REPUBLIC OF THE PHLIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
BRANCH 250
MUNTINLUPA CITY
ANTONIO BOMBA,
ISSA DOLERO,
MIKE KWARTO,
12345678
VINCENT MANAL, and
MAXI PARI
Plaintiff,

CIVIL CASE No.

For: Damages

-versusCITY OF MUNTINLUPA,
Defendant,
x------------------------------------------------x
JUDICIAL AFFIDAVIT OF JOHN NITOR
This Judicial Affidavit of JOHN NITOR is executed to
serve as his direct testimony in the instant case. This Judicial
Affidavit is offered to prove: (1) all the allegations in the
Complaint; (2) including all the ANNEXES appended thereto,
which he respectfully requests to be correspondingly marked
as EXHIBITS in this case; and (3) all matters related thereto,
with reservation to present additional exhibits in the course
of the proceedings of the instant case.
QUESTIONS were propounded by plaintiffs counsel,
Atty.Claire Anne Paralejas, in English, which the affiant fully
understands, while ANSWERS were given in English or
Tagalog and the corresponding translation of his answer is
provided after each question.

1. Please state your name, age, residence address, and

occupation.
Ans. John Nitor, 39 years old, 90 Lovely street,
Marcos compound, Putatan, Muntinlupa City,
janitor of Public Market of City of Muntinlupa.
2. How long are you employed as janitor of the public
market of City of Muntinlupa?
Ans. 15 years.
3. In your job as a janitor, how often do you clean around
the area of the septic tank?
Ans. Twice a week.
4. In the 15 years of working as a janitor, have you ever
seen the septic tank re-emptied?
Ans. No.
5. Does the Public toilet in the public market have
ventilation?
Ans. No.
6. Please describe the Public toilet.
Ans. The public toilet has three (3) cubicles and
two (2) sinks and there are no windows.
7. How about the septic tank, can you describe it?

Ans. Yes.
8. Please describe the septic tank and its ventilation.
Ans. It has cover. There is no other means of
emission of gas but through the cover.
9. Given that the septic tank was not re emptied for
nineteen (19) years, do you think if people were to open
the septic tank cover and without ventilation in the
public toilet, would such people inhale toxic gas that
are emitted from the same that may cause their death?
Ans. Yes.
10.
Do you attest to the truthfulness of your
statements and allegations in the Judicial Affidavit?
Ans. Yes.
IN WITNESS WHEREOF, I have hereunto affixed my
signature this 14th day of January 2015, Muntinlupa City,
Philippines.
____________
JOHN NITOR
Witness
Affiant
JURAT
SUBSCRIBED AND SWORN to before me, a notary public
in and for John Nitor, this 12th day of January, 2015, at
Muntinlupa City, Philippines, affiants appearing before me
with the following:

AFFIANT
John Nitor

COMMUNITY TAX CERTIFICATE

NO.

90876567

ISSUANCE
01/05/2015-

Muntinlupa

AFFIANT
John Nitor

TIN NO.
4234-2678-2875

ISSUANCE
01/06/2015-

Muntinlupa

presenting to me the above instrument, affiant is identified

through his officially issued identity card bearing his
photograph and signature and Community Tax Certificate
and who signed said document in my presence and sworn as
to said document that he understood the contents thereof
and that the same was his free and voluntary act and deed.
PARALEJAS AND QUITCO
Law Office
Counsel for the Plaintif
Unit 1, Southgate Building,
Madrigal Business Park,
Alabang, Muntinlupa City
By:
CLAIRE ANNE F. PARALEJAS
PTR No. 1234567 01.03.12
Muntinlupa City
IBP No. 112233 01.29.12
PPLM Chapter
Roll No. 09876

VERICSON D. QUITCO
PTR No. 0987654 01.03.12
Muntinlupa City
IBP No. 223344 01.29.12
PPLM Chapter
Roll No. 03456
Copy furnished by Registered Mail w/ Return Card:
PADRE RESURRECCION & RODRIGUEZ
Counsel for the Defendant
23rd Floor,
Multinational Centre
6805Ayala Avenue,
Makati City
ATTESTATION
We, the undersigned counsels, of legal age, single, and
a resident of Muntinlupa City, after having been duly sworn
to in accordance with law, hereby depose and say, that:
(1)
I am the counsel of ANTONIA BOMBA, ISSA DOLERO,
MIKE KWARTO, VINCENT MANAL and MAXI PARI in Case
No.1001
(2)
I faithfully recorded or caused to be recorded the
questions I asked and the corresponding answers that the
witness gave for his Judicial Affidavit, and
(3) Neither I nor any other person then present or assisting
him coached the witness regarding the latters answers.
IN WITNESS WHEREOF, I have hereunto affixed my
signature this 14th day of January 2015, Muntinlupa City,
Philippines.
PARALEJAS AND QUITCO

