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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


11th Judicial Region
Branch 3
Tagum City, Davao del Norte

PEOPLE OF THE PHILIPPINES,


Complainant,
Crim. Case no.: 12345
-versus-
For: Murder
ALLAN P. REYES,
Accused.
x------------------------x

OFFER OF TESTIMONY

The Private Complainant JUDY ANN A. SANTOS will testify to prove the fact that the
accused ALLAN P. REYES have intentionally, deliberately and willfully killed victim RYAN O.
SANTOS. She will also testify on the veracity, genuineness and truthfulness of the
documents to be presented which will support the allegation of murder.

Finally, she will testify on such matter consistent with the above-mentioned purpose
and matters relevant to this instant case.

Republic of the Philippines )


Province of Davao del Norte ) S.S.
City of Tagum )
x----------------------x

JUDICIAL AFFIDAVIT OF JUDY ANN A. SANTOS

I, JUDY ANN A. SANTOS, Filipino, of legal age, widow and a resident of Tagum City,
after having been duly sworn to an oath in accordance with law, do hereby depose and say
that:

A. I was examined by ATTY. JULIA A. BARRETO of Barreto & Associates Law Office.

B. I answered the questions the examining lawyer asked of me, fully conscious that
I do so under oath and that I may face criminal liability for false testimony or
perjury;

C. I was questioned and I answered in the language I understood (English dialect);

D. I was examined at the examining lawyer’s Office at Rm. 1, 3/F, Valdez Building,
Rizal Street, Barangay Magugpo North, Davao del Norte through the following
questions:

Question 1 (Q [respective number] hereinafter): Are you the same JUDY ANN A. SANTOS,
the Private Complainant of this instant case?
Answer (A hereinafter): Yes, I am the same person.

Page 1 JUDICIAL AFFIDAVIT OF JUDY ANN A. SANTOS; CRIM. CASE NO. 12345; FOR: MURDER
Q2: Please state your name, age, address and other personal circumstances.
A: I am Judy Ann A. Santos, Filipino, 45 years old, and a resident of No. 26 Durian
Street, Carmina Subdivision, Barangay Visayan, Tagum City. I also work as an Elementary
Principal of Tagum City National High School at National highway, Tagum City. I am the
wife of Ryan O. Santos.

Q3: What proof can you produce to prove the fact that you are the wife or widow of Mr.
Ryan O. Santos.
A: I have a copy of our marriage contract.

Marking: It is respectfully prayed to this Honorable Court that the copy of the Marriage
Contract be marked as Exhibit “___”.

Q4: Can you please tell me or narrate the personal circumstances of Ryan O. Santos?
A: He is my husband. He is a Filipino, 45 years old, and he lives with me at our house at
No. 26 Durian Street, Carmina Subdivision, Tagum City. He works as a branch manager of
ONB Tagum City Branch and was the incumbent auditor of the Homeowner’s Association of
Carmina Subdvision, Barangay Visayan, Tagum City.

Q5: And where is Mr. Ryan O. Santos now?


A: He is already dead.

Q6: What can you produce to prove the truth of the fact of death of Mr. Santos?
A: I have a death certificate.

Marking: It is respectfully prayed to this Honorable Court that the copy of the Death
Certificate be marked as Exhibit “___”.

Q7: If you can, can you please tell this Court how did Mr. Ryan Santos died?
A: He was runned down by a vehicle.

Q8: Can you please narrate and elaborate how he was runned down by a vehicle?
A: Yes. Last December 16, 2017 at about 6:00 o’clock in the morning, my husband and I
went for our routine jog along the National Highway, Tagum City from our residence. When
we reached the PNP Barracks, my husband and I heard a sound of an incoming vehicle.
That upon turning our backs to check the said sound, we were shocked to see a Fortuner
car coming towards us driven by Mr. Allan P. Reyes who I saw was seated at the driver’s
seat of the said vehicle.

Q9: Who is this Mr. Allan P. Reyes?


A: He was the one seated at the driver seat of the vehicle who runned down my
husband.

