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    Comment On Formal Offer of Evidence - TABANDA

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    Miko Tabanda
    This document contains the defendant's objections to the plaintiff's evidence in a civil case regarding collection of money. It summarizes the defendant's objections to each exhibit ("A" through "D") offered by the plaintiff as evidence. It also includes a counterclaim by the defendant seeking 20,000 PHP in attorney's fees due to the case. The defendant signs a verification of the facts stated in the answer.

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    Comment On Formal Offer of Evidence - TABANDA

    Uploaded by

    Miko Tabanda
    1K views4 pages
    This document contains the defendant's objections to the plaintiff's evidence in a civil case regarding collection of money. It summarizes the defendant's objections to each exhibit ("A" through "D") offered by the plaintiff as evidence. It also includes a counterclaim by the defendant seeking 20,000 PHP in attorney's fees due to the case. The defendant signs a verification of the facts stated in the answer.

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    Original Title

    Comment on Formal Offer of Evidence -TABANDA

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    This document contains the defendant's objections to the plaintiff's evidence in a civil case regarding collection of money. It summarizes the defendant's objections to each exhibit ("A" through "D") offered by the plaintiff as evidence. It also includes a counterclaim by the defendant seeking 20,000 PHP in attorney's fees due to the case. The defendant signs a verification of the facts stated in the answer.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    1K views4 pages

    Comment On Formal Offer of Evidence - TABANDA

    Uploaded by

    Miko Tabanda
    This document contains the defendant's objections to the plaintiff's evidence in a civil case regarding collection of money. It summarizes the defendant's objections to each exhibit ("A" through "D") offered by the plaintiff as evidence. It also includes a counterclaim by the defendant seeking 20,000 PHP in attorney's fees due to the case. The defendant signs a verification of the facts stated in the answer.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    You are on page 1of 4

    Republic of the Philippines

    First Judicial Region


    Branch No. 05
    Regional Trial Court
    Baguio City

    Dianne J. Bugayong Civil


    Case No. 172
    Plaintiff, For: Collection of
    Sum of Money
    Vs.
    Aileen S. Gamboa
    Defendant.
    x-----------------------------------------------------------------------------------
    -------x

    COMMENT/OBJECTIONS
    (To the Prosecution’s Formal Offer of Object and
    Documentary Evidence)

    The DEFENDANT by the undersigned counsel and unto


    this Honorable Court, most respectfully comments to
    the purpose of the offer as follows:

    “A” Contract of Loan Defendant through undersigned


    counsel, has no objection as the purpose
    of the exhibit but reserves his right to
    cross-examine such on all points.

    Defendant through undersigned counsel


    “B” BPI Check No. P3A-012345 objects to the admissibility of the exhibit
    on the ground that the Plaintiff failed to
    prove its genuiness and due execution
    and its existence in fact.

    Defendant through undersigned counsel


    “B-1” “DAIF” stamped on the objects to the admissibility of the exhibit
    check on the ground that the Plaintiff failed to
    prove its genuiness.

    Page 1 of 4
    “C” BPI Deposit Slip The defendant admits the issuance of
    the check but objects to the purpose of
    the offer which is to prove that the check
    was dishonored since no notice was
    given to the former.
    “D” Notice of Dishonor Defendant through the undersigned
    counsel admits the existence of the
    document but objects to the purpose as
    it does not prove anything and thus
    immaterial to the case.

    COUNTERCLAIM

    Due to this case, defendant expects to incur or spend


    attorney’s fees of not less than TWENTY THOUSAND PESOS
    (P20,000.00).

    PRAYER

    WHEREFORE, it is respectfully prayed of the Honorable


    Court that after hearing, it shall issue an order decreeing:

    1. That CIVIL CASE NO. 172 be dismissed.

    2. Order plaintiff to pay defendant actual attorney’s


    fees incurred in the amount of not less than TWENTY
    THOUSAND PESOS (P20,000.00).

    RESPECTFULLY SUBMITTED.

    In the City of Baguio, Philippines, this 25th day of


    August, 2018.

    TABANDA LAW OFFICE


    Suite 308 3/F Laperal Building
    Session Road, Baguio City
    2600 Philippines
    Telefax (083)552-5627
    Email: mikotabanda@gmail.com

    Page 2 of 4
    ________________
    ________________
    ATTY. MIKAEL LORENZO
    TABANDA
    Roll No. 51814
    IBP No. 021828-08/05/2017,
    Baguio City
    PTR No. 082818-08/06/2017,
    Baguio City

    VERIFICATION

    I, Aileen S. Gamboa, single, of legal age and resides


    at No. No. 231 Aurora Hill, Philippines, after having been duly
    sworn in accordance with law, do hereby depose and state
    that:

    1. I am the defendant in this case;

    2. I have caused the filing of the above answer;

    3. I have read the contents thereof and the facts


    thereon are true and correct according to my
    personal knowledge and on the basis of the copies of
    the documents and records I hold in my possession;

    4. I have not commenced any action or proceeding


    involving the same issues before the Supreme Court,
    Court of Appeals or before any tribunal or agency;

    5. To the best of my knowledge, there is no such


    pending action or proceeding before the Supreme
    Court, Court of Appeals or before any tribunal or
    agency;

    6. If I should thereafter learn that a similar action or


    proceeding has been filed or is pending before the
    Supreme Court, Court of Appeals or any other
    tribunal or agency, I undertake to report that fact
    within five (5) days therefrom, to this Honorable
    Court.

    Page 3 of 4
    IN WITNESS WHEREOF, I hereunto sign my hand this 14th
    day of September, 2018.

    AILEEN S. GAMBOA

    Subscribed and sworn to me this 14th day of September,


    2018, in the City of Baguio, Philippines.

    WITNESS MY HAND AND NOTARIAL SEAL.

    Doc. No. 29 ATTY. SAUL ARIES MARCK


    ORTIZ
    Page No. 32 Roll No. 5551: 03-02-10
    Book No. XVII IBP Lifetime: 3356
    Series of 2018 MCLE Compliance: II 12345
    PTR No. 86710

    Page 4 of 4

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