Republic of the Philippines

REGIONAL TRIAL COURT

Fourth Judicial Region
Branch 107, Los Baños, Laguna

FRANCISA B. PALADIN
Plaintiff, Civil Case No. 14747-CVA

- versus - for

Independent civil action for

JOANNE P. MALAYAO damages arising from People of
Defendants. the Philippines v. Joanne P.
Malayao (Criminal Case No.
14747 for Reckless Imprudence
Resulting in Homicide)
x--------------------------------------x

JUDICIAL AFFIDAVIT
OF FRANCISCA B. PALADIN

WITNESS
The witness is Mrs. Francisca B. Paladin, married, and a resident of 130
Maliksi St., Jubileeville Subdivision, Brgy. Masaya, Bay, Laguna.

LAWYER
The lawyer who took this testimony is Atty. Shynar Lei R. Betoya, with
address at SLRB Law Offices 1732 Rizal Ave., Los Bañ os, Laguna.

PLACE OF EXAMINATION
Their testimony was taken at the address of Mrs. Paladin at 130 Maliksi
St., Jubileeville Subdivision, Brgy. Masaya, Bay, Laguna.

DECLARATION
The witness answered the questions asked of her fully conscious that
she has done so under oath, and that she may face criminal liability for
false testimony or perjury if the answers are not true.

FORMAL OFFER OF TESTIMONY

The testimony of Mrs. Francisca B. Paladin, is being offered to prove
that:
1. She is the mother of deceased Andrew “Andy” Balde Paladin;

2. She did not participate in the Kasunduan entered between her

husband and her daughter, and the accused’s father;

3. She and her family experienced grief and financial setbacks due to
the death of Andy, especially during Christmas season;

DIRECT TESTIMONY

1. Please state your name and other personal circumstances.

I am Francisca B. Paladin, married, and a resident of 130 Maliksi

St., Jubileeville Subdivision, Brgy. Masaya, Bay, Laguna.

2. How are you related to the deceased, Andrew B. Paladin?

I am the mother of Andrew who was living with me and his father in
the same address.

3. When was the last time you saw your son alive?

In the early morning of December 24, 2017. My husband told me

that Andy toldhim that he would be attending simbang gabi at the
San Antonio Church along Lopez Avenue, Batong Malake, Los
Baños, Laguna. I saw him leave from our front door after he hugged
me.

4. What happened next?

Later, my husband received a call. He then told me that Andy was in

the Healthserv Hospital along the National Highway, Los Baños,
Laguna.

5. What did you do?

I immediately rushed to the hospital with my husband and

daughter. We say my son being attended at the Emergency Room.

6. What happened at the Emergency Room?

 The doctors told us that they were not able to revive him. They
declared him dead that same morning. He autopsied to have died
from “TRAUMATIC INJURIES OF THE HEAD AND ABDOMEN,
VEHICULAR ACCIDENT” as shown in a Death Certificate, a copy of
which is herewith attached as Annex A, and made an integral part
hereof.

7. What were the circumstances of his death?

I learned then that my son was hit by a vehicle while along Lopez
Avenue near the San Antonio Church where he said he was going.

8. Do you know the defendant in this case?

Yes, I do.

9. How did you get to know her?

Later in the afternoon, me along with my husband and my daughter

met with the accused who was said to be in the police station. She
was with her parents.

10. What transpired during the meeting?

The father started offering us money as compensation for the death

of our son. I ignored him, but my husband and daughter was
listening. The father invited us to his office, but I did not agree. I
discussed with my husband, and he said he would try to listen
because we may be financially unable to pay the expenses for Andy’s
hospitalization and burial.

11. What happened after?

I went home. Then my husband and daughter arrived after a few

hours, telling me they had an agreement with the father, and that
they signed a Kasunduan to that effect. I never took part in the
Kasunduan. There were also no updates from my husband on
whether payments were made by the father of the defendant on
December 27, 2017, and on January 15, 2018.
 12. How much did you spend in connection with the death of your
son?

My family spent a total of P193,419.60 for the hospital, funeral,

burial, and related expenses. The receipts of which expenses are
herewith attached as Annexes “B1” to “B7” and made an integral
part thereof.

13. Anything more you want to add?

As a mother, I am having difficulties in coping with the death of my

son. He was a very obedient and kind child. The last memory of him
was him respecting me and still telling us, his very old parents,
where he will be going. Despite also only being employed as a family
driver, he nonetheless continues to support our family. Our
Christmas will never be the same without Andy.

The affiant has nothing further to add.

Signed on August 27, 2018 in Laguna.

(sgd.)
FRANCISCA B. PALADIN
Affiant

SUBSCRIBED AND SWORN TO before me this 27th day of August 2018,

in Los Bañ os, Laguna, affiant exhibiting to me her Passport with number
A284912DP, issued in Laguna.

Doc No. ______ (sgd.)

Page No. ______ Atty. Filemon D. Nolasco
Book No. ______ Notary Public
Series of 2018. until Dec. 31, 2018
IBP OR No., 9021969; 1-03-18
PTR OR No., 067250; 1-09-18
MCLE 6 Compliance No. 0023361
th

Attorney’s Roll No. 38688

10460 Lopez Avenue,

Los Bañ os, Laguna
 LAWYER’S ATTESTATION

I, ATTY. SHYNAR LEI R. BETOYA, Filipino, of legal age, single, and with
address at SLRB Law Offices 1732 Rizal Ave., Los Bañ os, Laguna, after
being duly sworn, state that:

1. I am the lawyer who conducted the examination of the witness,

Mrs. Francisca B. Paladin;

2. I faithfully recorded the questions I asked and the corresponding

answers that the witness gave; and

3. Neither I nor any other person then present coached the witness
regarding his answers.

Signed on August 27, 2018 in Laguna.

(sgd.)
ATTY. SHYNAR LEY R. BETOYA
SLRB Law Offices 1732 Rizal Ave.,
Los Bañ os, Laguna

IBP OR No., 1135213; 1-03-18

PTR OR No., 1157291; 1-09-18
MCLE 6 Compliance No. 000532
th

Attorney’s Roll No. 11780215

SUBSCRIBED AND SWORN TO before me this 27th day of August

2018, in Los Bañ os, Laguna, affiant exhibiting to me her Driver’s License
with number N73-1241-318421, issued in Laguna, valid until Oct. 17,
2020.

Doc No. ______ (sgd.)

Page No. ______ Atty. Filemon D. Nolasco
Book No. ______ Notary Public
Series of 2018. until Dec. 31, 2018
IBP OR No., 9021969; 1-03-18
PTR OR No., 067250; 1-09-18
MCLE 6 Compliance No. 0023361
th

Attorney’s Roll No. 38688

10460 Lopez Avenue,

Los Bañ os, Laguna