REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL REGION
MAKATI, BRANCH _

PEDRO SANTOS,
Plaintiff,

-versus- Civil Case No. 4D-CIV-2-

22-001
CATS MOTORS INC., For: Damages
Defendants.
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JUDICIAL AFFIDAVIT OF
BEATRICE GOMEZ

Purpose of Testimony

The testimony of the witness, Beatrice Gomez, is being

offered for the following purposes:

(a) To prove that affiant owns the iPhone which

took a video of the security camera footage;

(b) To prove that it was affiant who took the video

of the security camera footage;

(c) To prove that the video taken by Affiant’s

iPhone is the actual security camera footage as
it appeared in the monitor of the I-C-ALL
security system; and

(d) To identify and authenticate the video, and

such other relevant matters.

Testimony on Direct Examination

I, BEATRICE GOMEZ, of legal age, single, a Filipino

Citizen, and with address at 123 Manalac St. Poblacion,
Makati City, Metro Manila, after having been sworn in
accordance with law, hereby respond to the following
questions propounded by Atty. Sara Karmina D. Avillon on
14 February, 2022 at the said address, with full consciousness
that my answers are being given under oath and that I may
face criminal liability for any false testimony or perjury:
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1. Q: Please state your name, age, civil status, and ad-

dress for the record.
A: Beatrice Gomez, 39, single, 123 Manalac St. Pobla-
cion, Makati City, Metro Manila.

2. Q: How do you know Pedro Santos, the plaintiff in this

case?
A: I met him through his wife, Maria, who I became
close with in college.

3. Q: When was the last time you met Pedro and Maria?
A: On September 1, 2021.

4. Q: Why did you meet up with Pedro and Maria?

A: They invited me and our other close friends to their
residence in Salcedo Village for a get-together.

5. Q: To the best of your knowledge, who were invited to

the get-together?
A: Jose delos Reyes, Juan Carlos, Arturo Sanchez,
Andres Chua, Sergio Joaquin, Mario Soriano,
Ricardo Tan, Beatrice Gomez, Caridad Raquel, and
Angela Espiritu.

6. Q: What happened during the get-together?

A: Me and my friends arrived at Pedro and Maria’s
place in Salcedo. But Pedro and Maria asked if they
could step out for a while to buy more food.

7. Q: What did you say when the spouses said they were
going to buy more food?
A: I said that they can go ahead since I also noticed
that there was not enough food for the group.

8. Q: What happened after Pedro and Maria left?

A: After a while, the group decided that we should also
go with Pedro and Maria since we felt guilty that
they would leave the party. So, the group left the
residence and went to the open parking area.

9. Q: What happened when you arrived at the open park-

ing area?
A: Each of us tried looking for Pedro and Maria’s vehi-
cle. After a minute or so, I heard Jose’s voice. He
was shouting “Maria’s stuck!”

10. Q: What did you do upon hearing Jose?

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A: I went towards the direction of the voice I heard and

I found Jose near a Jeep Cherokee vehicle.

11. Q: Who else did you see?

A: As I came nearer, I saw Pedro and Angela near the
driver’s seat of the vehicle.

12. Q: What were they doing?

A: They were trying to get the car to move backwards
to free Maria, who was then stuck underneath the car.

13. Q: What did you do upon seeing what happened to

Maria?
A: I tried to push the car backwards, along with the
other guests.

14. Q: What happened after Maria was freed from under-

neath the car?
A: Maria was taken to a hospital.

15. Q: How did you feel seeing Maria stuck underneath the
car?
A: I was shocked and was panicking, and I eventually
cried from being overwhelmed. I wanted to know
what happened to her, but everyone else was in
shock so I could not ask anyone about the incident.

16. Q: What did you do to find out about what happened to

Maria?
A: After I stopped crying and when I eventually calmed
down, I tried to ask other people who were also
there in the parking lot. Eventually, I met Isoy, the
house boy of the spouses.

17. Q: What did Isoy tell you?

A: He told me that there was a CCTV camera installed
in the parking lot and that I could check the
footage.

18. Q: Please tell me what you saw in the CCTV footage.

A: I saw that the Jeep suddenly stopped when it tried
to back up out of the parking slot. Then the spouses
went to the front of the car and pushed the car. The
car did not move. Maria stayed in front of the car
while Pedro went back to the driver’s seat. The car
suddenly accelerated forward, hitting Maria and
pinning her down.
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19. Q: What did you do after watching the CCTV footage?

A: After getting the permission of Isoy to take a video of
the monitor showing the CCTV footage, I asked him
to rewind the clip back to the point where the Jeep
suddenly stopped, and then I took a video of the
footage.

20. Q: Why did you take a video of the footage?

A: I wanted to show the other guests what happened
since they’re as confused as I was.

21. Q: What did you use in taking a video of the footage?

A: My phone.

22. Q: What brand is your phone?

A: It is an iPhone.

23. Q: What did you do after taking a video of the CCTV

footage with your iPhone?
A: I showed the video to the other guests.
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ATTESTATION OF THE WITNESS

I attest to the truth of the foregoing narration of facts by

affixing my signature below. I answered the questions with full
awareness that I was under oath at the time the questions
were propounded to me and that I may face criminal liability
for false testimony or perjury for any false statement in this
Judicial Affidavit. I warrant that the documents attached to
this Judicial Affidavit are faithful reproductions of their
original counterparts.

IN WITNESS WHEREOF, I have hereunto set my hand

this 14th day of February 2022, at Makati City, Philippines.

BEATRICE GOMEZ

SUBSCRIBED AND SWORN to before me this 14th day of Feb-

ruary 2022, in the City of Makati, Philippines, affiant having
exhibited to me her Driver’s License No. 13489189 issued on
the 20th day of June 2020.

HALAMIN A. WALLA
Notary Public
Until December 31,2025
PTR No. 23430
Issued at Makati City
On July 1, 2020

Doc. No. 7
Page No. 2
Book No. 1
Series of 2022
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EXAMINING COUNSEL’S ATTESTATION

I, Sara Karmina D. Avillon, after having been sworn in

accordance with law, hereby depose and state:

1. I personally conducted the examination of Beatrice

Gomez;

2. I faithfully recorded or caused to be recorded the

questions I asked and the corresponding answers that the
affiant, Beatrice Gomez, gave; and

3. Neither I nor any other person then present or

assisting me coached Beatrice Gomez, regarding her answers.

IN WITNESS WHEREOF, I have hereunto set my hand this

14th day of February 2022, in the City of Makati, Metro
Manila, Philippines.

SARA KARMINA D. AVILLON

SUBSCRIBED AND SWORN to before me this 14th day of Feb-

ruary 2022, in the City of Makati, Philippines, affiant having
exhibited to me her Driver’s License No. 10000001 issued on
the 10th day of May 2020.

HALAMIN A. WALLA
Notary Public
Until December 31,2025
PTR No. 23430
Issued at Makati City
On July 1, 2020

Doc. No. 8
Page No. 2
Book No. 1
Series of 2022