Q10: How did you come to know the identity of Mr. Allan P. Reyes?
A: I knew him because he was our neighbor at Carmina Subdivision since we moved
there for about 10 years or so. Also, he is the incumbent treasurer of our Homeowner’s
Association at Carmina Subdivision.

Q11: If you can, can you tell me what happened next?


A: Mr. Allan P. Reyes was speeding towards our direction and deliberately hit my
husband and me, and subsequently my husband was pinned down to the ground while I
was thrown away to the side.

Page 2 JUDICIAL AFFIDAVIT OF JUDY ANN A. SANTOS; CRIM. CASE NO. 12345; FOR: MURDER
Q12: If you can, can you tell me what happened subsequently?
A: Thereafter, police officers from the PNP Police Barracks immediately arrested Mr.
Reyes and some came to our aid and brought my husband and me to Tagum Doctors
Hospital.

Q13: Can you tell me, what happened when you were brought to the hospital?
A: While I was Tagum Doctors Hospital, I was given medical treatment at the
emergency room for the injuries I sustained from the incident.

Q14: If you can, can you please tell me what kind of injuries did you sustain during the
accident/incident?
A: I sustained a broken right arm and multiple abrasions and contusions on both arms
and legs.

Q15: What proof can you produce that you, in truth, received medical attention for the
injuries you have recently referred to?
A: I have a medical certificate executed by Dr. John C. Agoncillo.

Marking: It is respectfully prayed to this Honorable Court that the copy of the Medical
Certificate by Dr. John C. Agoncillo be marked as Exhibit “___”.

Q16: While you were given medical treatment, can you please tell me what happened to
your husband?
A: While I was given medical treatment, my husband was declared “dead on arrival” by
a certain Dr. Jaime G. Laurel.

Q17: What proof can you produce that your husband was declared dead on arrival?
A: I have a certificate for dead on arrival executed by Dr. Laurel.

Marking: It is respectfully prayed to this Honorable Court that the copy of the
Certificate for Dead on Arrival by Dr. Jaime G. Laurel be marked as Exhibit “___”.

Q18: If you know, can you please tell me why would Mr. Allan P. Reyes run over your
husband?
A: I had every reason to believe that Mr. Allan P. Reyes intentionally hit my husband
with his car because before this incident, Reyes and my husband had an altercation.

Q19: Can you please tell me about the altercation that transpired between Mr. Reyes and
your husband?
A: Last December 2, 2017, during a special meeting called by the Homeowners
Association, my husband made an announcement that as the auditor of the Homeowner’s
Association he discovered that there was a deficiency in the funds of the association
amounting to One Million Five Hundred Thousand Pesos (PHP 1,500,000.00)

Q20: What proof can you produce the veracity of the deficiency reported by your
husband?
A: I have an Audit Report executed by my husband.

Marking: It is respectfully prayed to this Honorable Court that the copy of the Audit
Report executed by Ryan O. Santos be marked as Exhibit “___”.

Page 3 JUDICIAL AFFIDAVIT OF JUDY ANN A. SANTOS; CRIM. CASE NO. 12345; FOR: MURDER
Q21: Can you please tell me what happened next?
A: After making the announcement, my husband asked Reyes about the deficiency
being the treasurer and sole keeper of the funds of the association.

Q22: What was the response of Mr. Reyes, if there is any?


A: Mr. Reyes did not take the question well because he suddenly got mad and furious as he
had the impression that my husband was imputing to him that he used the funds for his
personal use, specifically for purchasing himself with a brand new Fortuner when his job
would make it impossible for him to afford that kind of expensive vehicle.

Q23: Can you please tell me more about what happened next in the same meeting?
A: During the meeting, Reyes hurled defamatory remarks and threats to my husband
including threats to his life and the statement that he would do anything to get back at my
husband for humiliating him. He also slapped my husband afterwards.

Q24: What proof can you produce that such altercation happened?
A: I have a police blotter made by SPO2 Lily K. Cruz.

