JA - Edgar T. Digman (Plaintiff)

Republic of the Philippines
FIRST JUDICIAL REGION

MUNICIPAL TRIAL COURT OF LA TRINIDAD
Benguet Province
EDGAR T. DIGMAN,
Civil Case No.
Plaintiff,
_____________
- versus – FOR
RABERT A. LORENZO, FORCIBLE ENTRY
Defendant.
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JUDICIAL AFFIDAVIT
(For the Plaintiff EDGAR T. DIGMAN)
Plaintiff EDGAR T. DIGMAN, through counsel, unto this Honorable

Court, respectfully avers the following:
1. That herein witness Edgar T. Digman, is of legal age, married, Filipino

citizen, and a resident of MB 111 Puguis, La Trinidad, Benguet;
2. ATTY. REYNIEL LUTCHINA is the lawyer who conducted and

supervised the examination of the witness whose testimony was taken
and held at his law office located at 2nd Floor, Room 2, BSU Building,
Km. 5, Pico, La Trinidad, Benguet;
3. The witness-affiant is answering the questions asked of him fully

conscious and that he does so under oath and is aware that he may face
criminal liability for false testimony or perjury if he gives untruthful
statements.
By way of OFFER OF TESTIMONY, the witness-affiant herein states that

her testimony is being offered to prove the following:
a. Plaintiff is the owner of the lot covered under TCT No. 123456, which is
situated at Puguis, La Trinidad, Benguet;
b. Plaintiff had been in possession and occupation of the disputed property

since 2010;
c. Plaintiff entered into a Deed of Sale involving the subject lot with a
certain Albert James Escalderon;
Page 1 of 5
Judicial Affidavit of Edgar T. Digman
d. Plaintiff found out that defendant started occupying the subject lot during
the pandemic and when he was out of town;
e. Defendant deprived the plaintiff of his right to occupy and possess his
property;
f. Defendant occupied and possessed the subject lot through force, strategy
or stealth, which deprived the plaintiff from the possession of the same;
g. Plaintiff would also identify the documentary pieces of evidence attached

to this judicial affidavit.
h. He will identify documents and testify on other matters relevant to this

case.
With the offer above, transcribed below are questions propounded in ENGLISH, a
language known and understood by witness-affiant, and the answers to the
questions are also in the same language;
1. Q: Do you swear to tell the truth, the whole truth and nothing but
the whole truth?
A: I do.
2. Q: State your name and other personal circumstances.

A: I am EDGAR T. DIGMAN, legal age, married, Filipino, and a
resident of MB 111 Puguis, La Trinidad, Benguet, Philippines.
3. Q: Are you the same Edgar T. Digman, the plaintiff in this case?
A: Yes sir.
4. Why are you here?

A: To give a sworn statement by way of a judicial affidavit that would
constitute the same as my direct testimony against the defendant in the
above-captioned complaint.
5. Q: Why are you executing this Judicial Affidavit?

A: I am executing this Affidavit as my testimony in support to the
complaint against the defendant for Forcible Entry.
6. Q: Are you familiar with the subject land of the above-entitled case?
A: Yes, because I am the owner of the said subject land.
7. Q: Can you describe the subject property?

A: Yes, it is covered under TCT No. T-123456 particularly described as
follows:
AREA NO.: 300 square meters;

Tax Dec No: 123-456-789;
TITLE NO.: T-123456;
Page 2 of 5
8. Q: Where is it located?
A: It is located in Puguis, La Trinidad, Benguet, Philippines.
9. Q: Who was/were the previous owner/owners of the subject land?

A: The subject land was owned by Albert James Escalderon.
10.Q: Do you have proof to that?

A: Yes sir. I have with a copy of the TCT No. T-123456.
Counsel: May we respectfully pray unto the Honorable Court that this
copy of the TCT No. T-123456 be marked as Annex “A” and form an
integral part hereof.
11.Q: How did you acquire the said subject lot?

A: Sir, I bought it from Albert James Escalderon on June 10, 2010 by
virtue of the Deed of Absolute Sale.
12.Q: Do you have any proof of this?

A: Yes sir, I have here with me a copy of the Deed of Absolute Sale.
Counsel: May we respectfully pray unto the Honorable Court that the
copy of the Deed of Absolute Sale be marked as Annex “B” and form
an integral part hereof.
13.Q: What happened next, if any?

A: Sometime in the month of March, 2022, I discovered that the
defendant had been occupying the subject lot through force, strategy or
stealth, which deprived me from the possession of the same.
14.Q: Did you do something after knowing about it?

A: Yes, called the attention of the defendant and verbally demanded them
to vacate the lot but the latter refused to do so.
15.Q: What did you do next, if any?

A: I filed a complaint before the Lupon Tagapamayapa of Barangay
Puguis, La Trinidad, Benguet.
16.Q: How did the complaint before the Lupon Tagapamayapa

proceed?
A: The Punong Barangay had set the meeting but the defendant wilfully
failed or refused to appear without justifiable reason at the conciliation
proceedings before the Pangkat.

A: Yes sir, I have here with me a copy of the Certificate to File Action
issued by the Office of the Lupong Tagapamayapa.
Counsel: May we respectfully ask of the Honorable Court that the

copy of the Certificate to File Action issued by the Office of the
Page 3 of 5
Lupong Tagapamayapa be marked as Annex “C” and be made an
integral oart hereof.
18.Q: What did you do next, if any?

