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Republic of the Philippines


11th Judicial Branch
Branch ___
Davao City


Plaintiff, CIVIL CASE NO. 004-08
-versus FOR: Damages and Attorney’s
The testimony of the witness is offered to prove the following:
1. To prove that she was a passenger of the Davao Rabbit Bus
vehicle bearing the plate No. 246 at the time of the herein incident;
2. To prove that Benjamin Bigat had carefully driven the said bus
when he negotiated it while traversing the intersection of Sandawa
Road and Macarthur Highway, Matina, Davao City;
3. To prove that it was the reckless driving of Rolando Suizo, the
driver of KB Hino Cargo truck that caused the accident;
4. To prove that she and other passengers sustained physical injuries
as a result of the accident;
5. To prove that Rolando Suizo was the proximate cause of the

Republic of the Philippines }

City of Davao } ss.


I, ANGEL LOCSIN, Filipino, of legal age, married, a teacher, and a

resident of Sparrow Street, Ecoland, Davao City, after having been
sworn to in accordance with law, do hereby depose and state that:
1. I was examined by ATTY. HANNAH CYNDALL JARDINEL who
is holding office at JARDINEL ARAFOL VEGA and ACOSTA
Law and Accounting Firm, Landco, J.P. Laurel Avenue, Davao
City, Philippines, in the said office;

2. I answered the questions the examining lawyer asked fully

conscious that I may face criminal liability for false testimony
and perjury.

3. The following questions she asked and my corresponding

answers were the following:

1. Q: Please state your name and other personal

circumstances for the record.
A: I am Angel Locsin, Filipino, of legal age, married, a
teacher and a resident of Sparrow Street, Ecoland, Davao
Q: Palihog sa pagsaysay sa imong ngalan ug lain pang
kinaugalingong detalye para sa record.
A: Ako si Angel Locsin, Pilipino, sa hustong edad, kasado, isa
ka magtutudlo ug nakapuyo sa Sparrow Street, Ecoland
Davao City
2. Q: Are you the same Angel Locsin who is named as a
witness for the plaintiff in this case?
A: Yes.
Q: Ikaw ba ‘tung Angel Locsin na ginganlan na testigo
para sa tagdemanda ani nga kaso?
A: Oo.
3. Q: How are you connected with Davao Rabbit Bus Line
Inc.; the plaintiff in this case?
A: Regular passenger
Q: Unsa imong koneksyon sa Davao Rabbit Bus Line,
ang tagdemanda ani nga kaso?
A: Regular na pasahero
4. Q: Can you tell me about your whereabouts on the
morning of October 26, 2016.
A: I left my house around 6am to go to work.
Q: Palihog pakisaysay kung asa ka sa buntag adtong
Oktubre 26, 2016.
A: Nihawa ko ug balay mga alas otso sa buntag padulong
sa akong trabahuan

5. Q: What is regular route when going to your workplace

and what do you ride?
A: From my house, I usually ride a bus at the Ecoland
Terminal. I ride the bus going to Tagum.
Q: Unsa ang rota na imong ginasakyan kung padulong
ka sa imong trabahuan ug unsa ang imo ginasakyan?
A: Gikan sa akong balay, musakay kog bus sa Ecoland
Terminal. Akong ginasakyan kay katong bus na padulong

6. Q: Where will the bus usually pass from the Ecoland

Terminal and where is your desitnation?
A: It passes by Sandawa, then to Quirino straight to
Dacudao. My destination is at Buhangin Elementary School.
Q: Asa kasagaran naga agi ang bus gikan sa Ecoland
Terminal ug asa ka naga naog?
A: Muagi ang bus sa Sandawa pagkahuman sa Quirino, dire
diretso sa Dacudao. Munaog ko sa Buhangin Elementary
7. Q: When you were inside the bus on that specific day,
how was the driving of the bus driver?
A: The driver was very calm in his driving to the point that I
could stand to read the notes I was about to teach on that
day. Everything was so smooth.
Q: Katong naa na ka sa sulod sa bus, unsa ang
pagmaneho sa drayber?
A: Kalmado kaayo ang iyang pagmaneho, nakabasa pa gani
ko sa akong mga gisuwat para itudlo sa kato nga adlaw.
Malinawon kaayo ang tanan
8. Q: Do they always drive like that?
A: Yes. In fact, I always choose their bus line because I have
always trusted their drivers.
Q: Pirminte ba ingon ana ilang pag maneho?
A: Oo. Ang tinuod, sila gyud akong ginapili na bus line kay
naa koy salig sa ilang mga drivers.

