Republic of the Philippines

6th Judicial Region

Municipal Trial Court in Cities
Branch 8 – Bacolod City
-oOo-

PEOPLE OF THE PHILIPPINES,

Complainant,

-versus- CRIM. CASE NO. 00062797

For: Reckless Imprudence
Resulting in Damage
to Property with
Serious Physical
Injuries

JOSEPH “JOE” QUINN GOLBERG,

Accused.
x------ -- -------- --------x

JUDICIAL AFFIDAVIT OF JOSEPH QUINN GOLDBERG

This is the Judicial Affidavit of Mr. JOSEPH “JOE”

QUINN GOLDBERG (hereinafter referred to as “Accused”), of
legal age, single, Filipino, businessman and a resident of
Madre Linda Homes, Bacolod City, in relation to the above-
entitled case.

Preliminary Statement

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 The following questions were propounded by Atty. Ressie
June N. Pedrano (hereinafter referred to as “Counsel”) for
accused in this case, in her law office at 222 ND-Street, Bacolod
City.

The questions were in English language, a language

known and spoken by the Accused, who answered the
questions in the same language and of his personal
knowledge. Further, the Accused answered the questions
asked of him, fully conscious that he does so under oath and
that he may face criminal liability for false testimony or
perjury, in compliance with A.M. No. 12-8-8-SC.

Offer of Testimony
The testimony of the Accused is being offered to establish
the following facts:
(1) That he was the accused in the abovementioned case;
(2) To refute the material allegations charged against him by
the Private Complainant RHYS MONTROSE; and
(3) Other relevant matters.

Direct Examination Proper

Question 1: Please state your name and other personal
circumstances for the records.
Answer 1: I am JOSEPH “JOE” QUINN GOLDBERG, 36 years
of age, single, an American, businessman and a resident of
Madre Linda Homes, Bacolod City.

Question 2: Are you the same JOSEPH “JOE” QUINN

GOLDBERG charged in this criminal case?
Answer 2: Yes, Atty.

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Question 3: Do you know RHYS MONTROSE?
Answer 3: Yes, ma’am.

Question 4: How do you know him?

Answer 4: He is the complainant in this case.

Question 5: Mr. Witness, do you remember where you were

on March 16, 2023 at about 2:30 o’clock in the afternoon?
Answer 5: Yes, ma’am.

Question 6: Where were you on that date and time?

Answer 6: I was driving with my friend along Lacson Street
coming from the North direction going to the main branch of
Philippine National Bank.

Question 7: On that date and time, do you recall any unusual

incident that happened?
Answer 7: Yes, ma’am.

Question 8: What was that, if any?

Answer 8: I was going to the parking of Philippine National
Bank. I made a stop and a signal to the opposing vehicles of
my intention to go right to enter the parking area of the bank.
When I am almost at the gutter entering the parking lot, a
motorcycle which came out of nowhere bumped my car.

Question 9: Mr. Witness, you mentioned that you were driving

during the incident, what vehicle were you driving?

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Answer 9: I was driving my car, a Nissan GT-R, color white,
with plate number FTW-444.

Question 10: After the collision, what happened next, if any?

Answer 10: Due to the strong impact of the collision, the rider
fell on top of the hood of my Nissan GT-R and then slid
directly onto the pavement.

Question 11: Mr. Witness, what portion of your Nissan GT-R

was bumped by the motorcycle?
Answer 11: The left front side portion of my Nissan GT-R was
hit by the motorcycle.

Question 12: Is there anything else that was damaged in your

car?
Answer 12: Yes, Atty. The left side mirror got broken when the
motorcycle bumped me and the hood of my Nissan GT-R was
also damaged because it was where the rider fell.

Question 13: Mr. Witness, what proof do you have that your
Nissan GT-R sustained damage as a result of the collision with
the motorcycle?
Answer 13: I took pictures of the damages sustained by my
Nissan GT-R.

Question 14: You mentioned pictures. Here I am showing you

pictures of your car marked as Exhibit “2” to Exhibit “2-D”. Are
these the photographs you are referring to?
(Counsel handed over the document to witness and the witness
examined it.)
Answer 14: Yes, ma’am.

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Question 15: In Exhibit “2” can you tell me what is being
depicted in the photograph?
Answer 15: The scratch on the left front side portion of my
Nissan GT-R and the misalignment of my bumper.

Question 16: How about in Exhibit “2-A”?

Answer 16: The huge scratch sustained by my NISSAN GT-R
as well as the dent in the hood.

Question 17: How about in Exhibit “2-B”?

Answer 17: The broken left side mirror of my NISSAN GT-R.

Question 18: How about in Exhibit “2-C”?

