That I, Anselmo Salinguhay, Filipino, of legal age, married and a
resident of Dap Dap Mactan, Lapu-Lapu City, Cebu, Philippines, after being duly sworn in a manner prescribed by law, hereby depose and say;
1. That I am the branch manager of Fredzon Appliance Center with
branch address at Basak, Lapu-Lapu City;
2. That on August 6, 2018, Ren Rose Ceriales bought a Haer
Refrigirator, 10 cuft. With model #HRF-D34CH, serial # 60700524, on installment basis, with reservation of title upon completion of payments;
3. That on October 6, 2018, Ren Rose Ceriales also bought a CAMEL
CHEST FREEZER WITH model # CRF-60F2, serial # TF-1B16040114, also on installment basis, with reservation of title upon completion of payments;
4. That the aforesaid appliances were withheld by a certain Kevin Kim
(respondent) known to be the owner of Red Coco Town located at Malinao, Agus, Lapu-Lapu City;
5. That I made a demand orally to surrender the unit to our possession,
but the respondent refuses to surrender the possession of the above- mentioned appliances, contending that they will use the proceeds to cover up the rental payables of Ren Rose Ceriales;
6. That I insisted that the ownership of the said units still belongs to FREDZON APPLIANCE CENTER, but our argument fell into the deaf ears of the respondent;
7. That I personally saw the current possession of the above-mentioned
units and I verified that the said units were in the possession of the Respondent Kevin Kim, as shown in the photograph and marked as Annex “A”;
8. That I am executing this affidavit in order to attest and affirm to the
truth of the foregoing facts and for whatever legal intents and purposes this may serve.
IN WITNESS WHEREOF, I have hereunto set my hand this
___________________, in Lapu-lapu City, Philippines. ANSELMO I. SALINGUHAY Affiant
SUSBCRIBED AND SWORN TO BEFORE ME this _____________________, in Lapu-
lapu City, Philippines. Affiant exhibited to me her Non-Professional Driver’s License No. G05-05-002512.