Cross Exam for Dada Mee:

Q1: How many years have you been in business Ms. Dada Mee?
A1: Whatever years
Q2: During said years, how often do you visit your store located in Brgy. 64,
Sagkahan, Tacloban City?
A2: Okay, so you are saying that _______________________________________
(whatever her answer is)

Q: In your judicial affidavit, you said that you sourced the security guards of your
warehouse in San Jose from Ammu Security Agency?
A: Yes.
Q: How long have you been sourcing your security guards from Ammu Security
Agency?
A: (Whatever) _____________
Q: Okay. So, you have been in partnership with Ammu Security Agency for said
years? Am I right?
A: Yes.
Q: One of the document attached in your judicial affidavit is the Contract of
Security Services with Ammu Security Agency, correct?
A: Yes.
Q: Was it notarized?
A: Yes.
Q: In said document, as you may see and read before the court, it is expressly
stipulated that the provision of security services will be at Sagkahan, Tacloban
City. Correct? Will you please read the first paragraph of the contract.
A: Yes. (Reads the first paragraph.)
Q: In fact, the said address was mentioned in the contract four times, first in the
first paragraph which you recently read, referring to Sagkahan, Tacloban City as
the place of business of Dadamo, 2nd was on the 2nd paragraph indicating the
property located in Brgy. 64, Sagkahan, Tacloban City as the premises where
Ammu will provide security services. Am I correct Ms. Dada Mee?
A: Yes.
Q: It was further reiterated on the Security Services stipulation saying that the
said services shall be performed at the same address. Correct? Please read the
number 1 stipulation in the contract.
A: Yes. (Reads the contract)
Q: Lastly was on the 4th stipulation referring to the Liability Insurance Disclaimer
of Ammu, stating no liability in case of any damage incurred in Sagkahan,
Tacloban City. Thus, from the express stipulation in the contract, the services
you contracted was to be performed on the property of Dadamo Wholesale and
Retailer at Sagkahan. Will you agree with me, Ms. Dada Mee?
A: Yes. (hesitantly… hahaha)
Q: Let it also be noted by the court, that never was the warehouse in San Jose,
Tacloban City ever mentioned in the said contract. Am I correct, Ms. Dada Mee?
A: Yes.
Q: Please review the document Ms. Dada Mee. There is none, correct?
A: Yes.
Q: Do you have other properties in Sagkahan, other than the Dadamo Wholesale
and Retailer store?
A: None.
Q: Now, are the security guards at your store in Sagkahan from Ammu Security
Agency?
A: Yes.
_____________________________________________________________________

Q3: Okaaay. Also, in your judicial affidavit, you mentioned that your warehouse is
separate from your retailing store which is the Dadamo Wholesale and Retailer?
How do you keep track of your employees’ attendance? Do you keep separate
logs of your employees at the warehouse in San Jose and at your store in
Sagkahan?
A3: Yes.
Q4: So, the logbook in your store in Sagkahan will contain records of your
employees’ attendance at said store?
A4: Yes.
Q5: Will it be possible that your employees at the warehouse in San Jose will sign
or record his / her attendance in the logbook at your store in Sagkahan?
A5: No.
Q6: Okay, so you are saying that the attendance of your store employees is only
recorded in the logbook you keep at your store in Sagkahan, while that of your
warehouse employees attendance will only be recorded in your logbook kept at
your warehouse in San Jose. Correct?
A6: Yes.

Q: You said in your judicial affidavit that you terminated the services of Jude and
Paulo after they were caught stealing from your warehouse, right?
A: Yes.
Q: Did you incur losses from the said incident?
A: Yes.
Q: Did you file a criminal case against Paulo and Jude?
A: No.
Q: Did you ever consider filing a criminal case against Paulo and Jude and see
that they are punished?
A: No.
No more questions, your honor.