Republic of the Philippines

Department of Justice
OFFICE OF THE CITY PROSECUTION
Tacloban City

GRETHEL NOBIES,
Complainant NPS Docket No. _______________

-versus-
For:
LOUSIANNA ALBAMOS, ESTAFA under Article 315, Par.
Respondent. 1(b) of RPC
x-------------------------------x

JOINT JUDICIAL AFFIDAVIT

We, GRETA C. PAJARITO and LORNA A. FLORO, of legal age,

Filipino, single, resident of Catbalogan City, and the respective buyers of the
two units of second-hand cars from the agent and herein respondent
LOUISIANNA ALBAMOS, after having been duly sworn according to law,
hereby depose and state: THAT -

PREFATORY STATEMENT

The taking of our Judicial Affidavit was administered and supervised

by Atty. Charisse Louie L. Amosco, in her office at 2F Riego Bldg., Lopez
Jaena St., Tacloban City. We have requested to answer the questions herein
in the language we understand, fully conscious that we do so under oath and
may face criminal liability for false testimony or perjury.

PURPOSES OF TESTIMONY

The Judicial-Affidavit of the witnesses, GRETA C. PAJARITO,

hereto referred as WITNESS 1, and LORNA A. FLORO, hereto referred to
as WITNESS 2, will constitute as their direct testimony to prove that there
was an actual sale of the two units of second-hand cars by the agent –
respondent LOUISIANNA ALBAMOS, and specifically to prove the
following facts:

1. They are clients of respondent LOUSIANNA ALBAMOS;

2. GRETA C. PAJARITO purchased one unit of second-hand 2017
Hyundai Elantra with Vehicle Identification (VIN)
HYU20170971D from the agent – respondent LOUISIANNA
ALBAMOS;
3. LORNA A. FLORO purchased one unit of second-hand 2017
 Hyundai-EON with VIN HYU20170193I from the agent –
respondent LOUISIANNA ALBAMOS;
4. That each of the herein witnesses paid Three Hundred Fifty
Thousand Pesos (P350,000.00) for each the second-hand car
purchased;
5. That the said sale is evidenced by two provisional receipts,
amounting to Three Hundred Fifty Thousand Pesos only
(P350,000.00) each, or with an aggregate amount of Seven
Hundred Thousand Pesos (P700,000.00), issued by the agent –
respondent LOUISIANNA ALBAMOS;
6. Affiant will testify on other relevant matters and identify material
and pertinent documents in support of his allegations.

QUESTIONS & ANSWERS

1. Q: Ms. Witness, please state your name, age and other personal
circumstances.
A W1: I am Greta C. Pajarito, 35 years old, a businesswoman and a
resident of Brgy 13, Catbalogan City.
A W2: I am Lorna A. Floro, 36 years old, a businesswoman and a
resident of Brgy 12, Catbalogan City.

2. Q: Do you know Lousianna Albamos, the respondent to the complaint

of one Grethel Nobies of Estafa?
A W1: Yes, I do. She was the agent referred to us by our friend,
Emmanuel Sacro, whom recently learned about our need for second-hand
cars for our respective online selling business.

3. Q: Can you confirm whether or not you were able to buy second-hand
cars through agent Lousianna Albamos?
A W1: I confirm that I was able to purchase a second-hand car
through
agent-respondent Lousianna Albamos.
A W2: So do I.

4. Q: Can you elaborate on how the relative transaction transpired?

A W2: Ms. Albamos called us on July 29, 2021 to inquire and discuss
about our plan to purchase two units of second-hand cars. She informed us
she has two units of second-hand cars which met our requirements, so we
agreed to meet in Catbalogan City on July 30, 2021.