Answer 18: The huge dent on the hood of my NISSAN GT-R.

Question 19: And, lastly, in Exhibit “2-D” what does it show?

Answer 19: My car was already 6 to 7 inches away from the
gutter while the motorcycle was down in the bicycle lane
where he drove by me, tried to overtake and get ahead of me.

Question 20: Mr. Witness, after your NISSAN GT-R sustained

damage, what did you do with it, if any?
Answer 20: I went to NISSAN Bacolod to have a job estimate
of the damages sustained by my car.

Question 21: I am showing you a copy of a Job Estimate

marked as Exhibit “3” with a price estimate worth Php.
197,321.75, marked as Exhibit “3-A” and signed by one Simon
Soo a service advisor of NISSAN Bacolod, his signature is

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marked as Exhibit “3-B”. Is this the job estimate that you were
referring to?
(Counsel handed over the document to witness and the witness
examined it.)
Answer 21: Yes, ma’am.

Question 22: After knowing the cost of the damages sutained

by your NISSAN GT-R, did you still try to have it repaired?
Answer 22: Yes, ma’am. I have the copy of the Service Billing
issued by NISSAN Bacolod and the Official Receipt of my
payment.

Question 23: Now, Mr. Witness, I am showing you a

document entitled Service Billing marked as Exhibit “4” with
an Amount Payable worth Php.120,058.50 marked as Exhibit
“4-A”. Is this the document you were stating earlier?
(Counsel handed over the document to witness and the witness
examined it.)
Answer 23: Yes, ma’am.

Question 24: How about this document marked as Exhibit “4-

B” entitled Official Receipt, is this the receipt you were
referring to?
(Counsel handed over the document to witness and the witness
examined it.)
Answer 24: Yes, ma’am.

Question 25: Mr. Witness, you mentioned that during the

unfaithful incident, you were driving with your friend?
Answer 25: Yes, ma’am.

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Question 26: What is the name of your friend?
Answer 26: Kate Galvin.

Question 27: Where was she seated inside the car during the
incident?
Answer 27: She was sitting on the passenger seat where she
clearly heard and directly felt the strong impact of the
motorcycle hitting the car.

Question 28: If she would be asked, could she truthfully

describe what happened during March 16, 2023?
Answer 28: Yes, ma’am. Kate actually wrote a Sinumpaang
Salaysay about what she witnessed during the incident.

Question 29: I have here the Sinumpaang Salaysay signed by

Kate Galvin marked as Exhibit “5” TO Exhibit “5-A-1”. Is the
Salaysay you were referring to?
(Counsel handed over the document to witness and the witness
examined it.)
Answer 29: Yes, ma’am.

Question 30: Mr. Witness, you mentioned earlier that out of

nowhere, the motorcycle bumped you, why did you not see
him coming.
Answer 30: I did not see him coming because all the other
vehicles across me stopped to allow me to turn right and enter
the PNB parking space. After the Black TOYOTA Hi-Lux made
a full stop and signaled me to turn right, the vehicles behind
him also followed suit. During that time, I saw no other vehicle
at the right lane near the gutter.

Page 7 of 13
Question 31: Did you conduct any measure aside from using
the signal light of your NISSAN GT-R so you can safely drive to
where you will be parking?
Answer 31: Yes, ma’am. Even though the cars from across me
stopped to give way for me, I also continued looking at the left
and the right side of my vehicle to slowly maneuver my car to
the parking space.

Question 32: What made you decide that you were completely
free from turning right and proceed to the parking space of the
bank?
Answer 32: Aside from the Black TOYOTA Hi-Lux in the other
lane that stopped and allowed me to pass, the security guard
of the Philippine National Bank was also guiding me using his
left hand to proceed to the parking space.

Question 33: What is the name of this security guard?

Answer 33: His name is SG Vic Legaspi.

Question 34: What made you decide to follow SG Legaspi’s

instructions?
Answer 34: He was standing in front of the parking space of
the bank near the innermost lane by the gutter, so he had a
good view of every vehicle that was in the north bound lane.
He was in the position to immediately signal me to stop if he
saw a motorcycle driving in and about to pass through the
right lane.

Question 35: Mr. Witness, if SG Legaspi will be asked to

confirm your testimony, can he give a truthful description of
the events that transpired during the incident?

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Answer 35: Yes, ma’am. SG Legaspi along with the other
security guard on duty at the Philippine National Bank that
day made a Sinumpaang Salaysay.

Question 36: I am showing you a Sinumpaang Salaysay

signed over the name of SG Vic Legaspi and marked as Exhibit
“6” to Exhibit “6-A”. Is this the Sinumpaang Salaysay you were
referring to?
(Counsel handed over the document to witness and the witness
examined it.)
Answer 36: Yes, ma’am.

