Republic of the Philippines

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
Baguio City
Branch 6

CLAIRE ANN GARCIA

-Plaintiff Civil Case No. 7082-R

FOR

-versus- COLLECTION OF SUM

OF MONEY
MARGARET C. RAROQUE
-Defendant
x-----------------------------------x

JUDICIAL AFFIDAVIT OF DEFENDANT MARGARET

RAROQUE ON DIRECT EXAMINATION

COMES NOW THE DEFENDANT, MARGARET RAROQUE unto

this Honorable Court, in support of her defense against the above
entitled complaint respectfully states that:

1. The herein affiant-witness is MARGARET C. RAROQUE,

is of legal age, married, and with address at No. 8 Suello
Village Marcos Highway, Baguio City, Philippines;

2. Atty. RODEL D. GALLETO is the lawyer who conducted

and supervised the examination of said affiant-witness
whose testimony was taken and held at his law office
located at 3RD Floor, Jose Miguel Building, Abanao St.,
Cor. Yandoc St. Baguio City;

3. The affiant-wtiness is answering the questions asked of

her fully conscious and that she does so under oath, and
that she may face criminal liability for false testimony or
perjury, and hereby declares under solemn oath that:

“I am, MARGARET C. RAROQUE, 67 years of age,

Filipino citizen, single, and with residence at 264 SLU-SVP
Housing Project, Bakakeng, Baguio City, Philippines ,
executes this Judicial Affidavit, the contents of which
were explained to me in the English and Pilipino language
all of which I know, speak and understand. I am fully
aware that I am answering the questions asked of me
 under oath and any untruthful statement that I make
thereon may subject me to a criminal prosecution for
perjury or giving false testimony. Answering truthfully, I
hereby state that:

And by way of OFFER OF TESTIMONY, herein states, that:

By way of offer, herein witness is being presented in this case

to prove and testify on the following matters, to wit:

1. To testify on the facts and circumstances involved in her

contractual relationship with the plaintiff in this case;
2. To identify the answer she prepared in response to the
complaint filed by the plaintiff against her that shall form
part of her direct testimony;
3. To identify the pertinent documents in her defense
against the complaint of the accused;
4. To testify on other matters relating to the above entitled
case;
5. All these to prove that the plaintiff is not entitled to the
reliefs prayed for in her complaint.

WITH THE KIND PERMISSION OF THE HONORABLE COURT:

1. A: You mentioned that you are Margaret Raroque, is that

correct madam witness?
Q: Yes, sir.;

2. Q: How are you related to the Margaret Raroque who is the

defendant in this case?
A: I am the defendant Margaret Raroque, sir.;

3. Q: Will you tell me who is the complainant in this case

madam witness?
A: The complainant is Architect Claire Ann Garcia, sir.;

4. Q: Will you tell me who is Architect Claire Ann Garcia madam

witness?
A: Architect Claire Ann Garcia is the contractor who
undertook to renovate my house at #8 Suello Village,
Marcos Highway, Baguio City;

5. Q: And will you tell me why Architect Claire Ann Garcia filed
this case against you in court if you know, madam
witness?
A: Architect Claire Ann Garcia filed this case against me in
 court because she claims that I owe her money for
additional works conducted that is over and above the
contractual agreement we have entered into, sir.

6. Q: And what can you say about the claim of the

complainant?
A: I do not owe the complainant, sir.

7. Q: And why is that madam witness?

A: I do not owe the complainant because after paying her a
substantial portion of the contract price agreed upon for
the renovation of my house she and her workers
abandoned the project unfinished, sir;

8. Q: So what did you do when you found out that a complaint

had been filed against you by Architect Claire Ann Garcia,
madam witness?
A: I caused the preparation of my answer to her complaint,
sir;

9. Q: And where is this answer you are referring to madam

witness?
A: It is attached to the records of the case sir;

10. Q: And the complaint?

A: It is also attached to the records of the case, sir.

11. Q: Now if shown to you a copy of the complaint will you be

able to recognize it madam witness?
A: Yes, sir. (The complaint shall be identified by the witness
at the time she is presented for the taking of his
testimony before the Honorable Court considering the
circumstantial constraint that prevents the identification
of the document at the time of the taking of this
affidavit);

12. Q: Now, if you were shown a copy of the answer you made
to the complaint filed against you by Architect Claire Ann
Garcia will you be able to recognize it?
A: Yes, sir;

13. Q: Now madam witness, do you affirm the allegations

contained in the answer you have filed that is attached to
the records of the case?
A: Yes, sir;
14. Q: And what would you like for the Honorable Court to do
with the answer you identified?
A: I would like for the Honorable Court to consider the
answer I have identified to form part of my direct
testimony against the complaint filed against me, sir;

15. Q: Do you have anything more to add madam witness?

A: When the plaintiff left the project, I had to find someone
else to finish the work they have abandoned, that
amounted more than the retention amount as provided
for in the contract we entered into with the plaintiff;

16. Q: Is there anything else you would like to add?

A: None, sir.

17. Q: Will you voluntarily sign this Judicial Affidavit?

A: Yes I will, sir.

MARGARET C. RAROQUE
Affiant

SUBSCRIBED AND SWORN to before me, this 30th day of June

2014, in the City of Baguio, Philippines, affiant is personally known to
me.
Doc. No. ___;
Page No. ___;
Book No. ___;
Series of 2014.

LAWYER’S ATTESTATION

I, RODEL D. GALLETO, of legal age, Filipino citizen and with office address
at 3RD Floor Jose Miguel Building, Abanao Street Corner Yandoc Street, Baguio
City, Philippines, under oath attest that:
 1. I am the lawyer who propounded the questions on direct
examination of the witness Margaret C. Raroque;
2. I faithfully recorded or caused to be recorded in her judicial
affidavit the questions asked of her and the corresponding answers
she gave thereto;
3. In the course of asking her questions, neither I nor any other
persons present or assisting me in the examination coached her
regarding her answers.

IN WITNESS WHEREOF, I have hereunto set my hand this 30 th day of

June, 2014 in the City of Baguio, Philippines.

RODEL D. GALLETO

SUBSCRIBED AND SWORN to before me this 30th day of June, 2014 in

the City of Baguio, Philippines by the affiant who exhibited to me IBP
Identification Card with roll number 54542.

Doc. No. ___;Page No. ____;

Book No. ___; Series of 2014

Copy furnished:

Atty. JUDY T. CALSI

Counsel for the Plaintiff
No. 16 Loro Street,
Dizon Subdivision,
Baguio City

STEVEN C. RAROQUE

EXPLANATION

A copy of the foregoing judicial affidavit is being filed with the Honorable
Court, and the served a copy to the counsel for the plaintiff by registered mail in
consideration of the lack of personnel at the office.

STEVEN C. RAROQUE