Republic of the Philippines)

Antipolo City )s.s.

AFFIDAVIT

I, ARTEMIO E. PAGARIGAN JR, of legal age, married, resident of 5 Mansion

Road, Serra Monte, Filinvest East, Marcos Hi-way, Antipolo City, after having
been sworn in accordance with law, hereby depose and state that:

1. I am the Owner of a term investment insurance described as

“HealthInvest 10-Pay” under Policy Number 1018740710 issued by Philippine
American Life and General Insurance Company (“Philamlife”);

2. Sometime in 2015, I was offered a term investment insurance by Mr.

Antonio K. Celestino III, an accredited Philamlife insurance agent and a friend. I
was convinced to take out a “HealthInvest 10-Pay” with an annual premium
payment of Php 50, 177.02, Attached as Annex “A” is a copy of the policy issued
by Philamlife;

3. In view of my trust and confidence to Mr. Celestino, being a friend, I

always pay him in cash for the annual premium for the years 2015 and 2016.
Attached as Annex “B” and “C” are the receipts for the said periods;

4. Sometime in June 2017, I personally delivered my annual premium

payment in cash to Mr. Celestino at McDonald’s Marcos Hi-way, Antipolo City.
Simultaneous with the payment of my annual premium, my wife, Mona Lisa N.
Pagarigan also signed a new insurance contract (“HealthInvest 10-Pay”) in the
amount of Php 45,777.21. Attached as Annex “D” is a copy of my wife’s policy
also handled by Mr. Celestino;

5. For the year 2018, my wife met Mr. Celestino again in McDonald’s
Marcos Hi-way, Antipolo City to simultaneously deliver in cash our premium
payments of Php 50, 177.02 for my policy and Php 45, 777.21 for my wife’s policy.
Again, we trusted Mr. Celestino to remit the premium payments to Philamlife as
he did before;

6. In June 2019, we again simultaneously paid the premium to Mr.

Celestino for both our policies thru bank deposit to Mr. Celestino’s BPI Account
No. 002979-0028-34 per attached BPI deposit slip as Annex “E”;

7. However, sometime in October 2019, Philamlife introduced their ePlan,

an online customer portal where a policy owner can view, access and manage
their policies. I decided to enroll my policy but was unable to do so. I
immediately called the customer hotline of Philamlife and was informed that my
policy has lapsed for failure to pay the premium for 2019.

8. Upon further verification with Philamlife Customer Service Cubao

Branch, my wife was informed that it was the “rider provisions” for Accident,
Health and Critical Illness on my policy that have lapsed in 2019 for failure to
pay the 2019 premium. Further, the said rider provision was only reinstated in

1
October 2018, which means that it lapsed in 2017 but was re-instated only in
October 2018.

9. I called Mr. Celestino to verify the veracity of the statements given by

Philamlife but Mr. Celestino insisted that he did make the payments in 2019 at
SM Calamba and that the policy cannot lapse.

10. That considering that Mr. Celestino insisted that he did remit my annual
premium payment under Policy Number 1018740710, the rider provisions on
Accident, Health and Critical Illness should still be in force. It will be unfair on my
part if I cannot avail of the rider provisions which I paid an extra premium for if
Philamlife will consider it as lapse for reasons not due to my actions. I reiterate
that I have been religiously paying the annual premiums on my policy and has
not been in delay in the payments at any time.

11. That if there is an issue on “unremitted premium payments” between

Philamlife and their agents, the same should be resolved between them and
should not affect the policy of the owner. It must also be emphasized that
despite the claim of Philamlife that the rider provisions on my policy were
reinstated in 2018 or have already lapsed in 2019, I have not received any
notice to this effect.

12. Philamlife has not issued any notice that the rider provisions on my
policy lapsed in 2017 and was merely reinstated in 2018. I also did not receive
any notice in 2019 that the rider provisions lapsed. Hence, in this regard, I would
like to insist that the rider provisions on ACCIDENT, HEALTH and CRITICAL ILLNESS
should be considered in force or at the very least, for Philamlife to consider my
request to have it reinstated;

13. I am executing this Affidavit to attest to the truthfulness of the

foregoing statements and for whatever legal purpose it may serve.

IN WITNESS HEREOF, I am signing this Affidavit this ___ day of _____ 2020 in
Antipolo City.

ARTEMIO E. PAGARIGAN JR.

SUBSCRIBED AND SWORN TO BEFORE ME, this __ day of _____ 2020 in

Antipolo City, affiant exhibiting to me his _________________ as competent
evidence of identity and avowed under penalty of law the truthfulness of the
foregoing in accordance with the Rules on Notarial Practice.

Doc. No.
Page No.
Book No.
Series of 2020