REPUBLIC OF THE PHILIPPINES

7th JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 17
Cebu City

Maria Pasar,
Plaintiff

- versus - Civil Case No.87000

Juan Flatwan, For: Replevin

Defendant

x--------------x

FORMAL OFFER OF DOCUMENTARY EXHIBITS

Defendant by counsel, and to this Honorable Court

most respectfully submits his documentary exhibits and
the purposes for which they are offered, as follows:

1. Exhibit “1”, “1-A” – This is the Judicial Affidavit

of the Defendant Juan Flatwan executed on August 13,
2018.

Purpose: This exhibit will serve as the direct

testimony of the Defendant and to prove the
allegations stipulated in the Answer.

2. Exhibit “2”, “2-A” – This is the Judicial Affidavit

of witness SPO3 PEDRO KOTONG executed on August 13,
2018.

Purpose: This exhibit will serve as the direct

testimony of the witness of the Defendant and is
 offered to corroborate that Defendant was indeed
involved in a vehicular accident

3. Exhibit “3” — This is the Certificate of Hospital

Confinement of Defendant Juan Flatwan issued by
Vicente Sotto Memorial Medical Center, showing the
date of Confinement which was February 26, 2018. The
Certificate also reflected the injuries sustained by
the Defendant and that he had undergone a surgery
which required him to be confined for 15 days to
fully recuperate. It is attached as Exhibit “A” in
the Judicial Affidavit.

Purpose:
This exhibit is offered to prove that Defendant
got involved in an accident in South Road Properties
(SRP) Tunnel, Cebu City while in the course of doing
his work which rendered him unable to return the
vehicle on that same day, and on the following days
thereafter, as agreed upon in the Employment
Contract.

4. Exhibit “4” — This is the screenshot of the Call logs

of the Defendant’s mobile phone, showing the number
of the Plaintiff. It is attached as Exhibit “B” in
the Judicial Affidavit.

Purpose:
This exhibit is offered to prove that Defendant
did inform the Plaintiff that the he was involved in
a vehicular accident and that the motorcycle was in
the custody of CITOM.

5. Exhibit “5” — This is the Police Report executed by

SPO3 Pedro Kotong referring to the vehicular accident
which Defendant was involved.

Purpose:
 This exhibit is offered to prove that the
Defendant was indeed involved in an accident and that
the vehicle was towed and impounded by the CITOM.