Judicial Affidavit Respondent Rez Catedral

Republic of the Philippines
REGIONAL TRIAL COURT

Sixth Judicial Region
Branch 20
Family Court
Iloilo City
-oOo-
FAITH V. CATEDRAL, CIVIL CASE NO. M-16-0000-22

P
etitioner,
FOR: DECLARATIN OF
NULLITY OF MARRIAGE
UNDER ARTICLE 35
PARAGRAPH (3) OF THE
FAMILY CODE
- versus –
REZ KRISTOFFER JUN Z. CATEDRAL,

Respondent.
x--------------------------------------x
JUDICIAL AFFIDAVIT
Witness: JIMMY SANTOS-BRYANT
PURPOSE OF THE TESTIMONY
1. To prove that he is the defendant in the instant case;
2. To prove that he entered into a loan agreement with Plaintiff Pao

Tang Lending, Inc. (Plaintiff, hereafter), in the amount of One Million Pesos
(Php 1,000,000.00) secured by a promissory note dated November 21, 2019,
payable on November 21, 2021, with interest at six percent (6%) per annum;
3. To prove that he has made several payments to Plaintiff by reason

of the loan agreement, prior to the filing of this instant case;
4. To prove that despite his payments, Plaintiff unilaterally

rescinded their loan agreement, and demanded the entire sum of One Million
1
Pesos (Php 1,000,000.00), exclusive of interest without deducting payments
already made by defendant;
5. To prove other relevant matters concerning the foregoing; and

6. That this Judicial Affidavit shall serve as his direct testimony.
REPUBLIC OF THE PHILIPPINES)

CITY OF ILOILO ) S.C.
X - - - - - - - - - - - - - - - - - - - - - - - - - - ---x

JUDICIAL AFFIDAVIT
I, JIMMY SANTOS-BRYANT, of legal age, Filipino, single, and with

address at Quintin Salas Street, Jaro, Iloilo City, Philippines, state under oath
as follows:
PRELIMINARY STATEMENT
The person examining me is ATTY. MARIO MIGUEL F. TABURNOK, of

legal age, single, Filipino, with office address at TABURNOK LAW OFFICE,
Dawn Building, Sibalom, Antique, Philippines. The examination is being held
at the same address. I am answering his questions fully conscious that I do so
under oath and may face criminal liability for false testimony and perjury.
1. Q: Mr. witness, can you please state your name and other
personal circumstances?
A: I am JIMMY SANTOS-BRYANT, of legal age, Filipino, single,

and with address at Quintin Salas Street, Jaro, Iloilo City,
Philippines;
2. Q: Can you please tell us why you are here today?
A: I am here today because I want to testify in support of the

ANSWER WITH SPECIAL AND AFFRMATIVE DEFENSES filed
by Pao Tang Lending, Inc., through their representative,
Tanjiro Kamado-Reyes, against me;
3. Q: Earlier you said that you are here to give your testimony in
support of the Answer filed by your counsel. What is it that you
wanted to testify on?
A: I am here because I want to testify that I have made

payments with regard to my loan obligation, and that prior to
the date of maturation of the promissory note which I
executed, plaintiff and I agreed on an extended date of
2
payment due to financial restraints brought about by the
Covid-19 Pandemic;
4. Q: You mentioned a Promissory Note, can you elaborate

further on the circumstances surrounding its due execution, if
any?
A: Yes, on November 2019, I approached Tanjiro Kamado-

Reyes (“Tanjiro”, hereafter), the Senior Accounts Manager of
Pao Tang Corporation, seeking for a loan to cover expenses the
former incurred in the management of his business.
Thereafter, on November 21, 2019, Tanjiro, representating Pao
Taong Lending Corporation, tried to reach me and offered me
to avail of their loan services to finance the my expenses for my
business operations;
5. Q: What happened next, if any?
A: I confided to Tanjiro that it was his first time to obtain loan

services from a Lending Company. I firmly echoed reservations
in availing the same primarily because I did not want to secure
the loan with any collateral, real or personal property or other
assets;
6. Q: What happened next, if any?
A: Tanjiro was most reassuring in offering me a loan with

terms that will allow me to secure a ready source for
additional capital without entailing him to offer any collateral
because he has sufficient business assets to fulfill payment of
the loan;
7. Q: What happened thereafter?
A: I furnished Tanjiro with Pinay Fleek’s registration

documents, its audited financial statements and other
supporting documents which they required until these were
found complete and in order;
(The audited financial statements of Pinay Fleek are hereto