Law Office
Counsel for the Plaintif
Unit 1, Southgate Building,
Madrigal Business Park,
Alabang, Muntinlupa City
By:
CLAIRE ANNE F. PARALEJAS
PTR No. 1234567 01.03.12
Muntinlupa City
IBP No. 112233 01.29.12
PPLM Chapter
Roll No. 09876
VERICSON D. QUITCO
PTR No. 0987654 01.03.12
Muntinlupa City
IBP No. 223344 01.29.12
PPLM Chapter
Roll No. 03456
EXPLANATION
Due to time, distance and manpower constraints,
copies of this Pre-trial Brief are being filed and served by
registered mail.
Muntinlupa City, February 18, 2015.
PARALEJAS AND QUITCO
Law Office
Counsel for the Plaintiff
Unit 1, Southgate Building,
Madrigal Business Park,
Alabang, Muntinlupa City
By:

CLAIRE ANNE F. PARALEJAS

PTR No. 1234567 01.03.12
Muntinlupa City
IBP No. 112233 01.29.12
PPLM Chapter
Roll No. 09876
VERICSON D. QUITCO
PTR No. 0987654 01.03.12
Muntinlupa City
IBP No. 223344 01.29.12
PPLM Chapter
Roll No. 03456
Doc. No. 2;
Page No. 1;
Book No. 1;
Series of 2015.

REPUBLIC OF THE PHLIPPINES

REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
BRANCH 250
MUNTINLUPA CITY
ANTONIO BOMBA,
ISSA DOLERO,
MIKE KWARTO,
12345678
VINCENT MANAL, and
MAXI PARI
Plaintiff,

CIVIL CASE No.

For: Damages

-versusCITY OF MUNTINLUPA,
Defendant,
x------------------------------------------------x
JUDICIAL AFFIDAVIT OF MANNY GER
This Judicial Affidavit of MANNY GER is executed to
serve as his direct testimony in the instant case. This Judicial
Affidavit is offered to prove: (1) all the allegations in the
Complaint; (2) including all the ANNEXES appended thereto,
which he respectfully requests to be correspondingly marked
as EXHIBITS in this case; and (3) all matters related thereto,
with reservation to present additional exhibits in the course
of the proceedings of the instant case.
QUESTIONS were propounded by plaintiffs counsel,
Atty. Claire Anne Paralejas, in English, which the affiant fully
understands, while ANSWERS were given in English or
Tagalog and the corresponding translation of his answer is
provided after each question.

1. Please state your name, age, residence address, and

occupation.
Ans. Manny Ger, 45 years of age, 87 Baguio street,
McKinley Village, Alabang, Muntinlupa City and
Supervisor of the Muntinlupa Public Market.
2. How long are you employed as supervisor of the public
market of City of Muntinlupa?
Ans. 5 years.
3. What are the work included in your job description in
relation to the safety and cleanliness of the public toilet
in the public market?
Ans. To make sure the place is at all times clean
and also for the safety of the people using the
same, to put up warning signs such as Wet floor
and other related signs.
4. So you allocate budget for the warning signs?
Ans. Yes.
5. In case the septic tank is re-emptied, is it in your job to
put up warning signs that toxic gas may be emitted, as
in the case if the floor has just been mopped to put
wet floor sign?
Ans. No, it not required for us to do so.
6. Then not putting up the warning sign that toxic gas
would be emitted if in case of re-emptying of the septic
tank would defeat your purpose in making sure of the
safety of the people using the public toilet?

Ans. Yes.
7. Do you attest to the truthfulness of your statements
and allegations in the Judicial Affidavit?
Ans. YES.
IN WITNESS WHEREOF, I have hereunto affixed my
signature this 14th day of January 2015, Muntinlupa City,
Philippines.
______________
MANNY GER
Witness
Affiant
JURAT
SUBSCRIBED AND SWORN to before me, a notary public
in and for Manny Ger, this 11th day of January, 2015, at
Muntinlupa City, Philippines, affiants appearing before me
with the following:
AFFIANT

COMMUNITY TAX CERTIFICATE

NO.

