REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

City of Cebu
Branch 12

PAULA COELHO,
Plaintiff, CIVIL CASE No. 894112
FOR: Unlawful Detainer
-versus -

NICO MACHIAVELLI,
Defendant.

x- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -x

JUDICIAL AFFIDAVIT OF PAULA COELHO

(Pursuant to A.M. No. 12-95-07-SC)

I, PAULA COELHO, Filipino, of legal age, single and currently residing at Block
3, Lot 1, Northwoods Residences, Lahug, after having been sworn to in accordance with
the law, do hereby depose and state:

PRELIMINARY STATEMENT

That conformably with Section 3(b) of A.M. No. 12-95-07-SC, I state that Atty.
Justin Ross C. Alesna is the counsel who conducted and supervised my examination as
a witness at his office in the University of San Jose-Recoletos, Main Campus, Cebu
City, Cebu;

That conformably also with Section 3(c) thereof, I hereby state under pain of
perjury that I am answering the questions propounded, as appearing herein below, fully
and conscious that I do so under oath and that I may be criminally liable for false
testimony or perjury.

PURPOSE: This affidavit / testimony of plaintiff, PAULA COELHO, is being offered to

prove that Nico Machiavelli, herein defendant, is not lawfully entitled to the possession
of the residential townhouse owned by the plaintiff in which the defendant has been
occupying by virtue of a contract of lease which has now been nullified in view of the
latter’s failure to religiously pay his leasehold rentals; thus, the existence of a cause of
action for unlawful detainer suit.

Q1: Do you know Northwoods Residences Subdivision?

A1: Yes.

Q2: Do you own the specific residential house located in Block 1,

Lot 3 in the said subdivision?
A2: Yes, I inherited it from my parents.
 Q3: Do you know the defendant?
A3: Yes, he is Nico Machiavelli. He is the lessee, occupying the
subject property.

Q4: When was it leased?

A4: It was on November 3, 2011 for a consideration of P15,000.00
a month as rental.

Q5: Was the defendant still paying the monthly rental fees?
A5: No, the defendant failed to pay the agreed rental fees for
several months starting February 19, 2012 up to the present.

Q6: What did you do after the defendant’s failure to pay the
supposed rental fees?
A6: I gave her a demand letter asking her to pay the unpaid rental
fees and to vacate the residential townhouse, which was received
by the defendant as shown in the registry return receipt hereto
attached as Annex “A.”

Q7: What was the action of defendant after receiving the demand
letter?
A7: None. The defendant refused to pay, and to vacate and
surrendered possession of the property.

Q8: What did you do after the defendant’s refusal to vacate the
property upon your demand?
A8: I visited and informed the defendant that she must vacate the
property.

Q9: What did you do next?

A9: I am now coming and asking in your office, atty. Alesna, for
legal remedies in order for the defendant to make good of her
unpaid rentals, and to vacate and surrender the possession of the
apartment she has been unlawfully occupying.

- - - - - - - - - -END OF STATEMENT- - - - - - - - - -

IN WITNESS WHEREOF, I have hereunto set my hand and caused my notarial

th
seal to be affixed this 20 day of May, 2021, in Cebu City, Philippines.

(SGD.) PAULA COELHO

Affiant

SUBSCRIBED AND SWORN to before me, a Notary Public in the City of Cebu,
th
this 18 day of May, 2021, in Cebu City, Cebu, Philippines, affiant, exhibiting to me her
Passport No. 1-2345-0A as her competent evidence of identity, issued on March 16,
2018 at DFA Cebu City.

(SGD.) ATTY. JUSTIN ROSS C. ALESNA

 NOTARY PUBLIC
Until December 31, 2022
USJ-R, Main Campus, Cebu City, Cebu
Roll of Atty. No. 00000
PTR No. 00000, issued at Cebu City, 08/01/20
IBP No. 00000, Cebu City Chapter, 08/25/20
MCLE Compliance No. 00000

Doc. No. 12;

Page No. 2;
Book No. 1;
Series of 2021;

ATTESTATION

I, ATTY. Justin Ross C. Alesna, after having been duly sworn to in accordance
with law, do hereby depose and state that:

1. I have personally examined the plaintiff PAULA COELHO;

2. I have faithfully recorded or caused to be recorded the questions propounded

and the corresponding answers thereto made by her;

3. I further attest that I have not nor any other person herein present, or assisting
me, coached PAULA COELHO regarding her answers; and,

4. I fully understand that any false attestation shall subject me to disciplinary

action, including disbarment.

IN WITNESS WHEREOF, I have hereunto set my hand and caused my notarial

th
seal to be affixed this18 day of May, 2021, in Cebu City, Philippines.

(SGD.) ATTY. JUSTIN ROSS ALESNA

Examining Officer

SUBSCRIBED AND SWORN to before me, a Notary Public in the City of Cebu,
th
this 18 day of May, 2021, in Cebu City, Cebu, Philippines, affiant, exhibiting to me his
Community Tax No. 12345 issued at Cebu City Hall as his competent evidence of
identity.

(SGD.) ATTY. JANILA BAJUYO

NOTARY PUBLIC
Until December 31, 2022
Cebu City Hall, Cebu City, Cebu
 Roll of Atty. No. 8121983
PTR No. 050183/Cebu City/08-01-20
IBP Lifetime Membership No. 9031983, Cebu City Chapter, 04/27/14
MCLE Compliance No. V-005374

Doc. No. 28;

Page No. 04;
Book No. 06;
Series of 2021;