REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Branch 1, City of Manila

ALAY BUHAY FOUNDATION

CHARITY CENTER
Plaintiff,
CIVIL CASE No. 02-002022____
-versus- For: DAMAGES ARISING FROM
ARTICLE 25 OF THE CIVIL CODE
OFFICE OF THE BARANGAY
CHAIRMAN, BARANGAY 473
SAMPALOC MANILA through
its Barangay Chairman
ERNESTO CABUYAO, Barangay
Kagawad JASON ESTANISLAO,
LYDIA SAYSON, SAMMUEL
LONTOK, ABDUL JALANDONI,
RICARDO SUMAYAO, AMIRA
BERNARDINO and MARK
HOMERES, Barangay Treasurer
LISA LAGUANI and Barangay
Secretary JASSICA FLORES
Defendants.
x------------------------------------------x

FORMAL OFFER OF
DOCUMENTARY EVIDENCE

PLAINTIFF, through undersigned counsel and unto this

Honorable Court most respectfully and formally offers the
following documentary evidence for the purposes indicated
herein below provided:

EXHIBIT DOCUMENT PURPOSE

“A” Secretary To prove that Ms.
(Part of the Certificate issued Marinelle Tan, as
Records) by Alay Buhay the name stated
Foundation Charity therein, is
Center in favor of authorized to
Ms. Marinelle Tan represent Alay
Buhay Foundation
Charity Center as
 the plaintiff the
case stated above.

“B” SEC Registration of To prove the legal

(Part of the Alay Buhay standing of Alay
Records) Foundation Charity Buhay Foundation
Center Charity Center, as a
Private Charitable
Institution,
registered under
Security and
Exchange
Commission, in
putting up the case
against the herein
defendants.

“C” Proclamation No. To establish the fact

(Part of the 1267 issued by the that Metro Manila is
Records) Office of the and still under the
President State of Calamity
at the time of the
display of
extravagance, by
the Barangay
Officials.

“D” Series of Pictures of To establish the fact

(Part of the the ten (10) Toyota that indeed, there
Records) Vios Sedan were ten (10)
Toyota Vios Sedan,
delivered and
displayed in the
Barangay of the
defendants herein.

“E” Contract to Sell To prove that the

(Part of the between Toyota – barangay officials
Records) Quezon Avenue of Barangay 473,
Branch and Brgy. Sampaloc Manila is
Officials of Brgy.473 the buyer of the ten
Sampaloc, Manila (10) Toyota Vios
Sedan.
 “F” Car Sales Receipt To prove that then
(Part of the ten (10) Toyota Vios
Records) Sedan was fully
purchased during
the period where
Metro Manila is
under the State of
Calamity.

“G Series” Judicial Affidavit of To prove the legal

(Provisionally Ms. Marinelle Tan standing of the
Marked) Alay Buhay
Foundation Charity
Center.

To establish the fact

of the existence of
the collective
actions of the
defendants
constituting a
violation under
Article 25 of the
Civil Code.

“H” Judicial Affidavit of To support the

(Provisionally Mr. Elmer claim
Marked) Caguindagan corroborating with
the statement of
facts by Witness
Tan, insofar as the
purchase of the
Toyota Vios Sedan
is concern.

To prove that the

ten (10) Toyota Vios
Sedan were
delivered and were
displayed in an
open area in the
Barangay Hall of
Barangay 473
Sampaloc, Manila
 “I” Judicial Affidavit of To prove that
(Provisionally Mrs. Rosario Bensol indeed, the
Marked) collective acts of
the defendants at
the time, were
malicious, resulting
to public outrage

Accordingly, Plaintiff prays that the above-mentioned

documentary evidence (Exhibits A to I) be admitted in the
evidence for the purposes they are being offered and upon
admission thereof, herein plaintiff be considered to have rested
its case.

Respectfully submitted.

01 September 2022. Quezon

IN WITNESS WHEREOF, I have hereunto set my hand this 16th

September 2022 at Quezon City, Philippines.

CRUZ FLORES RAMIREZ TALANA & TAN Law offices

Counsel for Plaintiff
Unit 309 Philippine Social Science Center Building
Commonwealth Avenue, Diliman, Quezon City
Telephone Nos.: (02) 8453-3532 and (02) 85100734
Mobile Number: (+63) 915.446.5894
Email Address: mdtala27@gmail.com
Microsoft Teams: mdtala27@gmail.com
By:

MICHAEL DONASCO TALANA

PTR No. 1324032; 03 January 2022; Quezon City
IBP Lifetime Member No. 12345; 04 August 2018
MCLE Compliance No. VI-012345; 21 March 2018
Roll No. 98765
Copy furnished:
Atty. AJAY ANN M. DELA CRUZ
Counsel for the defendants
Unit 25 Kayumanggi Street
Mandaluyong City 1550 Metro Manila

ERNESTO CABUYAO
JASON ESTANISLAO
LYDIA SAYSON
SAMMUEL LONTOK
ABDUL JALANDONI
RICARDO SUMAYAO
AMIRA BERNARDINO
MARK HOMERES
LISA LAGUANI
JASSICA
FLORES
Barangay Hall
Barangay 473,
Samapaloc, Manila