11th Judicial Region Branch 3 Nabunturan, Compostela Valley
Bridget Abad, Plaintiff, CIVIL CASE No. 220321
- versus – FOR: Damages for injuries, Loss
of earning capacity, Moral Davao Metro Shuttle damages and Attorney’s Fees. Corporation, Defendant. x- - - - - - - - - - - - - - - - - x
FORMAL OFFER OF DOCUMENTARY EVIDENCE
PLAINTIFF by the undersigned counsel and unto this
Honorable Court, most respectfully offers the following documentary and exhibits for the above titled case, to wit:
EXHIBITS DESCRIPTION PURPOSE/S
“A” Sinumpaang- To correlate the testimony in
Salaysay of Ms. the Judicial Affidavit (Exh. “C” Gloria Nitura for Plaintiff). “A-1” Signature of Ms. To prove that the witness duly Gloria Arafol executed the affidavit (Exh. “A”). “B” Sinumpaang- To corroborate the testimony of Salaysay of Mr. the first witness; Daveu Araneta To testify to the truth of the affidavit executed; To establish the circumstances surrounding the incident in question “B-1” Signature of Mr. To prove that the witness duly Daveu Araneta executed the affidavit (Exh. “B”). “C” Judicial Affidavit of To testify as the primary Mrs. Bridget Abad witness; To testify to the truth of the affidavit executed; To establish the circumstances surrounding the incident in 1 question; “C-1” Signature of Mrs. To prove that the witness duly Bridget Abad executed the affidavit (Exh. “C”). “D” Judicial Affidavit of To prove the performance of PO2 Dexter his duty as First Responder Senoron and Investigator within the scope of his duty and regular performance of duty; To testify to the truth of the affidavit executed; To identify the victim and the accused. “D-1” Signature of PO2 To prove that the witness duly Dexter Senoron executed the affidavit (Exh. “D”). “E” Pinagsamang To correlate the testimony in Sinumpaang- the Judicial Affidavit of the Salaysay of PO2 second witness. Dexter Senoron “F” Traffic Incident To provide the court Report information as to the circumstances of the incident “G” Medical Records To submit to the court and Certification of information of the cause of the Permanent Total injuries sustained by the Disability plaintiff; To corroborate the testimony of the first witness; To prove permanent total disability; “H” Letter addressed to To apprise the court of the Mrs. Bridget Abad subsequent effects of the re: Forced accident; Retirement Due to To prove the loss of earning Disability, signed by capacity of the plaintiff; Dep.Ed. SDS Cyrus Bohol “I” Medical Bills from To prove actual expenses Davao Doctors incurred on the part of the Hospital plaintiff;
Aforesaid exhibits are being offered to prove the breach of
contract of carriage due to the negligence of the diver of the
2 defendant, resulting to the permanent total disability of the plaintiff due to the incident at the address indicated in the Complaint.
WHEREFORE, premises considered, it is most respectfully
prayed to this Honorable Court that the foregoing object and documentary exhibits be admitted for which each and all said exhibits were offered in proving the claims of the complainant and with the formal submission of the aforesaid coupled with the testimonies of the witness who testified thereon.
Tagum City. July 14, 2018
LUNA MARIA DOMINIQUE S. ACOSTA
Counsel for the Plaintiff
NOTICE
The Hon. Clerk of Court
RTC Branch 3, Nabunturan, Compostela Valley
GREETINGS:
Please submit the foregoing Formal Offer for the consideration
and approval of the Honorable Court immediately upon receipt thereof.