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Republic of the Philippines

Department of Justice
REGIONAL TRIAL COURT
Branch ______
Neverland City

ALPHA COMPANY Docket No: 123456


Complainant,

-versus-

SPS. ADAM & EVE BRAVO, For: Recovery of


Respondents. Possession

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JUDICIAL AFFIDAVIT OF COCO A. BRAVO

I, COCO A. BRAVO, 70 years old, married to Anna M. Bravo,


residing at Lot 4, Block 3, Resistance Street, Glenwoods Subd., Neverland,
after having been sworn to in accordance with the law do hereby depose and
state:

That ATTY. CAROL S. MORALES is the counsel, affiliated with


MMMDQ Law Offices, located at G/F Q. Arch Tower, Poblacion, Neverland
City, who conducted and supervised my examination as a witness at the said
office;

That I, having been sworn in accordance with law and fully conscious
that I do so under oath and that I may face criminal liability for false testimony
or perjury;

PURPOSE

The affidavit for the defense is being offered to prove that the
respondent did not commit any act of depriving the petitioner from possession
of its property.

1. Q: State your name and other personal circumstances for the record.
A: I am COCO A. BRAVO, 70 years old, married to Anna M. Bravo,
residing at Lot 4, Block 3, Resistance Street, Glenwoods Subd.,
Neverland City.

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2. Q: What is your job?
A: I manage my own business, hence, I am self employed.1

3. Q: Do you know the respondents in this case?


A: Yes.

4. Q: How did you know the respondents?


A: I am the father of Adam Bravo named here as one of the respondents.

5. Q: Are you aware of the case filed against the respondents?


A: Yes.

6. Q: How are you aware of the case?


A: My wife and I lives two blocks away from the residence of my son,
I am aware of the situation that they are facing. I am the one who
donated the property to the Spouses in consideration of their marriage.

7. Q: How did you acquire the property in dispute?


A: My wife and I bought the property, because we want our son to have
a place near ours. That’s why when my son decided to get married, we
promptly prepared the transfer of the property in favor of my son and
his wife. Before their marriage we made sure that the property will be
transferred to them. Fortunately, the transfer was done right in time
before their marriage.

8. Q: Do you have the papers to support your claim regarding donation?


A: Yes.

9. Q: Do you recall the papers you signed in order to validly donate the
property?
A: Yes. We executed a document which contains the provision of
donations, and we were given a document which contains the
acceptance of the property we donated. (Footnote: 2: Exhibit B-Deed
of Donation, Exhibit C-Acceptance of Donation)

10.Q: Do you have any idea that other people, not Sps. Bravo, own the
qland that you donated?
A: No. I don’t have any idea. I was the one who bought the property
and the title of such was with me. Years passed and no one contest nor
claim any ownership of the property that we bought.

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Exhibit A – SEC Registration

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11.Q: Was there ever an instance that you have seen Sps. Bravo occupy
the land herein disputed?
A: Yes.

12.Q: Can you narrate before this Honorable Court the instances that you
have witnessed in support of the occupancy of Sps. Bravo?
A: Yes. My wife and I after buying the property and before donating
such, constructed a small nipa hut which serves as our “pampalipas
oras”. After donating the property, my son and his wife build their
house and they made use of the land. They managed to construct several
improvements in the property. The land was primarily used by my son
as a farmhouse in which they store crops, animals and equipment for
cultivation.

13.Q: Do you recall how many years have passed after you donated the
property?
A: Yes. I think approximately 30 years or more.

COCO A. BRAVO
Affiant

SUBSCRIBED AND SWORN TO before me this November 22, 2018


in Neverland City, the following affiant exhibiting to me her Passport No.
123890 issued at DFA Neverland being sufficient and competent evidence of
her identity pursuant to the 2004 Rules of Notarial Practice.

Doc. No. 02; PILIPINAS QUISING


Page No. 08; Notary Public for Muntinlupa
Book No. 5; Commision Serial No. 12345
Series of 2018. Until Dec 31, 2018
Roll of Attorney: 17865
IBP No. 234

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PTR No. 6573

I, ATTY. CAROL S. MORALES, of legal age, Filipino, with postal


address MMMDQ Law Offices, located at G/F Q. Arch Tower, Poblacion,
Neverland after being duly sworn depose and say:

1. I was the one who conducted the examination of COCO A. BRAVO at


my aforementioned office G/F Q. Arch Tower, Poblacion, Neverland:

2. I have faithfully recorded or caused to be recorded the questions I asked


and the corresponding answer that the witness gave;

3. I nor any other person then present or assisting her coached the witness
regarding her answers;

IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day


of November 2018 at Neverland.

ATTY. CAROL S. MORALES


Affiant

SUBSCRIBED AND SWORN TO before me this 22nd day of


November 2018 at Neverland, the following affiant exhibiting to me her
Passport No. 158157 issued at DFA Neverland being sufficient and competent
evidence of her identity pursuant to the 2004 Rules of Notarial Practice.

Doc. No. 02; PILIPINAS QUISING


Page No. 08; Notary Public for Muntinlupa
Book No. 5; Commision Serial No. 12345
Series of 2018. Until Dec 31, 2018
Roll of Attorney: 17865
IBP No. 234
PTR No. 6573