Marking: It is respectfully prayed to this Honorable Court that the copy of the Police
Blotter by SPO2 Lily K. Cruz be marked as Exhibit “___”.

Q25: Going back to the vehicular incident, what did you do after the said incident, if any?
A: I filed a complaint against Mr. Allan P. Reyes for intentionally and deliberately
killing my husband.

Q26: Showing to you this document entitled as Affidavit-Complaint. How is this related to
the one you said earlier?
A: This is the same Affidavit-Complaint that I filed.

Q27: In this document consist of eight (8) pages and on the eighth page, it contains the
name of Judy Ann A. Santos and above it is a signature. Whose signature is this?
A: Mine.

Marking: It is respectfully prayed to this Honorable Court that the copy of the
Affidavit-Complaint be marked as Exhibit “___” and the signature be marked as Exhibit “___”.

Q28: Under your oath, do you affirm to the truthfulness, accuracy and veracity of this
Judicial Affidavit you executed and everything you answered and mentioned above, Mrs.
Santos?
A: Yes sir.

Q29: Do you have anything more to say?


A: I am stating for the record that the attachments in this Judicial Affidavit are faithful
reproductions of their corresponding original copies. I hereby undertake that I will bring
the original documents for comparison during scheduled direct examination in court.

IN WITNESS WHEREOF, I have hereunto affixed my signature this ___ day of


__________ 2018 at Tagum City, Davao del Norte, Philippines.

JUDY ANN A. SANTOS


Affiant
PRC ID no.: 3591018
Page 4 JUDICIAL AFFIDAVIT OF JUDY ANN A. SANTOS; CRIM. CASE NO. 12345; FOR: MURDER
SUBSCRIBED AND SWORN to before me this ___ day of __________ 2018 at Tagum
City, Davao del Norte, Philippines. The affiant presented to me her competent evidence of
identity indicated below her name and signature.

Doc. No. ; ATTY. JULIA A. BARETTO


Page No. ; NOTARY PUBLIC
Book No. ; Roll of Attorneys No. 512345
Series of 2018. PTR No. 26-26-0-10, 04/23/2013
IBP No. 910205, 4/11/09, Tagum
Admitted to the Philippine Bar - April 11, 2009

Republic of the Philippines )


Province of Davao del Norte ) S.S.
City of Tagum )
x----------------------x

SWORN ATTESTATION OF THE CONDUCTING LAWYER

I, ATTY. JULIA A. BARETTO of Baretto & Associates Law Office with office address
at Rm. 1, 3/F, Valdez Building, Rizal Street, Barangay Magugpo North, Davao del Norte,
after having been duly sworn to in accordance with law, do hereby depose and say that:

I am the conducting/supervising lawyer of private complainant Judy Ann A. Santos,


who executed the above judicial affidavit;

I have faithfully recorded or caused to be recorded the questions I asked and the
corresponding answers that the private complainant gave; and

Neither I nor any other person then present or assisting her, coached the Private
Complainant regarding the latter’s answers.

IN WITNESS WHEREOF, I have hereunto affixed my signature this ___ day of


__________ 2018 at Tagum City, Davao del Norte, Philippines.

ATTY. JULIA A. BARETTO


Affiant
TIN 920-233-111

SUBSCRIBED AND SWORN to before me this ___ day of __________ 2018 at Tagum
City, Davao del Norte, Philippines. The affiant presented to me her competent evidence of
identity indicated below her name and signature.

Doc. No. ; ATTY. NADINE R. LUSTRE


Page No. ; NOTARY PUBLIC
Book No. ; Until December 31, 2018
Series of 2018. PTR No. 917870 - Jan. 3, 2018
IBP No. 919600

Page 5 JUDICIAL AFFIDAVIT OF JUDY ANN A. SANTOS; CRIM. CASE NO. 12345; FOR: MURDER
Roll No. 14222

Page 6 JUDICIAL AFFIDAVIT OF JUDY ANN A. SANTOS; CRIM. CASE NO. 12345; FOR: MURDER

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