Republic of the Philippines

7th Judicial Region

MUNICIPAL TRIAL COURT
Loon, Bohol

SUZETTE
Plaintiff, Civil Case No. 123
For: Specific Performance
-versus- and Damages

MARIA
Defendant.
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FORMAL OFFER OF EXHIBITS

PLAINTIFF, through the undersigned counsel, unto the Honorable

Court, most respectfully files this Formal Offer of Documentary Exhibits
for marking and admission of the following:

EXHIBIT “A” - LTO Certificate of Registration No. 123456789

EXHIBIT “A-1” - LTO Official Receipt No. 1234567

Purpose: To prove –

1. That the subject motorcycle in this case is Honda with plate no. GE
28734;
2. That plaintiff SUZETTE is the registered owner of the motorcycle
and the motorcycle was duly registered with the LTO when the
incident happened;
3. That the Honda motorcycle is just one year old at the time of the
incident, April 01, 2016 being its registration date and the date of
the incident is April 12, 2017.

EXHIBIT “B” - Police Blotter Entry No. 0260 dated April 24, 2017
EXHIBIT “C” - PNP Sketch

Purpose: To prove -

1. That the incident was duly reported to the Loon Police Station and
police officers have conducted an investigation on the incident;

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 2. That PO1 Jade, the in-charged Traffic Investigator and the last
witness for the plaintiff, recorded the incident;
3. That the Nissan Navara pick-up hit the Honda motorcycle;
4. That the motorcycle suffered damages;
5. That there is no mention that the Nissan Navara pick-up suffered
damages.

EXHIBIT “D” - Police Record

Purpose: To prove -

1. That JOHN and MARIA appeared at PNP-Loon Station and came to

an agreement that the latter will shoulder the medical expenses of
the former as well as the repair of the motorcycle which sustained
damages;
2. That there is no mention that the Nissan Navara pick-up suffered
damages;
3. That JOHN and MARIA signed in the Police Record signifying their
conformity to the agreement;
4. That said entry as to the settlement or agreement of the parties
was prepared by P01 JADE.

EXHIBIT “E” - Price Quotation from Du Ek Sam, Inc.

EXHIBIT “E-1” - Reissued/second issued copy of the quotation from
Du Ek Sam – Tagbilaran dated March 19, 2018.

Purpose: To prove -

1. That the Honda motorcycle was assessed for repair price

quotation at Du Ek Sam, J.A. Clarin St., Tagbilaran City;
2. That the spare parts listed in the Price Quotation were the ones
damaged and need to be replaced or repaired;
3. That the total cost is Php 32,629.00 cash or P33,812.44 if debit or
credit card;

EXHIBIT “F” - Certificate to File Action issued by the Office of the

Lupon Tagapamayapa of Brgy. Moto Sur

Purpose: To prove that the plaintiff and the defendant have appeared
before the Punong Barangay/Lupon in compliance with the
Katarungang Pambarangay Law with the hope to settle the case by
defendant’s payment of the amount of Php 32,629.00, however,
defendant refused to pay, hence, mediation failed and the
Certificate was issued.

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EXHIBIT “G” - Demand Letter sent by the Plaintiff’s counsel
addressed to the defendant
EXHIBIT “G-1” - Postal Registry Receipt
EXHIBIT “G-2” - Registry Return Card

Purpose: To prove –

1. That the plaintiff exerted earnest efforts to demand from the

defendant in a most civil and formal way outside the court the
payment for the repair of the motorcycle in the amount of
P32,629.00;
2. That plaintiff likewise demanded for the payment of damages.

EXHIBIT “H” - Official Receipt No. 000203 (Acceptance fee)

EXHIBIT “H-1” to “H-6” - OR Nos. 4502481, 0420872, 621581,
13644809, 2831881, and 5603111
(Court filing fees)
EXHIBIT “H-7” - Acknowledgment Receipt (Administrative costs)

Purpose: To prove the expenses incurred by the plaintiff for this case.

With the submission and the admission of the above evidence

together with the testimony of the plaintiff and other witnesses, the
plaintiff rests her case.

MOST RESPECTFULLY SUBMITTED.

Tagbilaran City, Bohol, _____________________.

ATTY. FRANCES
Counsel for the Plaintiff
018 Street Extension
Tagbilaran City, 6300, Bohol, Philippines
Roll No. 12345 : May 23, 2017/IBP No. 053304
MCLE Compliance No. VI-0001234 : February 23, 2018
PTR No. 0000123: Jan. 03, 2018: Tagbilaran City
TIN: 123-456-789 / Mobile No. 09321234567

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Copy furnished by Registered Mail:

ATTY. DIONISIO Reference No.

ATTY. JESSA
Law Office
CPG Avenue
Tagbilaran City

EXPLANATION OF NON-PERSONAL SERVICE

ATTY. DIONISIO and ATTY. JESSA were sent a copy of this Formal
Offer of Exhibits by registered mail in lieu of personal delivery that
cannot be effected due to distance between offices and/or due to lack of
manpower.

FRANCES