REPUBLIC OF THE PHILIPPINES

National Capital Region

REGIONAL TRIAL COURT
Branch 143
MAKATI CITY

JERWIN S. LAM-OK,
Plaintiff,

-versus- CIVIL CASE No. 123456

For: Damages

DELTA PHI CHI CORPORATION,

Defendant.
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JUDICIAL AFFIDAVIT

I, MANONG A. TOMAS twenty-five (29) years of age,

Filipino, residing at 511 Security Street, Red Horse Homes, Makati
City, after 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 by way of my answers to the
questions propounded to me by PATRICIA NICOLE Y. ACIDO, at
8th Floor, Tower One and Exchange Plaza, Makati City, do hereby
depose and state:

That this judicial affidavit is being offered to prove all the

allegations in the Answer, including all annexes appended thereto,
and all other related matters, facts, and circumstances relevant and
material to this case;

That this Judicial Affidavit is written in English, a language

known and understood by me; and

That the following are the questions propounded by counsel,

which are numbered consecutively, followed by the answer, which
shall serve as my direct testimony in this case.
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JUDICIAL AFFIDAVIT
Jerwin Lam-Ok v. Delta Phi Chi Corporation
Civil Case
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Q Please state your name for the record.

1
A My name is Manong A. Tomas
Q Where do you currently reside?
2 I live in 511 Security Street, Red Horse Homes, Makati
A
City.
Q What is your present occupation?
3
A I am a security guard for DPC village, sir.
Q Who is your employer?
4
A The Securitron Security Service Corporation
Since you are employed as a security guard, where do
Q
you report for work?
5
I am deployed at the DPC village sir, as a guard in its
A
clubhouse
Q Which is located where, Mr. Witness?
6
A In Club Street, Delta Phi Chi Village, Makati City.
Q How long have you been deployed there?
7 I’ve been deployed in the village for 3 years, and
A
stationed at the clubhouse for 1 year.
Can you explain to this court your duties and
Q responsibilities as a security guard stationed at the club
house?
8
I just normally just stand guard at the club house, do
A roaming around the vicinity of the club house.

9. Q Are you subject to any supervision by the Village?

Yes, we are briefed every morning by the Delta Phi Chi
A
Corps homeowners head at 6am
Q. What do these briefings cover?
Usually we are reminded of our daily routine and given
additional instructions for special circumstances such as
10 A.
expected constructions done by homeowners.

11 Q. Did you have a briefing at the morning of Jan 30, 2018

A. Yes.

12. Q. What was discussed in this briefing?

We were reminded of our usual duties and the issue of
the playground being closed for the week for renovation
A.
was raised, thus we were reminded to be more vigilant as
the kids will be playing all around the village.
Q Where is the water tan located?
13
A The village water tank lot is across the clubhouse.
14 Q Can you describe the area of the water tank?
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JUDICIAL AFFIDAVIT
Jerwin Lam-Ok v. Delta Phi Chi Corporation
Civil Case
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The water tank is enclosed by a wired fence, and the only

entrance is locked with a padlock that the guards have. It
A
also has a warning which states that NO
ENTRY/BAWAL PUMASOK.
Interesting. Mr. Witness, can you please tell this Court
Q
15 what were doing on 30 January 2018 at around 5:00pm?
A I was doing my vicinity rounds around the club house.
Did you notice anything peculiar while you were doing
Q
your rounds??
16
None, before starting my rounds, I even checked on the
A
lock which was still intact.
What did you do when you heard cries of help in the
Q
17 water tank area?
A I immediately responded and ran towards the area.
Q What happened after?
I found Jerry unconscious in the hands of the houseboy, I
18
A immediately radioed to request an ambulance. I tried
basic first aid measures such as CPR.
Q And then?
19 I keep on trying to revive jerry until the ambulance
A
arrived.
 Page 4 of 7
JUDICIAL AFFIDAVIT
Jerwin Lam-Ok v. Delta Phi Chi Corporation
Civil Case
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IN WITNESS WHEREOF, I have hereunto affixed my

signature this 1st day of April 2018 at Makati City, Philippines.

DEREK R. MANONG
Affiant

SUBSCRIBED AND SWORN to before me this 1st day of April

2018 in Makati City, Philippines, affiant exhibiting to me her Voter’s
ID No. 7603-008B-J0181LAP10000 issued by the Commission on
Elections on 11 September 2017 in Manila City.

JUAN DELA CRUZ

Notary Public
Commission No. 022, Until Dec. 31, 2018, Makati
IBP Lifetime No. 09144, 04/29/10
PTR No. 37764340, 10/27/2017, MakatiCity
Roll No. 56070
MCLE Exemption No. V-000513, 06/24/15
 Page 5 of 7
JUDICIAL AFFIDAVIT
Jerwin Lam-Ok v. Delta Phi Chi Corporation
Civil Case
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Doc. No.
Page No.
Book No.
Series of 2018
 Page 6 of 7
JUDICIAL AFFIDAVIT
Jerwin Lam-Ok v. Delta Phi Chi Corporation
Civil Case
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ATTESTATION OF LEGAL COUNSEL

I, ATTY. JOSE ANGELO C. TIGLAO, of legal age, Filipino,

with office address at 30th Floor, 88 Corporate Center, Makati City, do
hereby certify that:

1. I propounded the questions to MARIO DELA CRUZ and

faithfully recorded or caused to be recorded the questions I
asked and the corresponding answer that the witness gave; and
2. I nor any other person then present or assisting him, coached
the witness regarding his answers.

IN WITNESS WHEREOF, I have hereunto affixed my signature

this 1 day of April 2018 at Makati City, Philippines.
st

JOSE ANGELO C. TIGLAO

Counsel for the Plaintiff
Roll No. 98765
IBP Lifetime No. 12345, 04/23/10
PTR No. 3802389, 01/04/17, Makati City
MCLE Compliance No. V-0011812, 11/10/15

SUBSCRIBED AND SWORN to before me this 1st day of April

2018 in Makati City, Philippines, affiant exhibiting to me his Voter’s
ID No. 7603-008B-J0181LAP10000 issued by the Commission on
Elections on 11 September 2017 in Manila City.

JUAN DELA CRUZ

Notary Public
Commission No. 022, Until Dec. 31, 2018, Makati
IBP Lifetime No. 09144, 04/29/10
PTR No. 37764340, 10/27/2017, Makati City
Roll No. 56070
MCLE Exemption No. V-000513, 06/24/15
 Page 7 of 7
JUDICIAL AFFIDAVIT
Jerwin Lam-Ok v. Delta Phi Chi Corporation
Civil Case
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Doc. No.
Page No.
Book No.
Series of 2018

Copy furnished:

Atty. Patricia Nicole Acido

Counsel for the Defendant