REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 85, QUEZON CITY

PPC ASIA CORPORATION,

Plaintiff,

-versus- Civil Case: R-QZN-17-133912-CV

For: Collection of Sum of Money

PINEDA RN AUTO SUPPLY AND

GENERAL MERCHANDISE &
ROLANDO NEMIS PINEDA AND
MARITES MERCADO PINEDA,
Defendants.
x------------------------------------------x

FORMAL OFFER OF EVIDENCE

Plaintiff, by counsel, to this Honorable Court, respectfully

submits its formal offer of evidence, thus:

As part of the testimony of witness ZEUS T. TADEO, the

following documentary exhibits are being offered in evidence, to wit:

1. EXHIBITS “Exhibits “A”, “A-1” and “A-2” – Credit

Term Application Form (CTAF) and DTI Permit and Mayor’s
Permit.
PURPOSE: To prove that Ronaldo N. Penida is the registered
owner and proprietor of Pineda RN Auto Supply.

2. EXHIBITS “B” and “B-1”– Delivery Receipt No. 12753

and the Conditions of Delivery therein below.
PURPOSE: To prove that automobile products in the total
amount of Php203,972.00 was delivered and duly received by
Pineda Rn Auto Supply on February 2, 2012.
3. EXHIBITS “C” and “C-1”– Delivery Receipt No. 12817
and the Conditions of Delivery therein below.
PURPOSE: To prove that automobile products in the total
amount of Php34,958.00 was delivered and duly received by
Pineda RN Auto Supply on February 7, 2012.

4. EXHIBITS “D” and “D-1” – Delivery Receipt No.

13057 and the Conditions of Delivery therein below.
PURPOSE: To prove that automobile products in the total
amount of Php71,604.00 was delivered and duly received by
Pineda RN Auto Supply on February 18, 2012.

5. EXHIBITS “E” and “E-1” – Delivery Receipt No. 13164

and the Conditions of Delivery therein below.
PURPOSE: To prove that automobile products in the total
amount of Php98,860.00 was delivered and duly received by
Pineda RN Auto Supply on February 20, 2012.

6. EXHIBITS “F” and ‘F-1”– Front and dorsal portion of

Allied Bank Check No. 0130599.
PURPOSE: To prove that check payment was initially made
by Plaintiff Maritess N. Pineda, but the same was dishonored
upon presentment for payment.

7. EXHIBITS “G” and “G-1”– Front and dorsal portion of

Allied Bank Check No. 0130598.
PURPOSE: To prove that check payment was initially made
by Plaintiff Maritess N. Pineda, but the same was dishonored
upon presentment for payment.

8. EXHIBITS “H” and “H-1”– Front and dorsal portion

of Security Bank Check No. 0011050.
PURPOSE: To prove that check payment was initially made
by Plaintiff Maritess N. Pineda, but the same was dishonored
upon presentment for payment.

9. EXHIBITS “I” and I-1”– Front and dorsal portion of

Security Bank Check No. 0011049.

2
PURPOSE: To prove that check payment was initially made
by Plaintiff Maritess N. Pineda, but the same was dishonored
upon presentment for payment.

10. EXHIBITS “J” and “J-1”– Front and dorsal portion of

Security Bank Check No. 0011101.
PURPOSE: To prove that check payment was initially made
by Plaintiff Maritess N. Pineda, but the same was dishonored
upon presentment for payment.

11. EXHIBITS “K” and “K-1” - Front and dorsal portion of

Security Bank Check No. 0011100.
PURPOSE: To prove that check payment was initially made
by Plaintiff Maritess N. Pineda, but the same was dishonored
upon presentment for payment.

12. EXHIBITS “L” and “L-1” - Front and dorsal portion of

Security Bank Check No. 0011099.
PURPOSE: To prove that check payment was initially made
by Plaintiff Maritess N. Pineda, but the same was dishonored
upon presentment for payment.

13. EXHIBITS “M” and “M-1” - Front and dorsal portion

of Security Bank Check No. 0011098.
PURPOSE: To prove that check payment was initially made
by Plaintiff Maritess N. Pineda, but the same was dishonored
upon presentment for payment.

14. EXHIBITS “N” and “N-1” - Front and dorsal portion

of Security Bank Check No.0011097.
PURPOSE: To prove that check payment was initially made
by Plaintiff Maritess N. Pineda, but the same was dishonored
upon presentment for payment.

15. EXHIBITS “O” and O-1 – Demand Letter dated

October 3, 2016 and the signature of Mr. Pineda thereon.

3
PURPOSE: To prove that PPC Asia Corporation sent a formal
demand to Pineda RN Auto Supply for the payment of the
latter’s outstanding obligation to the former and was received
personally the subject demand letter by Mr. Ronald N.
Pineda, himself.

16. EXHIBITS “P” and “P-1” - Affidavit of Personal Service

executed by Credit and Collection Manager, Zeus T. Tadeo.
PURPOSE: To prove that BC Villaseñor Construction duly
received the subject demand letter on October 20, 2016.

16. EXHIBITS “Q” and “Q-1” – Statement of Account.

PURPOSE: To prove that PINEDA RN AUTO SUPPLY has an
outstanding obligation to pay PPC Asia Corporation in the total
amount of Php409,394.00.

17. EXHIBITS “R” and R-1”– Affidavit of Transaction

executed by Credit and Collection Manager, Zeus T. Tadeo.
PURPOSE: To prove that based on facts and records, Elvis Jr.
Battery Shop has an existing unpaid obligation to PPC Asia
Corporation in the total amount of Php901,748.37, and that the
latter has continually exerted efforts to collect payment of the
same.

18. EXHIBITS “S” and “S-1”- Official Receipts No. 5123605

and No. 5123606.
PURPOSE: To prove that the herein plaintiff actually paid the
filing fee for the institution of this civil action.

19. EXHIBITS “T,” and “TA-1”– Judicial Affidavit of

Witness Zeus T. Tadeo, and his signature on page 17 thereof.
PURPOSE: To prove that that on different occasions,
defendants ordered and received various automobile products
from the plaintiff corporation; that several demands, sufficient
time and a number of chances were afforded the defendants,
however, the latter’s obligation to the plaintiff still remained
unpaid; and that there is actual and meritorious bases for the
collection of sum of money.

4
 With the formal offer of documentary exhibits, the plaintiff,
thru counsel, is now closing its evidence. And upon admission of the
same, it moves that the case be respectfully submitted for decision.

Quezon City, January 29, 2020.

ATTY. APRIL FLEURENZ ROSE C. MACALANDA

Counsel for the Plaintiff
4/F PPC Tradenology Center
1008 Quezon Avenue, Quezon City
Cellphone No. 0917-174-8142
PTR No. 9264613, 1/7/20, QC
IBP No. 104223, 1/8/20, QC
SC Roll No. 64529
MCLE VI-0011533

Copy Furnished:

Atty. Ricky G. Ty
Ty and Tupas Law Offices
Counsel for Defendants
Unit 5B, 5/F Unioil Center Building
Acacia Avenue cor. Commerce Ave.,
Madrigal Business Park
Ayala-Alabang, Muntinlupa
.

5
 EXPLANATION

The foregoing Judicial Affidavit was served thru LBC due to lack
of messengerial services to effect personal service.

APRIL FLEURENZ ROSE C. MACALANDA