REPUBLIC OF THE PHILIPPINES)

PROVINCE OF LA UNION ) S.S.

MUNICIPALITY OF SAN JUAN )
X- - - - - - - - - - - - - - - - - - - - - X

AFFIDAVIT OF WITNESS
(Elena Esperanza)

I, ELENA ESPERANZA, of legal age, Filipino citizen, married, and a resident

of and with postal address at Purok IV, Brgy. Carlatan, San Fernando City, La
Union, after having been duly sworn to in accordance with law do hereby depose
and state that:

1. I am the bookkeeper of THI PHUONG LOAN TRAN SALANGA relative

to her business undertakings in San Fernando City, La Union;

2. I am also her personal friend and a confidante;

3. I have personal knowledge as to her legal battles with his son Edmer
T. Salanga, who is contesting her share of ownership in the estate left
behind by her late husband, Teodoro N. Salanga, Jr.;

4. As it is now, Thi Phuong Loan’s have almost totally lost possession of

the properties left behind by his late husband because Edmer
Salanga has taken over possession and control of almost all of the
properties of the late Teodoro N. Salanga, Jr., through threat,
intimidation, harassment and violence against her despite the fact
that both of them were declared/appointed by the court as co-
administrators of all the properties included in the estate of the late
Teodoro N. Salanga; and except for the Salanga building where Thi
Phuong Loan is desperately fighting his son’s aggressive actions to
force her out of the property which incidentally is declared in her
name and the late Teodoro N. Salanga, Jr, she has nothing left to
manage;

5. Thi Phuong Loan is still holding on to her claims over the Salanga
building where she still lives but quite miserably because of the
actions of Edmer Salanga and his workers in making life for Thi
Phuong Loan uncomfortable and miserable to force her to give up,
which I know for a fact will not happen because according to Thi
Phuong Loan she will stay and will fight for her right over the
properties which she and her late husband acquired through the
fruits of their labor;

6. Recently, Edmer Salanga has succeeded in coercing the lessee of Thi

Phuong Loan over her property at Don Joaquin Street, Brgy. III, San
Fernando City, La Union to give up the lease and leave the property
being leased and subsequently, he unilaterally took over the property
from Thi Phuong Loan by forcibly excluding her from entering the
premises, which Thi Phuong Loan cannot do anything about but to
file a complaint for grave coercion against him;

7. As a result, Thi Phuong Loan is left with no property to manage and

to earn income from because Edmer Salanga had all the properties
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under his control and the only one left is the Salanga building which
Page

he wanted Thi Phuong Loan ousted by making her life miserable with

Affidavit of Witness ~ Elena Esperanza

 the help of the workers he hired and stationed at the Salanga
building, such as (i) cutting off her electricity,(ii) refusing entry to her
visitors, friends (including myself) and even workers whom she
contracted to fix her clogged sink and toilet bowl which to date
remains as such, (iii) locking her car by the steering wheel with a bar
lock which prevented Thi Phuong Loan from using her car for more
than a year, (iv) throwing out her personal belongings and foods, (v)
disconnecting and destroying her CCTV surveillance system and
other sort of things to make her life at the Salanga building
unbearable, miserable and helpless, all of which were intended to
force her to give up her claims and ultimately leave the property; and

8. Now that she has filed a case of grave coercion against Edmer
Salanga in conspiracy with his co-accused/respondents, Rino Miqui
and Elinor Dalidig, she now fears for her life all the more, such that
she is now staying temporarily in my place so that she can personally
attend to the complaint she filed without fear of being intimidated,
harassed and threatened by Edmer Salanga and his cohorts.

I am executing this affidavit to attest to the truthfulness of the foregoing

facts and circumstances and to support the material allegations of THI
PHUONG LOAN TRAN SALANGA (Mrs. Salanga) in her COMPLAINT-
AFFIDAVIT against EDMER T. SALANGA IN CONSPIRACY WITH HIS CO-
ACCUSED/RESPONDENTS, RINO MIQUI AND ELINOR DALIDIG FOR THE
CRIME OF GRAVE COERCION.

FURTHER AFFIANT SAYETH NAUGHT.

San Juan, La Union for San Fernando City, La Union this __ day of
______________________, 2021.

ELENA ESPERANZA
Witness/Affiant
____________________________________________

SUBSCRIBED AND SWORN TO before me a Notary Public for and in

_________________________________ this ___ day of _______________, 2021,
affiant exhibiting to me her competent proof of identity as stated below her
signature and printed name above.

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of _____.
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Affidavit of Witness ~ Elena Esperanza

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Affidavit of Witness ~ Elena Esperanza