Question 37: As to the other guard you were referring to have

been on duty with SG Vic Legaspi on the date of the incident, I
have here a copy of a Sinumpaang Salaysay signed by Ricardo
Ruiz, and marked as Exhibit “7” to Exhibit “7-A”. Is he the
other security guard you mentioned accompanying SG Victor
Legaspi?
(Counsel handed over the document to witness and the witness
examined it.)
Answer 37: Yes, ma’am.

Question 38: Mr. Witness, aside from your companion inside

the vehicle and the security guards of Philippine National
Bank, is there anyone else who can testify and affirm your
testimony?
Answer 38: Yes, ma’am. Her name is Dawn Reyes.

Question 39: How is this Dawn Reyes involved or aware of the

incident if any?

Page 9 of 13
Answer 39: She was a PNB Client who was sitting inside her
car when the incident happened.

Question 40: How did she witness the collision incident?

Answer 40: Ms. Dawn Reyes parked her a Purple HONDA City
at the space nearest to the street, the parking space right
beside the bicycle lane. She was sitting inside her car, and
waiting for her air-con to cool completely before she could
drive out of the parking space. While she waited, she
witnessed how the motorcycle driver, in his impulsiveness,
tried to race the White NISSAN GT-R from reaching the gutter
side.

Question 41: Mr. Witness, if Ms. Dawn Reyes will be asked to

confirm your testimony, can she give a truthful description of
the events that transpired during the incident?
Answer 41: Yes, ma’am. Ms. Reyes executed a Sinumpaang
Salaysay.

Question 42: I have here a copy of a Sinumpaang Salaysay

signed by Dawn Reyes, and marked as Exhibit “8” to Exhibit
“8-A”. Is this the Sinumpaang Salaysay you were referring to?
(Counsel handed over the document to witness and the witness
examined it.)
Answer 42: Yes, ma’am.

Question 43: Considering what you have said, Mr. Witness,

what do you want the Honorable Court to do with the case
filed against you?
Answer 43: I hope and pray that this case filed against me be
dismissed. I have employed diligence in my driving when the

Page 10 of 13
incident occurred. I am sorry for the injury suffered by the
Private Complainant Rhys Montrose but this injury was due to
actions of his own and not by me nor did I contribute to such.

Question 44: Mr. Witness, do you affirm and confirm the

truthfulness and veracity of all the statements you have stated
in this Judicial Affidavit?
Answer 44: Yes, ma’am.

Question 45: That would be all for now. Thank you for your
time and full cooperation.
Answer 45: You’re welcome.

IN TRUTH AND WITNESS WHEREOF, the witness have

hereunto affixed his hand this 1st day of April 2023, at the City
of Bacolod, Philippines.

____________________________________
JOSEPH QUINN GOLDBERG
I.D. No.:_____________________

SUBSCRIBED AND SWORN TO BEFORE ME, this

______________ at Bacolod City, Philippines. Affiant personally
appeared bearing competent proof of his identity.

Witness my hand and seal.

ATTY. RESSIE JUNE N. PEDRANO

Notary Public
For and in the Cities of Bacolod, Talisay, Murcia & Salvador Benedicto
Notarial Comm. No. 0016-23; Until 12-31-23
Roll of Attorneys No. 76442

Page 11 of 13
 MCLE Compliance No. VI-0003348 (Until April 14, 2023)
PTR No. 4159103, 01-31-23; Bacolod City
IBP Lifetime No. 020278; 06-27-22, Neg. Occ. Chapter
Room 3, 2nd Flr., JRH Building, 222ND-Street, Bacolod City.

Doc. No.___;
Page No.___;
Book No.___;
Series of 2023.

SWORN ATTESTATION
The undersigned hereby attests that, as counsel of the
witness, she faithfully recorded or caused to be recorded the
questions she asked and the corresponding answers that the
witness gave; and that neither she nor any other person then
present or assisting her coached the witness regarding the
latter's answers.

ATTY. KEVIN CROSBY P. CABATUAN

Notary Public
For and in the Cities of Bacolod, Talisay, Murcia & Salvador Benedicto
Notarial Comm. No. 0011-22; Until 06-12-23
Roll of Attorneys No. 77554
MCLE Compliance No. VI-0004459 (Until May 4, 2023)
PTR No. 4276123, 01-31-23; Bacolod City
IBP Lifetime No. 040567; 11-12-22, Neg. Occ. Chapter
Center Plaza, Rm. 1, Bacolod City.

Doc. No.___;
Page No.___;
Book No.___;
Series of 2023.

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