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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
National Capital Judicial Region
Branch 77, Quezon City

WILLIE FERNANDO S. MAALIW,

Complainant,

- Versus - Civil. Case No. Q-99-38219

For: Damages

REYNATUS SAN JUAN, ET AL.,

Accused.
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FORMAL OFFER OF EVIDENCE

COMPLAINANT, by counsel, to this Honorable Court, Formally Offer’s

his Evidence to wit:

EXHIBIT PARTICULARS

“A” Memo to the Vice President of PMED dated 29 August

1997

“A-1 to A-2” Signatures of the PMED Staff

PURPOSE: To show the malicious and baseless complaint of

defendants against complainant that caused damages to the latter. It is also

offered to prove the lack of basis on the part of defendants to make such complaint

against herein complainant.

EXHIBIT PARTICULARS

“B” Memo from the VP-FMEG Re: Request for Formal

Investigation dated September 15, 1997

PURPOSE: To show and prove that the baseless complaint contrived by

defendants was given due course that ultimately brought damage and prejudice to

complainant;
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EXHIBIT PARTICULARS

“C” Memo from Willie Maaliw Reply to memo of PMED

Staff dated August 29, 1997

“C -1- C-19” Continuation of Memo from W. Maaliw

PURPOSE: To show and prove that the Administrative complaint against

Maaliw that was given due course was baseless as explained in the document and

the complaint was calculated to cause damage and prejudice to Maaliw;

EXHIBIT PARTICULARS

“D” Memo from the Office of the General Counsel

dated Sep. 16, 1999

“D-1” Dispositive Portion from the Memo from the Office of

the General Counsel

PURPOSE: To show and prove that Maaliw was proven not liable to the

malicious complainant of Gross Discourtesy in the Course of Official duty contrived

by defendants.

EXHIBIT PARTICULARS

“E” Statement of Account of the Complainant from Citibank

dated 09/13/88 amounting to P 54,639.88

“F” Statement of Account of the Complainant from Citibank

dated 09/27/88 amounting to P 31,201.00

“G” Written Formal Complaint with Preliminary Attachment

form the Counsel of City bank dated August 21, 2000 .

PURPOSE: To show and prove the damage suffered by Maaliw from the

contrived complaint of defendants as a consequence of the forfeiture of Maaliw’s

employment benefits. The damage suffered under the documents is financing

charges for failure to pay monthly dues on purchases with Citibank card in the total

amount of P 305,190.67 as of August 21, 2000. Further, the exhibits are offered to

show that complainant is under threat of being sued causing anxiety and besmirch

reputation.
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“H” Statement of Account of the Complainant from Bankard

Dated 09/22/88 amounting to P 18,041.32

PURPOSE: To show and prove the damage suffered by Maaliw from the

contrived complaint of defendants as a consequence of the forfeiture of Maaliw’s

employment benefits. The damage suffered under the document is financing charges

for failure to pay monthly dues on purchases with BANKARD and financing

charges in the total amount of P 18,041,32 as of October 18, 1998.

“I” Demand Letter from the Counsel of Far East bank dated
March 16, 2000.

PURPOSE: To show and prove the damage suffered by Maaliw from the

contrived complaint of defendants as a consequence of the forfeiture of Maaliw’s

employment benefits. The damage suffered under the document is financing charges

for failure to pay monthly dues on purchases with FAREASTCARD in the total

amount of P 47,890.60 as of February 10, 200. Further, the exhibit is offered to

show that complainant is under threat of being sued causing anxiety and besmirch

reputation.

EXHIBIT PARTICULARS

“J” Statement of Account of the Complainant from

Hongkong Bank Dated 07/27/98 amounting to P
27,255.07

PURPOSE: To show and prove the damage suffered by Maaliw from the

contrived complaint of defendants as a consequence of the forfeiture of Maaliw’s

employment benefits. The damage suffered under the document is financing charges

for failure to pay monthly dues on purchases with HONGKONG BANK CARD in

the total amount of P 27,255.07 as of July 27, 1998.

EXHIBIT PARTICULARS

“K” Demand Letter from the Counsel of Solidcard dated

September 23, 2000.
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PURPOSE: To show and prove the damage suffered by Maaliw from the

contrived complaint of defendants as a consequence of the forfeiture of Maaliw’s

employment benefits. The damage suffered under the documents is financing

charges for failure to pay monthly dues on purchases SOLIDCARD in the total

amount of P 67,572.34 as of February 23, 2000. Further, the exhibit is offered to

show that complainant is under threat of being sued causing anxiety and besmirch

reputation.

EXHIBIT PARTICULARS

“L” Department Order No. 05 from Land Bank dated

January 31, 1997

PURPOSE: To show and prove that Maaliw was an Executive Assistant IV

and designated as Acting BEO I and head of the Cost & Quantity surveying Unit
(CQSU), which office is different from the office of defendants.

EXHIBIT PARTICULARS

“M” Performance Target Worksheet & Appraisal Report

of the Complainant

PURPOSE: To show and prove the functions and works of Maaliw; To

prove the lack of basis of the complaint of the defendants against Maaliw at the

Land Bank.

EXHIBIT PARTICULARS

N PMED Organizational Chart

PURPOSE: To show and prove that defendants have no working relation

with complaint at Land Bank. Consequently, defendants have no basis in fact and

in law to complain against herein complainant before the Land Bank

EXHIBIT PARTICULARS

“O” Memorandum from the Asst. Vice –President of Lang

Bank. Re: Filling-up of Positions by New Hires.
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PURPOSE: To prove the process of appointment of Bank employees; To

show that Maaliw has nothing to do with hiring and firing of bank employees; To

negate the wild and baseless accusation against Maaliw at the Land Bank that lead

to the forfeiture of Maaliw’s employment benefits

All the foregoing documentary exhibits are also offered as part of the

testimony of complainant.

With the admission of the foregoing exhibits, together with the testimonies

of the complainant, complainant rests his case.

Quezon City for August 8, 2002

BENJAMIN A. MORALEDA, JR.

Counsel for Complainant.
PTR # 2855271; 01-02-02; Q. C.
IBP # 529819; 01-02-02; Q. C.
3rd Floor, Vargas Building
103 Kalayaan Avenue
Diliman, Quezon City

Copy furnished:

ATTY. ERNESTO P. FERNANDEZ

Counsel for Defendants.
#76 Dollar Street, St. Michael Homes
Meycauyan, Bulacan

EXPLANATION

The copy for Atty. Fernandez was served by registered mail due to time
constraints.

BENJAMIN A. MORALEDA, JR.