You testified that you came to know the defendant in this case, Maria Teresa Victoria

dela llarte, when she was introduced to you by her brother, Jose Raul Rodriguez,
correct? (Q5).

You claim that you met the defendant in July 2017 (Q33) at the birthday celebration
of Jose Raul Rodriguez in his home in Manila Doctors Village, correct?

(Q34) Was that the first time that you personally met the defendant which was in July
2017?

Q7: You said that you met Jose Raul C. Rodriguez sometime in Sept. 2016, brother of
herein defendant, who introduced himself as the administrator of the property covered
by TCT No. T-25594 which is owned by defendant

- When you met Jose Raul C. Rodriguez sometime in Sept. 2016, at that time
you had not met defendant yet, Maria Theresa Victoria dela Llarte? Answer
must be Yes! - (Note only witness’ answer is inconsistent – “But you testified
that you came to know the defendant in July 2017 (Q33) at the birthday
celebration of Jose Raul Rodriguez in his home in Manila Doctors Village)
-
- When you met Jose Raul C. Rodriguez sometime in Sept. 2016, did he show
you document to prove that he is the brother of Defendant? (You rely on SPA
only)

- When you met Jose Raul C. Rodriguez sometime in Sept. 2016 and introduced
himself as the administrator of the property covered by TCT No. T-2559, did
he show you document to show that he is administrator of the property covered
by TCT No. T-25594 which is owned by defendant (You rely on SPA only)

Q21: You testified that on October 3, 2016, you made a downpayment in the amount
of Php50,000 which Jose Raul Rodriguez received in behalf of defendant?

At that time, on October 3, 2016, when you allegedly made a downpayment in the
amount of Php 50,000, still you had seen or personally met the defendant?

Q32: You identified a Special Power of Attorney dated June 10, 2017. So
the date of the document is June 10, 2017, agree?

- At that time, on October 3, 2016, when you allegedly made a downpayment in

the amount of Php 50,000, there was no document or SPA that was presented to
you by Jose Raul Rodriguez showing that he was authorized to sell the property
subject of this case and to receive payment, correct?
Q24: You identified as Exhibit B a copy of Acknowledgment Receipt dated Oct. 3,
2016 for the alleged downpayment of Php 50,000.. In this Acknowledgment Receipt,
will you agree with me that there is no signature defendant?

Q25:: You alleged that after paying Jose Raul Rodriguez the downpayment of
50,000 on Oct. 3, 2016, you subsequently paid the amount of Php
61,000 to Jose Raul Rodriguez on Nov. 7, 2016?

- Will you agree that when you allegedly paid the amount of Php 61,000 to Jose
Raul Rodriguez on Nov. 7, 2016, you did not have any document or SPA to
show that defendant had authorized Jose Raul Rodriguez to sell the property or
receive payments on her behalf, because the SPA was allegedly executed on
June 10, 2017?

You also claimed to have made payments from December 2016 to December 2017 in
the amount of Php 7,000/month. Q28: You identified a List of Payments (Exhibit
E) dated Nov. 7, 2016 to Dec. 2017

- Whose handwriting is this?

- There were no witnesses to this list, correct?

See Q32: A while ago, you confirmed that the date of execution of the Special
Power of Attorney (Exhibit C) is June 10, 2017.

- Will you agree that when you allegedly made payments to Jose Raul Rodriguez
in the amount of Php 7,000/month from December 2016 to up to May 2017,
you did not have any document or SPA to show that defendant had authorized
Jose Raul Rodriguez to sell the property or receive payments on her behalf
because the SPA was executed on June 10, 2017, correct?

- Will you agree with me that in this Special Power of Attorney dated June 10,
2017, there is no use of specific word “ratify” in reference to any transaction
involving the property covered by TCT No. 25594?

Q18: You identified TCT No. T-25594 (Ex F). (Q11) You identified a Contract to
Sell dated Sept. 7, 2017 (Exh. “D”) involving the property covered by said title

When you allegedly executed a Contract to Sell of the subject property covered by
TCT No. T-25594 (Ex F), it is stated that the seller, which refers to the defendant, is
the absolute owner.

Am I correct that when you executed the Contract to Sell, you checked the title?

Will you agree with me that in TCT No. T-25594 (Ex F), defendant is not the
registered owner of the title but a certain Jose Rodriguez?
 - The property covered by TCT No. T-25594 mentioned in the Contract to Sell is
situated in Manila Doctors Village, Almanza Uno, Las Pinas City, correct?

- The whole property consists of 475 sq. m., do you confirm that?

- But the subject of the Contract to Sell is only a portion of the property
consisting of 100 sq.m., correct?

- And the agreed purchase price for the 100 sq.m. was Php 750,000.00?

- But the Contract to Sell did not describe and specify the metes and bounds of
the 100 sq.m. to be purchased, correct?

- In fact, there was no subdivision plan that formed part of the Contract to Sell,
correct?

- In other words, am I correct to say that when Contract to Sell was allegedly
executed, you as buyer and the seller had not agreed on the specific metes and
bounds of the 100 sq.m.?

- The Contract to Sell states that the sum of Php 131,000.00 was paid already by
the buyer, do you confirm that?

- The Contract to Sell states that balance is payable within a period of 8 years in
the amount of not less than Php7,000 per month starting Oct. 5, 2017, do you
confirm that?

- But you do not have documentary proof to show that you made payments of
7,000/month from December 2017 and onwards, correct?

You testified that you came to know the defendant in this case when she was
introduced to you by her brother, Jose Raul Rodriguez. (Q5) ? And you testified that
you met the defendant in July 2017 (Q33) at the birthday celebration of Jose Raul
Rodriguez in his home in Manila Doctors Village?

(Q34) Am I correct to say that it was at this time that defendant suddenly advised you
not to make further payments, is that correct?

- Do you have any documentary proof that defendant advised you not to make
further payments? (Answer must be no)
 - Do you have any documentary proof that defendant refused to accept payment?
(Answer must be no)

- Do you have any documentary proof, such as a letter or written

communication, that was sent to the defendant regarding your intent to pay?
(Answer must be know)

- Did you send any demand letter to the defendant for her to accept you
payment? (Answer must be know)

38: You claim that due to the alleged refusal of defendant to accept your payments,
you suffered anxiety, sleepless nights and mental anguish?

Q42: You claimed that you developed illnesses by reason of defendant’s actions?

. By the way, how old are you now? What is your job?

You mentioned of Dr. Jason M. Mutuc and Dr Rosita Ocampo , the physicians who
allegedly examined you and issued you medical prescriptions. By the way, how long
have you known Dr. Mutuc. ? Dr, Ocampo? Since when have you been consulting to
them regarding your health condition?

Was it your first time in 2019 to visit hospitals and consult with physicians regarding
your health condition or not? (Answer must be know to establish prior illnesses due to
advanced age)

Prior to 2019, have you visited physicians and doctors ? When? How often?