attached as EXHIBIT “2” forming an integral part of this
Answer)
8. Q: What happened next?
3
A: To allay whatever fear or apprehension I had in availing the
credit facilities, Plaintiff Pao Tang extended to me a “clean
loan”—a personal loan without any security at stake, with loan
value amounting to One Million Pesos (PHP 1,000,000.00). And
on November 21, 2019, I acquiesced to Pao Tang’s terms and
was granted the approved loan amount of One Million pesos
(PhP 1,000,000.00), due on November 21, 2021, with an
interest at a rate of 6% per annum, among others;
9. Q: What happened after you executed the Promissory Note

dated November 21, 2019?
A: From thereon, I successively paid Pao Tang my dues in timely

increments, and as evidence thereof, I have with me a copy of
the Acknowledgement Receipt No. 69 issued by Pao Tang
Lending, Inc.;
(The acknowledgement reciept no. 69 is attached hereto as

ANNEX “3” and made an integral part of this answer)
10. Q: What else happened, if any?
A: However, at the onset of the Covid-19 Pandemic, as well as

various lockdown periods, my business, Pinay Fleek, suffered
major losses attributable to the three month long lockdown
imposed by the government, thereby hampering its business
ventures;
11. Q: How is that so?
A: On January 30, 2020, SARS-CoV-2 viral RNA was reported to

be detected by PCR on the initial swabs of the first confirmed
case in the Philippines. In March 2020, President Rodrigo
Duterte implemented hard lockdowns (i.e Enhanced Community
Quarantine) across the country in an attempt to arrest the
COVID-19 infection. Nationwide lockdowns imposed by the
government have adversely impacted people’s livelihood. My
business was hit hard, with clients terminating their contracts
and engagement abruptly tanked. Ultimately, my business,
Pinay Fleek, was closed down;
12. Q: What did you do next, if any?
A: Despite this, however, I still made payments to Pao Tang,

though eventually, I was constrained to send a letter to the
4
latter asking for a moratorium on payments to enable me to
recover from my losses;
(Said letter is attached hereto as ANNEX “4” and is made an

integral part of this answer)
13. Q: What did Plaintiff do after you sent them that letter, If any?
A: Plaintiff Pao Tang welcomed my letter and thereby granted

the moratorium, agreeing to a gentlemen’s agreement wherein
the latter would be given ample time to pay his dues;
14. Q: What happened thereafter, if any?
A: On February 2, 2022, I received from plaintiff a Final

Demand to Pay, through counsel, which informed me that my
loan was due and demandable, and failure to do so would
result in legal action. This came as a shock to me as I was not
aware that my obligation was now due and demandable, and
furthermore, I was of the notion that Plaintiff Pao Tang had
agreed to extend the period of payment;
15. Q: What can you say about the Complaint filed by the Plaintiff?
A: I was terribly dismayed by the actuations of the plaintiff. In

their Complaint, they makes it appear as though I have not paid
them a single centavo. I have been doing my best to diligently
pay them, but these were all left to naught when she filed this
case against. I pray that this case be dismissed, for the reason
that we have shown sufficient evidence to prove that the
Plaintiff has no cause of action to bring this case to court.
16. Q: What else do you want to say, if any?
A: For unceremoniously dragging this case to court, I also pray

that the Plaintiff be made to pay Actual Damages, representing
the costs we incurred in securing the services of a lawyer in the
amount of Php 50,000.00, Moral Damages in the amount of Php
100,000.00, and costs of suit.
17. Q: Do you affirm and confirm the contents of this Judicial

Affidavit?
A: Yes.
IN WITNESS WHEREOF, I have hereunto set my hand this ___ day of

May 2022 at the City of Iloilo, Philippines.
5
JIMMY SANTOS-BRYANT
Affiant
JURAT/NOTARIAL CERTIFICATE
The affiant whose name and personal circumstances are stated above
appeared in person before me this _____ day of May 2022 in the City of Iloilo,
Philippines, presented the foregoing Affidavit, signed the same in my
presence, and affirmed or swore under oath to the truth and correctness of
the contents or allegations of the same.
I personally know the affiant and she exhibited to me his PWD ID No.
129037532-198204 as competent proof of identity.
Doc. No. ___;

Page No. __;
Book No. __;
Series of 2021.
ATTESTATION CLAUSE
I, MARIO MIGUEL F. TABURNOK, of legal age, Filipino, single, with

address at A. PANES LAW, Dawn Building, Sibalom, Antique, Philippines, after
having been sworn in accordance with law hereby attest and say, THAT:
1. I am the counsel/lawyer who conducted the examination of the

witness JIMMY SANTOS-BRYANT;
2. I attest that I have faithfully recorded the questions I asked and the
corresponding answers that the said witness gave;
3. I likewise attest that neither I nor any other person then present or
assisting the said witness has coached him regarding his answers;
4. And I finally attest that what the witness has answered the questions
all true to her own knowledge and belief and I understand that any
falsity that I may cause shall be a ground for disciplinary action as a
lawyer.
IN WITNESS WHEREOF, I have hereunto set my hand this ____ day of

