Republic of the Philippines

REGIONAL TRIAL COURT

FOURTH JUDICIAL REGION
ORIENTAL MINDORO
BRANCH 40
Calapan City
-o0o-

CALAPAN LABOR SERVICE CIVIL CASE No. CV-18-7333

DEVELOPMENT COOPERATIVE
(CALSEDECO)Represented by
MANUEL CUBOS,
Plaintiff,
Versus for

LERMA A. BALMES ET AL., COLLECTION OF SUM OF

Defendants, MONEY AND DAMAGES
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FORMAL OFFER OF EXHIBITS

Comes now Plaintiff, through counsel, and unto this Honorable Court, most
respectfully offers for admission the following exhibits to wit:

Exhibit “A” and its sub-marking- The petition-to prove the existence of
the same and to show that the filing of the instant complaint has been duly signed;

Exhibit “B” and its sub-marking- Board Resolution-to prove the

existence of the documents and to show that the filing of the instant complaint has
been authorized by the plaintiff’s board of directors;

Exhibit “C” and its sub-marking- Secretary’s Certificate-to prove the

existence of the document and to show that the Resolution was passed by the
Board of Directors

Exhibit “D” and its sub-marking- Board Resolution-to prove the

existence of the documents and to substantiate plaintiff’s claim that it designated
the attorney in fact to initiate this complaint;

Exhibit “E” and its sub-marking- Secretary’s Certificate-to prove the

existence of the document and to show that the Resolution was passed by the
Board of Directors

Exhibit “F” and its sub-marking- Loan Application/Agreement Form-

To prove the existence of the documents and to prove that defendant, Lerma A.
Balmes applied for and was granted a loan by the plaintiff. Also to show that the
other co-defendants participated in the contract and signed the same in their
capacity as co-makers;

Exhibit “F-2” - the signature of the defendants. Co makers,- To prove

that they are privy to the contract and to show that they acceded they obligation as
co-makers;

Exhibit “G” and its sub-marking- Loan Release Voucher- to prove that
the amount of the loan applied for by the defendants were released to them;

Exhibit “H” and its sub-marking- Memorandum of Agreement- to show

that the contract between the parties to this case;

Exhibit “I” and its sub-marking- Statement of Account- to prove that the
defendants had an outstanding balance amounting to P458, 721.95 as of December
31, 2018;

Exhibit “J” and its sub-marking- Final Demand Letter- to prove that a
demand was made and served upon the defendant, Lerma Balmes, demanding
from her to pay the loan;

Exhibit “K” and its sub-marking- Final Demand Letter- to prove that a
demand was made and served upon the defendant, Luzviminda Cantuba,
demanding from her to pay the loan;

Exhibit “L” and its sub-marking- Final Demand Letter- to prove that a
demand was made and served upon the defendant, Eva Marfa, demanding from
her to pay the loan;

Exhibit “M” and its sub-marking- Final Demand Letter- to prove that a
demand was made and served upon the defendant, Jennifer Matalubos, demanding
from her to pay the loan;

Exhibit “N” and its sub-marking- Final Demand Letter- to prove that a
demand was made and served upon the defendant, Leovigilda Pia, demanding
from her to pay the loan;

At this juncture, plaintiff respectfully rests its case.

Wherefore, Plaintiff most respectfully prays of this Honorable Court, that

this case be considered submitted for resolution by this Honorable Court.

May 5, 2022
Calapan City, Oriental Mindoro

ATTY. JOSEPH RYAN C. APASAN

 Counsel for Plaintiff
IBP OR No. 134859
PTR No. 10389162/ Calapan City/ 1-5-2022
IBP Roll No. 56968
MCLE Compliance No. VI-0001337/12-12-16
352 Gozar Street, Camilmil, Calapan City, Oriental Mindoro

Copy furnished:
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NOTICE

Hon. Branch Clark of Court

RTC Branch 40,

Good day! Please submit the foregoing upon receipt hereof for the
Honorable Court’s consideration. Thank you.

JOSEPH RYAN C. APASAN

EXPLANATION

Copies of this motion were sent to the defendants thru registered mail due to
distance and lack of personnel of this office to effect personal service. Thank you.

JOSEPH RYAN C. APASAN