Republic of the Philippines

REGIONAL TRIAL COURT

Ninth Judicial Region
Branch 2
Zamboanga City
BRUNO TAN
Plaintiff,

CIVIL CASE NO. 2314

-versus-

FOR: NULLIFICATION OF ABSOLUTE

DEED OF

SALE, CANCELLATION
OF TITLE, RECONVEYANCE AND
RECOVERY OF OWNERSHIP OF
REAL PROPERTY AND DAMAGES
CHINA-ARAB BANK OF THE
PHILIPPINES, INC. Rep. By ABULANNANG
CHAN and ALBERTO TAN
Defendants.
x-----------------------------------------------x
JUDICIAL AFFIDAVIT OF THE WITNESS
CYNTHIA TAN
This Judicial Affidavit of witness, Cynthia Tan, is executed to serve as his
direct testimony in the instant case. This Judicial Affidavit is offered to prove
Petitioner Bruno Tan is the owner and has continuous, exclusive and notorious
possession and occupation of the Lot 2189-H.
QUESTIONS were propounded by plaintiffs counsel, Atty. Phyllisabelle
Bethany General in English, which the affiant fully understands, and the
ANSWERS were given by the witness Cynthia Tan were also in English.
1. Do you swear to tell the truth, the whole truth and nothing but the truth?
Answer: I do.
2. Are you aware that you may face criminal liability for false testimony or
perjury if you will not tell the truth?
Answer: I am.
3. Please state your name, age, address and occupation.
Answer:I am CYNTHIA TAN, Filipino, 29 years old and a resident of
Ayala, Zamboanga City. I am currently employed as an Office Clerk in
PhilHealth Zamboanga.

4. How do you know Ngu, Bruno and Alberto Tan, Deogracias and Editha
Uy and Francisco Chan and Gregory Chiong?
Answer: Ngu is my father. Bruno and Alberto are my brothers, and the
rest are my relatives.
5. In what way are you related to this case?
Answer: I am also a recipient of the Subdivided Estate of Ngu Tan, our
father.
6. Can you please tell me which lot was given to you?
Answer: Lot 2189-I was given to me, by virtue of the ExtraJudicial
Settlement Agreement we (my siblings and relatives) executed.
7. Can you please tell me to whom Lot 2189-H belongs to?
Answer: This belongs to Bruno.
8. Can you please tell me to whom Lot 2189-G belongs to?
Answer: Yes. It belongs to Alberto
9. How can you be certain?
Answer: We were all there, during the signing of the ExtraJudicial
Settlement Agreement. We agreed that what was stated therein would
represent the Lot we would inherit from our fathers estate.
9. Aside from that, are there any circumstances of which is indicative that
the lots belong to whom you say that they belong?
Answer: Yes. In March 2008, Bruno constructed small house on his lot.
And from what I know, he has been paying taxes for the said Lot.
10. How have you come to know about this fact?
Answer: I visited him a few times when he was constructing the house, and
there was one time I visited him, I saw his Tax Declaration lying around his
kitchen table.
11. You are aware that you are under oath?
Answer: Yes.
12. No further questions.

IN WITNESS WHEREOF, I have hereunto set my hand this 14th day of

February 2015 at Zamboanga City.
CYNTHIA TAN
AFFIANT
SUBSRIBED AND SWORN to before me this 14th day of February 2015
at Zamboanga City.
PHYLLISABELLE BETHANY GENERAL
COUNSEL FOR THE PLAINTIFF
2nd Floor BGIDC Building
Gov. Lim Avenue, Zamboanga City
Roll No. 123457 / 5-2-12
IBP No. 891017 / 12-29-14
PTR No. 654327 / 12-29-14
MCLE Compliance No. 110197 / 01-05-2015
Doc No: 17
Page No: 33
Book No: VIII
Series of 2015.
I, PHYLLISABELLE BETHANY GENERAL, of legal age, Filipino, with
postal address 2nd Floor BGIDC Building Gov. Lim Avenue, Zamboanga
City,after being duly sworn depose and say that:
1. I was the one who conducted the examination of witness Cynthia Tan at
my aforementioned office 2nd Floor BGIDC Building Gov. Lim Avenue,
Zamboanga City;
2. I have faithfully recorded or caused to be recorded the questions I asked
and the corresponding answer that the witness gave; and,
3. I or any other person then present or assisting me did not coach the
witness regarding her answers.
IN WITNESS WHEREOF, I have hereunto set my hand this 14th day of
February 2015 at Zamboanga City.

Atty. NARVARO BELAR S. NAVARRO

AFFIANT
SUBSCRIBED AND SWORN to before me this 14th day of February 2015
at Zamboanga City, Philippines, affiant exhibiting her IBP ID No. 891017 issued at
Zamboanga City on December 06, 2014.

ATTY. BENSAUD O. DEGUSMAN

NOTARY PUBLIC
Commission Serial Number: 123221
Notary Public for Zamboanga City
Until December 31, 2015
Nunez St. Zamboanga City
Roll No: 99821
IBP Lifetime Roll No: 22314, 1/2/12; Zamboanga City
Professional Tax Receipt No: 23142; 12/2/15; Zamboanga City
MCLE Compliance Certificate No.: 214142; 12/2/15.
Doc No: 53
Page No: 26
Book No: XIX
Series of 2015.