REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
BRANCH IV

DINDIN DIZON,
Plaintiff,

- versus - Civil Case No. 16-100

For: Collection of sum
of money

SPOUSES MAT AND BREA LAPAZ,

AND THE BREYS FEDERATION,
INC.,
Defendants.
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JUDICIAL AFFIDAVIT
OF
DEFENDANT BREA LAPAZ

This Judicial Affidavit of Brea Lapaz is executed to serve

her direct testimony in the instant case.

I, Brea Lapaz, of legal age, married, and living at #123 Parkhomes

Subdivision, Mabalacat City, Pampanga, defendant in this case, state
under oath as follows:

PRELIMINARY STATEMENT

The person examining me is Atty. Jackie D. San Mateo with office

address at J and J Law Office, No. 153 Hunters Bldg., Dau, Mabalacat
City, Pampanga. The examination is being held at the same address. I
am answering her questions fully conscious that I do so under oath
and may face criminal liability for false testimony and perjury.

PURPOSE: This affidavit/testimony of defendant Brea Lapaz is

being offered to prove that the plaintiff Dindin Dizon and co-
defendant and spouse, Mat Lapaz, did not enter into a Contract of
Loan, and assuming that they did, herein defendant has no
knowledge and/or participation to the said transaction alleged in the
subject complaint.
Defendant will also prove that the checks, allegedly issued for security
of the alleged loan, which is in her name, were not issued by her for
the said purpose.

1. Q. Please state your name and other personal circumstances for

the record.
A. I am Brea Lapaz, of legal age, married to Mat Lapaz and living
at #123 Parkhomes Subdivision, Mabalacat City, Pampanga.

2. Q. Do you know why you are here?

A. Yes, because I am one of the defendants in a suit filed by Ms.
Dindin Dizon.

3. Q. Do you know Ms. Dindin Dizon?

A. No, Maam.

4. Q. But have you met her personally?

A. No, Maam.

5. Q. What is the job of your spouse?

A. He is the Chief Operating Officer of the Breys Federation, Inc.

6. Q. Do you know his relationship or connection with Ms. Dizon?

A. No, Maam.

7. Q. But with the best of your knowledge, what kind of transaction

did your husband and Ms. Dizon entered into?
A. An investment.

8. Q. I am showing you this document, herein referred to as “Exhibit

C.” Do you know this document?
A. Yes Maam.

9. Q. What is this document?

A. The checks named in my account.

10. Q. Who signed this document?

A. Myself.

11. Q. What is your purpose for signing it?

A. It was intended for the payment for a house we are planning
to buy.

12. Q. According to the information, these checks were actually lost?

A. Yes, Maam.
13. Q. How was it lost?
A. My husband, after attending a meeting, left the envelope
containing such checks.
14. Q. Then, what happened?
A. My husband called me that the checks were lost.
15. Q. What did you do after knowing the lost of the checks?
A. I called my bank, informed the Manager that said check were
lost. I also sent them a letter informing the same and
requested for “stop payment” for the lost checks to which the
bank in a letter acknowledged.
16. Q. Do you have proof of such acknowledgment?
A. Yes Maam. I have the bank’s acknowledgment letter (Annex
“5”).

IN WITNESS WHEREOF, I have hereunto set my hand this

24th day of December 2022.

Brea Lapaz
Affiant

SWORN ATTESTATION

The undersigned hereby attests that, as counsel of the witness,

he faithfully recorded the questions he asked and the corresponding
answer of the witness and that he did not coached the witness’
answers to the questions propounded.

ATTY. JACKIE D. SAN MATEO

NOTARY PUBLIC
Until December 31, 2023
PTR No. 64965557-07 – 01/05/2018
IBP No. 761988-01 – 01/05/2018
MCLE Compliance No. 0034255

Doc. No. 245;

Page No. 35;
Book No. 42;