FLOW OF PRESENTATION OF WITNESS
Counsel: We call to the witness stand Mr. Panfillo Moreno. (witness will
swear in)
Witness is Mr. Panfillo Moreno your Honor _____ years old residence of
______ and is ready to testify.
COC: --------------------------------
Counsel: May I proceed your honor.
Judge: -------------
Counsel: With the permission of this Honorable Court, the purpose of
which the testimony is offered are already incorporated in this Judicial
Affidavit.
Counsel: Do you remember having executed a Judicial Affidavit in
relation to this case.
Witness: Yes, I remember having executed such Judicial Affidavit.
C: I have with me here a Judicial Affidavit composed of 5 pages
including attestation, will you go over it and tell this Honorable Court
that this is the is the Judicial Affidavit you are referring too.
W: Yes, I remember having executed such Judicial Affidavit.
C: There appears to be signatures on the left side of every first four pages
of Judicial Affidavit who’s signature are those?
W: It is my signature.
C: And on the last page, there is a signature appearing on top of the name
_________________ (Panfillo Moreno) Who’s name and signature is
this?
W: It is my name and signature.
C: Do you confirm and affirm the contents of this Judicial Affidavit?
W: Yes, I confirm and Affirm the contents of the Judicial Affidavit.
C: You made mentioned Mister witness, in your Judicial Affidavit this
sales invoice. Where is this sales invoice?
W: I submitted it to you.
C: There appears to be a name written this sales invoice who’s name is
this?
W: It is my name (may signature ba?).
C: May we pray your Honor that the sales invoice be marked as Exhibit
____
C: You made mentioned Mister witness in your Judicial Affidavit this,
statement of [Link] is this statement if account?
W: I submitted it to you.
C: May we pray your Honor that the statement of account be marked as
Exhibit ____.
C: You made mentioned Mister witness in your Judicial Affidavit this,
promissory note.
W: I submitted it to you.
C: You made mentioned Mister witness in your Judicial Affidavit this,
Demand letter. .Where is this demand letter?
W: I submitted it to you.
C: Mister Witness who are your active employees and your inactive
employees.
W: My active ees are:
My inactive ees are:
C: You mentioned that Harry Gabon is your former employee, What is
your proof that Harry is no longer your employee?
W: The termination letter I issued which he signed.
C: On this termination letter, there is a name and signature appearing on
top of the name _________________ (Panfillo Moreno) Who’s name and
signature is this?
W: It is my name and my name and signature, Sir.
C: May we pray your Honor that the termination letter be marked as
Exhibit ____.
C: The defendant alleged that they sent a letter requesting a copy of the
CCTV footage what was your response?
W: I did not offer a reply.
C: Why did you not respond to the letter sent to you?
W: There was an unscheduled power interruption for both days, Sir.
C: What is your proof for such unscheduled power interruption?
W: The notice of power of interruption posted in the official facebook
page of the BENECO, Sir.
C: Your Honor may we request the defense counsel to compare with the
actual post in the official facebook page of the BENECO and the
screenshot appears one and the same.
Defense counsel:
(option 1) No your Honor the screenshot is not the same with the
post.
(option 2) Yes your Honor, the machine photocopy appears to be
true and faithful reproduction of the actual post in the official
facebook page of the BENECO.
C:
(answer for option 1) May we pray the Honorable Court to
compare the screenshot machine copy with the l post in the official
facebook page of the BENECO.
(answer for option 2) May we pray your Honor that this screenshot
copy of the post BENECO be marked as exhibit________.
C: May we pray that the contents of Judicial Affidavits including
Documents exhibits and additional question and answers form part of the
direct testimony of the witness.
JUDGE:
-------- FORMAL OFFER OF EVIDENCE-------
C: Your Honor, we are offering the following testimony as our
testimonial and documentary evidences.
C:
Sales invoice, the purpose of which is supporting the fact that there had
been a sales transaction between the plaintiff and defendant valued at
TWO MILLION AND TWO HUNDRED FIFTY THOUSAND
PESOS (Php.2,250,000.00).
Statement of accounts, the purpose of which is to contest sales transaction
and amount due upon delivery of the items to the defendant.
Promissory Note, the purpose of which is this supports the fact that
the defendant made a promise to pay his unpaid obligation not later
than 29 October 2021.
Demand Letter, the purpose of which is It states that the written demand
letter was sent by the plaintiff due to the unpaid obligations of the
defendant and the unheeded oral demands by the plaintiff.
Termination letter, the purpose of which is to certify thatHarry Gabon
from his termination, he has no authority to receive the payment from
______.
Notice of Unscheduled power interruption, the purpose of which is to
certify the failure to provide the CCTV footages.
