Republic of the Philippines

Regional Trial Court

Branch X
Tuguegarao City, Cagayan

JOB ORDER EMPLOYEES OF THE

VICE GOVERNOR’S OFFICE AND THE
SANGGUNIANG PANLALAWIGAN
Represented by:
MELVIN K. VARGAS, JR.
Petitioners Special Civil Action No. 99
for Certiorari, Prohibition and
Mandamus
-versus-

MANUEL N. MAMBA, et.al

Respondents

OFFER OF TESTIMONY

The testimony of the witness is offered for the following purposes:

1. To prove that he is one of the Job Order employees of the Vice

Governor;
2. To prove that he has duly signed a contract of service
dated_________;
3. To prove that he has rendered services during the period that he was
contracted or on January to June 2019; and
4. To testify on other matters relevant and incident in this case.

JUDICIAL – AFFIDAVIT

I, __________________ of legal age, Filipino and a resident of Tuguegarao

City, Cagayan, as part of my testimony in the above-captioned case, after
having been duly sworn in accordance with law hereby depose and state the
following:

I am one of the petitioners in this case and in relation to the above-

entitled case, the counsel, ATTY. ED ARMAND T. VENTOLERO, of
23 PROVINCIAL ROAD BAGAY TUGUEGARAO CITY, CAGAYAN
asked me questions which I answered to the best of my ability, fully
conscious that I did so under oath and that I may face perjury and/or
any criminal liability for false testimony;

The questions asked by Atty. Ventolero and the answers I gave are as
follows:
 DIRECT EXAMINATION QUESTIONS

Q.1.Please state your personal circumstance.

A.1. I am ___________________, of legal age, single, with a residence
address at Tuguegarao City, Cagayan.

Q.2.Where are you presently connected Mr. Witness?

A.2. At the Provincial Government of Cagayan- Office of the Vice
Governor, sir.

Q.3. Are you one of petitioners in this case?

A.3. Yes, sir.

Q.4.By the way may I ask, have you authorized the Vice Governor to
file the instant case in your behalf?
A.4. Yes sir.

Q.5.What is your proof, Mr witness?

A.5. We have a special power of attorney sir.

Q.6.Is that attached in your petition?

A.6. Yes sir.

Q.7. Do you remember having executed a contract of service

dated____________?
A.7. Yes, sir.
Q.8. I am showing to you a contract of service dated January 2019
signed by Melvin Vargas as the First Party and you as the Second
party, duly attested by __________ and certified as to the availability
of funds by ____________as the budget officer. Kindly go over the
same if that is the same contract of service you have executed?
A.8. Yes sir, that is the same contract of service that I have signed.

Q.9.There is a signature above the name of __________. Is that the

same signature that you have affixed in the contract of service?
A.9. Yes, sir.

Q.10.I am collectively marking the contract of service as Annex “A” and

forming part of your judicial affidavit. Do you agree?
A.10. Yes, sir;

Q.11. Are you aware of Memorandum No. 91 and 94 series of 2019 of

the Governor?
A.11. Yes, sir.
 Q.12. Are you aware that these memoranda have invalidated your
contract of service?
A.12. Yes, sir.

Q.13. And because of that Memoranda you did not receive your salary,
is that correct Mr. witness?
A.13. Yes sir.
.
Q.14. By the way, may I ask how many months did you not receive
your salary?
A. 14. Since May 2019, sir or two months already.

Q.15. But from January to present, did you report in the office?
A.15. Yes sir.

Q.16.What is your proof?

A.16. I have my daily time records and my accomplishment reports sir.

Q.17.I am collectively marking these daily time records and

accomplishments as Annex “B” and Annex “C” in order to form part of
your Judicial Affidavit, do you agree?
A.17. Yes, sir.

Q.18. By the way, what are your duties and responsibilities in the office
as stated in the Contract of Service that you have executed?
A.18. My duties and responsibilities are the following:

a. Receive incoming communications

b. Sort out documents
c. Do other work as may be assigned….

Q.19. I have no more questions to ask. Do you want to say more?

A.19. No more sir.

IN WITNESS WHEREOF, I have signed this Judicial Affidavit on July 22,

2019 at Tuguegarao City, Cagayan.

____________________
Affiant
 SUBSCRIBED AND SWORN TO before me this 22nd day of July 2019 at
Tuguegarao City, Cagayan by the affiant personally known to the Notary
Public.

ATTY. ED ARMAND T. VENTOLERO

Doc No. Notary Public
Page No. Commission Expires on Dec. 31, 2019
Book No. VIII Commission No. RTC-TUG-2018-14
Series of 2019 PTR No. 2469779/01-05-2019
IBP No. 062442/01-04-2019
Roll No.68849
Tuguegarao City, Cagayan
 ATTESTATION OF LEGAL COUNSEL

I, ED ARMAND T. VENTOLERO, of legal age, single and a resident of

23 Provincial Road, Bagay, Tuguegarao City, Cagayan, after having been
sworn to in accordance with the law do hereby depose and say:

1. That I have faithfully recorded or caused to be recorded the

questions I asked and the corresponding answers that witness,
_______________, gave;
2. That I have not, nor any other person present or assisting coached
the witness regarding the witness’ answers; and
3. That I fully understand that any false attestation shall subject me to
disciplinary action, including disbarment.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

nd
22 day of July 2019 at Tuguegarao City, Philippines.

ED ARMAND T. VENTOLERO
Counsel for the Petitioner

SUBSCRIBED AND SWORN TO before me this 22nd day of July 2019 at

Tuguegarao City, Cagayan by the affiant personally known to the Notary
Public.

ATTY. KATHLEENE KEITH R. BENZON

Doc No. Notary Public
Page No. Commission Expires on Dec. 31, 2019
Book No. Commission No. RTC-TUG-2018-14
Series of 2019 PTR No. 2469779/01-05-2019
IBP No. 062442/01-04-2019
Roll No.68849
Tuguegarao City, Cagayan