Judicial-Affidavit-Of-Lucky P Santos Edited 2

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REPUBLIC OF THE PHILIPPINES

First Judicial Region


Regional Trial Court
Branch ___
City of San Fernando

PEDRO SAN JUAN Y GUERRERO,


Plaintiff,
LAND REGISTRATION CASE NO. ________
FOR: ANNULMENT OF TITLE and RECONVEYANCE
with Damages

-versus-

CARLO SAN JUAN Y GUERRERO


Defendants.

x---------------------------------/

JUDICIAL AFFIDAVIT OF
LUCKY P. SANTOS
I, Lucky P. Santos, of legal age, married, and self-employed, with
residence and postal address at Brgy. Biday, San Fernando City, La Union,:

PRELIMINARY STATEMENT

The person examining me is Atty. John Raymond Macusi with address


at XYZ Towers, Brgy. Lingsat San Fernando City 2500. The examination is
being held at the same address. I am answering his questions in English, a
language known to me and am fully conscious that I do so under oath and
may face criminal liability for false testimony and perjury.

OFFER

The testimony of the witness, Lucky P. Santos, is being offered to


serve as his direct testimony in this civil case and to prove:
1. That the witness was the original owner and seller of the said
property.
2. That the witness sold the property to the plaintiff-complainant Mr.
Pedro San Juan Y Guerrero.
3. That the witness and the plaintiff-complainant both contracted a
deed of sale on the selling of the said property in question.

JUDICIAL AFFIDAVIT PROPER

1. Q: Please state your name, age, residence, and occupation.


A: Lucky P. Santos, 49 years old, married, residing at Brgy. Biday, San
Fernando City, La Union and a plumber.

2. Q: Why are you here now?


A: To give a sworn statement by way of judicial affidavit, the same to
constitute as my direct testimony in the Complaint ANNULMENT OF
TITLE WITH RECONVEYANCE with Damages against Carlo G. San Juan.

3. Q: Who among the parties did you have a transaction with?


A: Pedro San Juan, the plaintiff-complainant of the case.

4. Q: How did you know the plaintiff-complainant?


A: He was the buyer whom I sold the property to.

5. Q:What is the total area of the land that you sold to the plaintiff-
complainant?
A: It is 4,900 sqm.

6. Q: Can you tell the Court, where is this property located?


A: The property is located in Barangay Biday, San Fernando City,
La Union.

7. Q: How did you know the total land area of the subject property?
A: Because I am the Original Owner of the land before I sold it to the
complainant-plaintiff

8. Q: How did you sell the property to the plaintiff-complainant?


A: We executed a Deed of Sale.

9. Q: If I showed you the Deed of Sale, Can you identify the contents of it?
A: Yes. it has a Original Certificate of Title No. 342 LOT 24-A- 0008
A parcel of land LOT 24-A- 0008 situated in the Brgy. Biday, City of San
Fernando, La Union …containing an area of forty-nine thousand (49000)
SQUARE METERS (OR 4.9 HECTARES).
10. Q: How did the plaintiff-complainant pay you and how much?
A: He paid me in cash. Three Hundred Thousand Pesos to be exact.

11. Q: Have you met at any point in your life the defendant in this case?
A: No, I have not.

IN WITNESS WHEREOF, I have hereunto set my hand this 16TH day of


March 2024 at City of San Fernando, La Union.

LUCKY P. SANTOS
Witness for the Plaintiff

SUBSCRIBED AND SWORN to before me this 16 th day of March 2024 at


City of San Fernando, La Union. Affiant exhibiting to me his Passport with
number ED9724403 valid until, September 15, 2026 as competent proof of
his identity.

ATTY. JOHN RAYMOND MACUSI


Counsel for the Plaintiff
Roll of Attorneys No. 88888
XYZ Towers, San Fernando City 2500, La Union, Philippines
IBP No. 10003, 02-01-2024, San Fernando City
PTR No. 987654 , 02-01-2024
MCLE No. 123456789, 02-01-2024, San Fernando City

Doc. No. 101;


Page No. 12;
Book No. 1:
Series of 2024

SWORN ATTESTATION OF THE LAWYER WHO CONDUCTED OR


SUPERVISED THE EXAMINATION OF THE WITNESS

The undersigned ATTY. JOHN RAYMOND MACUSI, of legal age, single,


and with law office address at XYZ Towers, Brgy. Lingsat San Fernando City
2500, under oath, deposes and states:
1. He is the Legal Counsel of the petitioner in the above-entitled petition;

2. He faithfully recorded or caused to be recorded the questions she


asked and the corresponding answers that the above-named witness gave;

3. Neither he nor any other person then present or assisting him coached
the witness regarding the latter’s answers; and

4. He conducted the examination of the petitioner at her law office


located at XYZ Towers, Brgy. Lingsat San Fernando City 2500 on March 16,
2024.

ATTY. JOHN RAYMOND MACUSI


Affiant

SUBSCRIBED AND SWORN to before me this 16th day of March 2024


at City of San Fernando affiant showing his competent proof of identity, to
wit: Driver’s License No. A04-00010001001, issued by Land Transportation
Office, City of San Fernando La Union, on August 27, 2023.

Doc No. 75;


Page No. 9:
Book No. 1:
Series of 2024

Copy Furnished:
Carlo San Juan, defendant

EXPLANATION AS TO SERVICE

A copy of this Judicial Affidavit is served on the Court and the


defendant and her counsel via registered mail due to the urgency of the
filing of the same, and the lack of field personnel of the undersigned
counsel at this time.
ATTY. JOHN RAYMOND MACUSI
Counsel for the Plaintiff
Roll of Attorneys No. 88888
XYZ Towers, San Fernando City 2500, La Union, Philippines
IBP No. 10003, 02-01-2024, San Fernando City
PTR No. 987654 , 02-01-2024
MCLE No. 123456789, 02-01-2024, San Fernando City

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