9. Q: How many passengers were with you during that day?

A: Around 30 to 35.
Q: Pila ka pasahero ang misakay kuyog nimo katong
A: Mga 30 to 35.

10. Q: Were there any collisions in the duration of your

travel? If so, where did it happen?
A: Yes. I was so shocked when I heard a loud bumping noise
and when our bus was moved. It happened at Sandawa
Q: Naa ba’y nahitabong pagbangga samtang ga byahe
mo? Asa banda nahitabo?
A: Oo. Nakuratan ko katong nakadungog ko ug kusog na
tingog sa pagbangga ug katong na isbog among bus.
Nahitabo ni sa Sandawa crossing.

11. Q: How did this happen?

A: The bus was just on its lane running within the speed limit
when suddenly an overspeeding truck swerved, thereby
occupying the bus’ lane.
Q: Giunsa ni pagkahitabo?
A: Naa lang sa iyang linya ang bus, nagdagan sa speed limit.
Kalit lang nay overspeeding na trak nga ni swerve ug nisakop
sa linya sa bus.

12. Q: To what extent was the bus damaged?

A: The bus was severely damaged from its front portion to the
Q: Unsa ka dako ang damyos sa bus?
A: Grabe ang damyos sa bus gikan sa atubangan hantod sa
tunga-tunga sa.

13. Q: What happened to the passengers of the bus?

A: We were all shocked. Some were crying while those who
were seated at the left side of the bus got severely injured
from the collision.
Q: Naunsa ang mga pasahero sa bus?
A: Kalit mi nangalisang. Ang uban gahilak samtang katong
mga nakalingkod sa wala na bahin sa bus kay samdan gikan
sa pagbangga.

14. Q: What happened after the collision?

A: 911 hurriedly came and brought those who were injured to
the hospital including me.
Q: Unsa nahitabo paghuman sa pagbangga?
A: Miabot dayon and 911 ug gidala ang mga samdan sa
hospital, apil ko didto.

15. Q: What did you do at the hospital?

A: We had ourselves examined for the injuries. Others were
treated with their open wounds.
Q: Unsa inyo gibuhat sa tambalanan?
A: Nagpa-eksamen mi ug ang uban gi hinluan ug gi ayo ilang
mga samad.
IN WITNESS WHEREOF, I have hereunto set my hand this 15th
day of February 2017 at Davao City.


and for Davao City this 15th day of February 2017. Affiant personally
came and appeared with SSS No. 567893 issued on March 4, 2001 at
Davao City, bearing her photograph and signature, known to me as the
same person who personally signed the foregoing instrument before me
and avowed under penalty of law to the whole truth of the contents of
said instrument.

Doc. No. _________;

Book No. __________; Notary Public
Series of 2017. Until December 31, 2017
PTR No. 7856783, 07/16/16, Davao
City, IBP No. 1041534, 07/4/16,
Davao City Chapter
Roll of Attorneys No. 65820
, TIN No. 188-096-654
MCLE Compliance No. II-0987654

I, HANNAH CYNDALL JARDINEL, of legal age, Filipino, single,

and a resident of Hillside Subd., Bajada Davao City, Philippines with
office address at JARDINEL ARAFOL VEGA and ACOSTA Law and
Accounting Firm, Landco, J.P. Laurel Avenue, Davao City, Philippines,
under oath hereby STATES that:

1. I conducted and supervised the examination of Mrs. Angel

Locsin as witness of the above-entitled case;

2. I faithfully caused to be recorded the questions I asked and the

corresponding answer that the witness gave; and

3. Neither I nor any other person then present or assisting me

coached the witness regarding his answers.

IN WITNESS WHEREOF, I affix my signature this February 15,

2017 at Davao City, Philippines.



SUBSCRIBED AND SWORN TO before me, a Notary Public of

Davao City, Philippines, this 15th day of February 2017, Hannah Cyndall
Jardinel exhibiting to me her Driver’s License No. L-04-45676587 valid
until December 12, 2019 bearing her photograph and signature as
completed proof of her identity.


Page No. ___; Notary Public
Book No. ____; Until December 31, 2017
PTR No. 7853783, 07/11/16, Davao
Series of 2017.
City, IBP No. 1041535, 07/15/16,
Davao City
Roll of Attorneys No. 65823
TIN No. 188-096-638
MCLE Compliance No. II-098765