May, 2022 at the City of Iloilo, Philippines.
6
MARIO MIGUEL F. TABURNOK
Affiant
JURAT/NOTARIAL CERTIFICATE
The affiant whose name and personal circumstances are stated above
appeared in person before me this ____ day of May 2022 in the City of Iloilo,
Philippines, presented the foregoing document, signed the same in my
presence, and affirmed or swore under oath to the truth and correctness of
the contents or allegations of the same.
The affiant is personally known to me and he exhibited to me his IBP ID

with Attorney’s Roll No. 11021.
RHEINHART G. PAHILA
Doc. No. ____; NOTARY PUBLIC
Page No. ___; UNTIL DECEMBER 31, 2021
FOR THE CITY AND PROVINCE OF ILOILO
Book No. ___; SECOND FLOOR, SEVENTY N BUILDING,
Series of 2022. JALANDONI STREET, JARO ILOILO CITY
NOTARIAL COMMISSION REG. NO. 77/ 2-26-2020
PTR NO. 7256685 / January 4, 2021 / Iloilo City
IBP Temporary Receipt No. 01003/ January 04, 2021 / Iloilo City
ATTORNEY’S ROLL NO. 72374
MCLE COMPLIANCE NO. VII-0002320 / APRIL 14, 2022

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Republic of the Philippines

REGIONAL TRIAL COURT

FAITH V. CATEDRAL, CIVIL CASE NO. M-16-0000-22

REZ KRISTOFFER JUN Z. CATEDRAL,

Witness: JIMMY SANTOS-BRYANT

PURPOSE OF THE TESTIMONY

1. To prove that he is the defendant in the instant case;

2. To prove that he entered into a loan agreement with Plaintiff Pao

3. To prove that he has made several payments to Plaintiff by reason

4. To prove that despite his payments, Plaintiff unilaterally

5. To prove other relevant matters concerning the foregoing; and

REPUBLIC OF THE PHILIPPINES)

I, JIMMY SANTOS-BRYANT, of legal age, Filipino, single, and with

The person examining me is ATTY. MARIO MIGUEL F. TABURNOK, of

A: I am JIMMY SANTOS-BRYANT, of legal age, Filipino, single,

2. Q: Can you please tell us why you are here today?

A: I am here today because I want to testify in support of the

A: I am here because I want to testify that I have made

4. Q: You mentioned a Promissory Note, can you elaborate

A: Yes, on November 2019, I approached Tanjiro Kamado-

5. Q: What happened next, if any?

A: I confided to Tanjiro that it was his first time to obtain loan

6. Q: What happened next, if any?

A: Tanjiro was most reassuring in offering me a loan with

7. Q: What happened thereafter?

A: I furnished Tanjiro with Pinay Fleek’s registration

(The audited financial statements of Pinay Fleek are hereto

8. Q: What happened next?

9. Q: What happened after you executed the Promissory Note

A: From thereon, I successively paid Pao Tang my dues in timely

(The acknowledgement reciept no. 69 is attached hereto as

10. Q: What else happened, if any?

A: However, at the onset of the Covid-19 Pandemic, as well as

11. Q: How is that so?

A: On January 30, 2020, SARS-CoV-2 viral RNA was reported to

12. Q: What did you do next, if any?

A: Despite this, however, I still made payments to Pao Tang,

(Said letter is attached hereto as ANNEX “4” and is made an

A: Plaintiff Pao Tang welcomed my letter and thereby granted

14. Q: What happened thereafter, if any?

A: On February 2, 2022, I received from plaintiff a Final

A: I was terribly dismayed by the actuations of the plaintiff. In

16. Q: What else do you want to say, if any?

A: For unceremoniously dragging this case to court, I also pray

17. Q: Do you affirm and confirm the contents of this Judicial

IN WITNESS WHEREOF, I have hereunto set my hand this ___ day of

Doc. No. ___;

I, MARIO MIGUEL F. TABURNOK, of legal age, Filipino, single, with

1. I am the counsel/lawyer who conducted the examination of the

IN WITNESS WHEREOF, I have hereunto set my hand this ____ day of

The affiant is personally known to me and he exhibited to me his IBP ID

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