Manny Ger
Muntinlupa

AFFIANT
Manny Ger

01/06/2015-Muntinlupa

90876567
TIN NO.

ISSUANCE
01/05/2015-

ISSUANCE
4234-2678-2875

presenting to me the above ANSWER, affiant is identified

through her officially issued identity card bearing her
photograph and signature and Community Tax Certificate
and who signed said document in my presence and sworn as

to said document that he understood the contents thereof

and that the same was his free and voluntary act and deed.
PARALEJAS AND QUITCO
Law Office
Counsel for the Plaintif
Unit 1, Southgate Building,
Madrigal Business Park,
Alabang, Muntinlupa City
By:
CLAIRE ANNE F. PARALEJAS
PTR No. 1234567 01.03.12
Muntinlupa City
IBP No. 112233 01.29.12
PPLM Chapter
Roll No. 09876
VERICSON D. QUITCO
PTR No. 0987654 01.03.12
Muntinlupa City
IBP No. 223344 01.29.12
PPLM Chapter
Roll No. 03456
Copy furnished by Registered Mail w/ Return Card:
PADRE RESURRECCION & RODRIGUEZ
Counsel for the Defendant
23rd Floor,
Multinational Centre
6805Ayala Avenue,
Makati City
ATTESTATION

We, the undersigned counsels, of legal age, single, and

a resident of Muntinlupa City, after having been duly sworn
to in accordance with law, hereby depose and say, that:
(1)
I am the counsel of ANTONIA BOMBA, ISSA DOLERO,
MIKE KWARTO, VINCENT MANAL and MAXI PARI in Case
No.1001
(2)
I faithfully recorded or caused to be recorded the
questions I asked and the corresponding answers that the
witness gave for his Judicial Affidavit, and
(3) Neither I nor any other person then present or assisting
him coached the witness regarding the latters answers.
IN WITNESS WHEREOF, I have hereunto affixed my
signature this 14th day of January 2015, Muntinlupa City,
Philippines.
PARALEJAS AND QUITCO
Law Office
Counsel for the Plaintif
Unit 1, Southgate Building,
Madrigal Business Park,
Alabang, Muntinlupa City
By:
CLAIRE ANNE F. PARALEJAS
PTR No. 1234567 01.03.12
Muntinlupa City
IBP No. 112233 01.29.12
PPLM Chapter
Roll No. 09876
VERICSON D. QUITCO
PTR No. 0987654 01.03.12

Muntinlupa City
IBP No. 223344 01.29.12
PPLM Chapter
Roll No. 03456
EXPLANATION
Due to time, distance and manpower constraints,
copies of this Pre-trial Brief are being filed and served by
registered mail.
Muntinlupa City, February 18, 2015.
PARALEJAS AND QUITCO
Law Office
Counsel for the Plaintiff
Unit 1, Southgate Building,
Madrigal Business Park,
Alabang, Muntinlupa City
By:
CLAIRE ANNE F. PARALEJAS
PTR No. 1234567 01.03.12
Muntinlupa City
IBP No. 112233 01.29.12
PPLM Chapter
Roll No. 09876
VERICSON D. QUITCO
PTR No. 0987654 01.03.12
Muntinlupa City
IBP No. 223344 01.29.12
PPLM Chapter
Roll No. 03456
Doc. No. 3;
Page No. 1;

Book No. 1;
Series of 2015.
REPUBLIC OF THE PHLIPPINES
REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
BRANCH 250
MUNTINLUPA CITY
ANTONIO BOMBA,
ISSA DOLERO,
MIKE KWARTO,
12345678
VINCENT MANAL, and
MAXI PARI
Plaintiff,

CIVIL CASE No.

For: Damages

-versusCITY OF MUNTINLUPA,
Defendant,
x------------------------------------------------x
JUDICIAL AFFIDAVIT OF MARCO POLO
This Judicial Affidavit of MARCO POLO is executed to
serve as his direct testimony in the instant case. This Judicial
Affidavit is offered to prove: (1) all the allegations in the
Complaint; (2) including all the ANNEXES appended thereto,
which he respectfully requests to be correspondingly marked
as EXHIBITS in this case; and (3) all matters related thereto,
with reservation to present additional exhibits in the course
of the proceedings of the instant case.
QUESTIONS were propounded by plaintiffs counsel,
Atty.Claire Anne Paralejas, in English, which the affiant fully
understands, while ANSWERS were given in English or

Tagalog and the corresponding translation of his answer is

provided after each question.
8. Please state your name, age, residence address, and
occupation.
Ans. Marco Polo, 32 years of age, 12 Mahogany
street, Polar Village, San Antonio, Muntinlupa and
Engineer.
9. Which line of expertise are you engaged at in exercise
of your profession as Engineer?
Ans. Civil
and
Sanitary
Engineer,
mainly
construction and maintenance of septic tanks.
10.
Have you ever had the chance to inspect the
septic tank in the public market of Muntinlupa?
Ans. Yes.
11.

When were you able to inspect the same?

