MADRID, JEFFERSON B.

PRACTICE COURT
2 Section 4S (2019400257) ATTY. JOHN JACOME

REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
BRANCH 69
Quezon City

XYZ BANKING CORP.

Represented by its General Manager
Winston D. Dela Cruz,
Plaintiff,

- versus - Civil Case No. 3658-S

For: Specific Performance,
Collection and damages with
Prayer for Preliminary
Attachment
GLENDA HUWEBES
Defendant.
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OBJECTIONS
(TO THE JUDICIAL AFFIDAVIT OF LORNA B. MANGAT)

DEFENDANT, by counsel, respectfully comments/objects to

following regarding the JUDCIAL AFFIDAVIT of LORNA B. MANGAT as
follows:

1. That the judicial affidavit should be rendered inadmissible, in

accordance with Section 10 of the Judicial Affidavit Rule (A.M. No.
12-8-8-SC) (JAR), for not complying with Sections 3 and 4 of the
JAR with respect to the following:
 a. That there were some attachments which was not submitted with
the judicial affidavit, hence Exhibit “E”, and Exhibit “F” of the
judicial affidavit were not identified or authenticated.
b. That there was no statement stating that a false attestation shall
subject the lawyer mentioned to disciplinary action, including
disbarment.

2. That questions number 3 to 8 should be rendered inadmissible in

evidence for lack of basis, the questions and answers assumes facts
not established. No evidence has been presented shows that the
witness has been employed by XYZ Bank.

3. That question number 11 and 12 should be rendered inadmissible in

evidence for not laying the proper foundation and being a conclusion
of fact, the witness has not properly described Defendant much to
conclude that proper identification has been achieved.

4. That question number 15 should be rendered inadmissible in

evidence for not laying the proper foundation. The bank process of
obtaining the loan was not explained. The answer was merely a
conclusion of fact.

5. That question number 17 should be rendered inadmissible in

evidence for being a leading question. The question suggests an
answer from the witness pertaining to the character of the loan.

6. That question number 19 should be rendered inadmissible in

evidence for being a conclusion of fact. The question suggests an
answer from the witness pertaining to the character of the loan.

7. That question 24 should be rendered inadmissible in evidence for

being a leading question. The question suggests an answer from the
witness pertaining to the character of the loan.

8. That question 25 should be rendered inadmissible in evidence for

being a leading question. The question suggests an answer from the
witness pertaining to the character of the loan.
9. That question 26 should be rendered inadmissible in evidence for
being a leading question. The question suggests an answer from the
witness pertaining to the payment of the loan.

10. That question 31 should be rendered inadmissible in evidence for

being a leading question. The question suggests an answer from the
witness pertaining to the payment of the loan.

11. That question 33 should be rendered inadmissible in evidence for

being a leading question. The question suggests an answer from the
witness pertaining to the payment of the loan.

ATTY. TOSHIBA D. ASUS

Counsel for Defendant
ABC Law Firm
Tandang Sora, Quezon City
Roll No. 5619865
PTR No. 65116556 – 01/05/2017
IBP No. 9873215 – 01/05/2017
Both in Quezon City
MCLE Compliance No. 5619842