A: I sent a demand letter to the defendant, as the last resort before filing
an action, but to no avail.

A: Yes sir, I have here with me a copy of the Demand Letter.
Counsel: May we respectfully pray unto the Honorable Court that the
copy of the Demand Letter be marked as Annex “D” and be made an
integral part hereof.
20.Q: Do you have anything else to add or say?

A: None sir. That would be all.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 15th

day of July, 2022 at La Trinidad, Benguet
EDGAR T. DIGMAN
Affiant
SUBSCRIBED AND SWORN TO BEFORE ME THIS 15th day of July

2022 in La Trinidad, Benguet, Philippines. Affiant personally came and appeared
before me, exhibiting to me his Passport No. 0216 issued on August 12, 2020,
known to me and avowed under penalty of law to the whole truth of the contents
of said instrument.
Doc. No. 09
Page No. 2
Book No. 2 ATTY. REYNIEL LUTCHINA
Series of 2022 Counsel for the Plaintiff
Notarial Commission No. 11-2021
Until December 31, 2023
Roll No. 123456; June 17, 2016
IBP Lifetime No. 123456; Baguio-
Benguet
PTR No. 6418791 July 5, 2016, Benguet
MCLE Compliance No. VI-0007616
2nd Floor, Room 2, BSU Building,
KM5 Pico, La Trinidad, Benguet
Page 4 of 5
REPUBLIC OF THE PHILIPPINES)
Baguio City ) S.S
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ATTESTATION CLAUSE
I, REYNIEL LUTCHINA, of legal age, Filipino citizen and with office
address at 2nd Floor, Room 2, BSU Building, KM5 Pico, La Trinidad, Benguet,
Philippines, am the lawyer who conducted the examination of herein witness
EDGAR T. DIGMAN and hereby attest that a) I was the one who conducted the
examination of EDGAR T. DIGMAN, at my aforementioned office; b) I faithfully
recorded or caused to be recorded the questions I asked and the corresponding
answers that the said witness gave in ENGLISH a language known and understood
by the witness; and c) Neither I nor any other person then present or assisting the
said witness coached the witness regarding the latter’s answers;
IN WITNESS WHEREOF, I have hereunto affixed my signature over this

15th day of July 2022 at La Trinidad, Benguet, Philippines.
ATTY. REYNIEL LUTCHINA

Roll No. 123456
SUBSCRIBED AND SWORN to before me this 15th day of July 2022 in

La Trinidad, Benguet, Philippines. Affiant personally appeared and voluntarily
signed the foregoing Judicial Affidavit Affiant exhibited to me her valid
government identification issued by the Integrated Bar of the Philippines, bearing
the Lawyer’s Roll No. 123456, known to me as the same person who personally
signed the foregoing instrument before me and vowed under penalty of law to the
whole truth of its contents of his attestation.
Atty. Artemio Bustamante

Notary Public for Baguio City
Doc. No. 2 Commission No. 005-2021
Page No. 1 Until December 31, 2022
Book No. 3 Roll No. 98765 August 17, 2014, Baguio City
Series of 2022 3rd Floor, Room 7, Porta Vaga Building,
Session Road, Baguio City
Page 5 of 5

JA - Edgar T. Digman (Plaintiff)

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What is the nature of the case?

What is the nature of the case?

What evidence does the plaintiff provide to support their claim of ownership?

What evidence does the plaintiff provide to support their claim of ownership?

Republic of the Philippines

FIRST JUDICIAL REGION

Plaintiff EDGAR T. DIGMAN, through counsel, unto this Honorable

1. That herein witness Edgar T. Digman, is of legal age, married, Filipino

2. ATTY. REYNIEL LUTCHINA is the lawyer who conducted and

3. The witness-affiant is answering the questions asked of him fully

By way of OFFER OF TESTIMONY, the witness-affiant herein states that

b. Plaintiff had been in possession and occupation of the disputed property

g. Plaintiff would also identify the documentary pieces of evidence attached

h. He will identify documents and testify on other matters relevant to this

2. Q: State your name and other personal circumstances.

4. Why are you here?

5. Q: Why are you executing this Judicial Affidavit?

7. Q: Can you describe the subject property?

AREA NO.: 300 square meters;

9. Q: Who was/were the previous owner/owners of the subject land?

10.Q: Do you have proof to that?

11.Q: How did you acquire the said subject lot?

12.Q: Do you have any proof of this?

13.Q: What happened next, if any?

14.Q: Did you do something after knowing about it?

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

16.Q: How did the complaint before the Lupon Tagapamayapa

17.Q: Do you have any proof of this?

Counsel: May we respectfully ask of the Honorable Court that the

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

19.Q: Do you have any proof of this?

20.Q: Do you have anything else to add or say?

IN WITNESS WHEREOF, I have hereunto affixed my signature this 15th

SUBSCRIBED AND SWORN TO BEFORE ME THIS 15th day of July

IN WITNESS WHEREOF, I have hereunto affixed my signature over this

ATTY. REYNIEL LUTCHINA

SUBSCRIBED AND SWORN to before me this 15th day of July 2022 in

Atty. Artemio Bustamante

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