happened next after the repeated demands?

A. Still they did not deliver the title, so I went to my lawyer to ask for an advice about the matter

6. What did your lawyer tell you?

That Kathryn O. Bernardo, breached the mandate of PD no. 957 by delivering the titles of subdivision lots which
are completely different from that actually purchased by herein complainant. The other title for the fifth lot was
not delivered to complainant despite repeated demands.

Respondents’ failure to comply with the statutory obligation provided by Section 25 of P.D. No. 957 is a blatant
violation of the provisions of the said law and such transgression must be rectified by imposing upon them the
sanctions

GENERALAO

1. After you paid the entire purchase, what happened?

Titles were delivered to me but such titles were not the ones I paid for.

2. What did you do next?

I sent a demand letter to respondents to rectify the breach of its reciprocal obligation by delivering to me
the correct TCTs.

3. Who sent the demand letter?

It was my counsel.

4. What did the respondents do after receiving the demand letter?

They did not do anything because they refused to comply.

GUTIERREZ

1. Ms. Witness, after you received a copy of the 4 Transfer Certificates of Title, what were your actions, if any?

-I contact my friend who was a Geodetic Engineer to come with me, along with his assitants to Samal
and bring along with them the necessary equipment to assist me with my ocular inspection
because I was highly doubtful with the TCT’s given to me by the corporation since there
were discrepancies with the Deed of Sale and with the Ownership document previously given to me.

2. What did your friend who was a Geodetic Engineer found out when he assisted you with the ocular
inspection?

-That the previous lots pointed to me by Erich were not the same
lots contained in the 4 TCT’s. The description in the Title did not match the dimensions of the property.

3. How did you find the lots which were described in the 4 TCT’s?

-With the details pointed out in the TCT’s, the equipment showed a different area which was
approximately more than an hour away from the area previously endorsed to me.

4. Can you please describe the area?

-The property was undeveloped since it was a highly forested area and it was hard to reach the area
considering that we had to use a motorcycle to reach the property.

5. What did you do after you found out that the lots previously described to you by Erich were not the same
properties as indicated in the TCT’s?
 -I tried to contact Erich and Kathryn but they did not respond. Even to my text messages. That’s why I
opted to go to my lawyer and seek legal help.

SALAZAR