Ans. January 8, 2015 upon the approval of the city
government to inspect the same for the purpose of
this case.

12.
From your expert
describe the septic tank.

observation

and

findings,

Ans. It complied with the minimum requirements

of the law in constructing septic tanks such as the
inspection manhole that is in 0.42m 2 in which the
minimum area is 0.36m2. Also, that it is located in
not less than 25 meters away from well, spring,
cistern or other sources of drinking water supply.

However, the vented outlet baffle or sanitary tee

was damaged in which there is a problem
releasing the gas in the same from the septic tank
as in its usual escape.
13.
What do you think will be the effect of the
damaged outlet baffle?
Ans. Different from the usual escape of gas from
the septic tank, such escape would be faster that
would release more toxic gas in the air.
14.
Do you attest to the truthfulness of your
statements and allegations in the Judicial Affidavit?
Ans. Yes.
IN WITNESS WHEREOF, I have hereunto affixed my
signature this 14th day of January 2015, Muntinlupa City,
Philippines.
______________
MARCO POLO
Witness
Affiant
JURAT
SUBSCRIBED AND SWORN to before me, a notary public
in and for Marco Polo, this 11th day of January, 2015, at
Muntinlupa City, Philippines, affiants appearing before me
with the following:
AFFIANT
Marco Polo
Muntinlupa

COMMUNITY TAX CERTIFICATE

NO.

90876567

ISSUANCE
01/05/2015-

AFFIANT
Marco Polo

TIN NO.

ISSUANCE
4234-2678-2875

01/06/2015-Muntinlupa

presenting to me the above instrument, affiant is identified

through his officially issued identity card bearing his
photograph and signature and Community Tax Certificate
and who signed said document in my presence and sworn as
to said document that he understood the contents thereof
and that the same was his free and voluntary act and deed.
PARALEJAS AND QUITCO
Law Office
Counsel for the Plaintif
Unit 1, Southgate Building,
Madrigal Business Park,
Alabang, Muntinlupa City
By:
CLAIRE ANNE F. PARALEJAS
PTR No. 1234567 01.03.12
Muntinlupa City
IBP No. 112233 01.29.12
PPLM Chapter
Roll No. 09876
VERICSON D. QUITCO
PTR No. 0987654 01.03.12
Muntinlupa City
IBP No. 223344 01.29.12
PPLM Chapter
Roll No. 03456
Copy furnished by Registered Mail w/ Return Card:
PADRE RESURRECCION & RODRIGUEZ
Counsel for the Defendant

23rd Floor,
Multinational Centre
6805Ayala Avenue,
Makati City

ATTESTATION
We, the undersigned counsels, of legal age, single, and
a resident of Muntinlupa City, after having been duly sworn
to in accordance with law, hereby depose and say, that:
(1)
I am the counsel of ANTONIA BOMBA, ISSA DOLERO,
MIKE KWARTO, VINCENT MANAL and MAXI PARI in Case
No.1001
(2)
I faithfully recorded or caused to be recorded the
questions I asked and the corresponding answers that the
witness gave for his Judicial Affidavit, and
(3) Neither I nor any other person then present or assisting
him coached the witness regarding the latters answers.
IN WITNESS WHEREOF, I have hereunto affixed my
signature this 14th day of January 2015, Muntinlupa City,
Philippines.
PARALEJAS AND QUITCO
Law Office
Counsel for the Plaintif
Unit 1, Southgate Building,
Madrigal Business Park,
Alabang, Muntinlupa City
By:

CLAIRE ANNE F. PARALEJAS

PTR No. 1234567 01.03.12
Muntinlupa City
IBP No. 112233 01.29.12
PPLM Chapter
Roll No. 09876
VERICSON D. QUITCO
PTR No. 0987654 01.03.12
Muntinlupa City
IBP No. 223344 01.29.12
PPLM Chapter
Roll No. 03456
EXPLANATION
Due to time, distance and manpower constraints,
copies of this Pre-trial Brief are being filed and served by
registered mail.
Muntinlupa City, February 18, 2015.
PARALEJAS AND QUITCO
Law Office
Counsel for the Plaintiff
Unit 1, Southgate Building,
Madrigal Business Park,
Alabang, Muntinlupa City
By:
CLAIRE ANNE F. PARALEJAS
PTR No. 1234567 01.03.12
Muntinlupa City
IBP No. 112233 01.29.12
PPLM Chapter
Roll No. 09876

VERICSON D. QUITCO
PTR No. 0987654 01.03.12
Muntinlupa City
IBP No. 223344 01.29.12
PPLM Chapter
Roll No. 03456
Doc. No. 4;
Page No. 1;
Book No. 1;
Series of 2015.