5. Q: Can you relate what transpired between you and the respondent on
July 30, 2021?
A W2: Ms. Albamos and her driver brought the cars to my residence
in Catbalogan City where Ms. Pajarito met Ms. Albamos as well, for us to
inspect the second-hand car units, and to conduct test drives. We were
satisfied with the condition of the cars and they met our needs for our
business, thus, we decided to purchase the cars from her.
6. Q: Can you please state the specific units you purchased from the
respondent?
A W1: One 2017 Hyundai Elantra with VIN HYU20170971D for I,
and one 2017 Hyundai-EON with VIN HYU20170193I for Lorna.

7. Q: Please state the agreed price for the cars and the payment terms
you have agreed upon.
A W2: After negotiations, we agreed to buy each car for P350,000.00
on a cash basis.

8. Q: When did you pay the said amount?

A W2: We respectively paid Ms. Albamos immediately on July 30,
2021.

9. Q: Do you have a proof of the transaction?

A W2: Yes, she issued each of us a provisional receipt.

10. Q: Are these acknowledgment receipts I am presenting you, the ones

you were referring to?
A W2: Yes, these are the ones.

(Atty. Amosco most respectfully move to mark the referred provisional

receipts as Exhibit A and B, respectively.)

11. Q. Was there any discussion with the respondent about the transfer of
the Registrations of the cars to your names?
A W1: Yes. She said that she will assist on processing the documents
once the Official Receipt is issued by her Office, that was known to us as the
GN Traders.

12. Q: Has she assisted you in transferring the car registrations?

A W2: No. In fact, she has not contacted us. The last time we saw her
was that day and she has not been answering our calls since then.

13. Q: Please state your reason why you are executing the foregoing
sworn statement in this case?
A W1: Yes. I am executing this sworn statement to be adapted as my
direct testimony in this case to prove the cause of action of Ms. Nobies, for
criminal case of Estafa under Article 315 paragraph 1(b) of the Revised
Penal Code, against Ms. Albamos.

14. Q: Do you have anything else to add?

A W1 and W2: No more Attorney.

IN WITNESS WHEREOF, I have hereunto set my hand 2 nd day of February

2022 at Tacloban City, Philippines.
 GRETA C. PAJARITO LORNA A. FLORO
Affiant Affiant

SUBSCRIBED and sworn to before me, in the City of Tacloban, this 2 nd day
of February 2022 by the abovenamed affiants, who has satisfactorily proven
to me their identity through their Philippine Passports with ID numbers
P181799X and P88797x, issued on January 6, 2019 and January 7, 2020
respectively, and known to be the same persons who personally signed
before me this Joint Judicial Affidavit Complaint and attested that the
contents thereof are true and correct; and that she voluntarily executed the
same.

Doc. No. 54 CHARISSE LOUIE AMOSCO

Page No. 09 Notary Public for Tacloban City
Book No. 1 Roll No. 51379-2006
Series of 2022 IBP No. 808787-1/3/2007
PTR No. 4128464- 1/3/21; Tacloban
MCLE Compliance III No. 0013601
Issued on April 22, 2021

ATTESTATION CLAUSE
I, CHARISSE LOUIE AMOSCO, on my oath as Investigator and
Lawyer, with office address at 2F Riego Bldg., Lopez Jaena St., Tacloban
City, do hereby attest on the following:
(1) That I have faithfully recorded or caused to be recorded the
questions that were asked and the corresponding answers that the
witness gave; and
(2) That neither I nor any other person then present coached the
witness regarding the latter’s answers.
Tacloban City, February 2, 2022.

ATTY. CHARISSE LOUIE AMOSCO

SUBSCRIBED AND SWORN to before me this 2nd day of February

2022 at Tacloban City, lawyer exhibiting to me his Passport with ID No.
P18-1824, as competent evidence of identity.

Doc No. 56 ATTY. LORNA G. ATIBULA

Page No. 10 Notary Public for Tacloban City
Book No. 1 Roll No. 80123
Series of 2022 IBP No. 136751; 12-17-20
PTR No. 4121109- 1/3/21; Tacloban City