REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
BRANCH 4E
MANILA CITY

Lucy Paez and Alfredo Paez

Plaintiff,

-versus- Civil Case No. 17534

For: Nullification of the Special
Power of Attorney, Deed of Sale and
Real Estate Mortgage

Asuncion Paez and Malaya Finance Corporation

Defendants.
X--------------------------------------X

JUDICIAL AFFIDAVIT OF
WITNESS ERICKSON A. AMION

I, ERICKSON A. AMION, of legal age, married, and living at North Greenhills,

Village, San Juan, a witness for the plaintiff in this case, state under oath as
follows:

PRELIMINARY STATEMENT

The person examining me is Atty. JESUS CLARO T. CEBRIAN Jr. with office
address at 3rd Flr., Best Bldg., T.M. Kalaw cor. Taft Avenue, Ermita, Manila, The
examination is being held at the same address. I am answering his questions
fully conscious that I do so under oath and may face criminal liability for false
testimony and perjury.

PURPOSE: This Judicial Affidavit of the witness ERICKSON A. AMION is

being offered as evidence for the Plaintiff to prove the following:

1. That Dioniosio Paezs ailment is

2. That said ailment affects the mental faculties of the patient whereby
the latter is not able to place his thumbprint intelligently and
voluntarily;

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 The questions asked by Atty. JESUS CLARO T. CEBRIAN Jr and the
answers I gave are as follows, to wit:

1. QUESTION (Q): Mister Witness, do you know the plaintiff in this case?

ANSWER (A): Yes sir.

2. Q: Why do you know him?

A: He was referred to me by Dr. M________ sometime in May 2009 to

request cognitive evaluation to obtain an over- all assessment of his
intellectual, cognitive, and personality functions and to rule out presence
of cognitive impairment.

3. Q: Did you conduct a psychiatric study of the party in this case?

A: Yes sir.

4. Q: Now, could you please tell us the manner by which you conducted your
study?
A: I did the standard procedure which was to do a detailed psychiatric
history and mental status examination by psychiatric interviews with the
petitioner. I also subjected the petitioner to a battery of psychological tests.
The information gathered was then studied and collated to make a written
report.

5. Q: Madam witness, in connection with your study, what were your findings
insofar as the plaintiff is concerned?
A: I assess the petitioner over-all functioning suggest presence of Major
Neurocognitive Impairment, sir.

6. Q: In terms that could be understood even by a layman, could you please

elaborate on the disorder of the plaintiff?
A: This disease is also known as dementia. His memory, and attention
and executive function were compromised. He was experiencing some
problem with his memory with regard to his storage of information. He had
difficulty in comprehending situations and making plans or decisions and
ability to deal with abstract ideas which also incapacitate him to decide
and execute actions with logic and rightful judgment.

7. Q: This kind of disorder on the part of the plaintiff, is this chronic?

A: yes sir.

8. Q: is it pathological?
A: yes sir.

9. Q: Does it boarder on a kind of neurosis or psychosis?

A: It is a neurotic disorder.

10. Q: Now mister witness, you are trying to tell us that this Dependent
personality disorder is pathological and chronic. Did it gravely affect the
capacity of the deceased Dionisio Paez to sign the deed of absolute sale
willfully and voluntarily?
A: yes sir.

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 11. Q: Why do you say so?
A: Because his disease greatly affect his mental faculties compromising
his ability to comprehend, reason and intelligently make decisions.

12. Q: Mister Witness, with regard to the disorder of the Plaintiff, did this
disorder exist even before she entered into the contract of Deed of
Absolute Sale?
A: yes sir.

13. Q: Is the disorder on the part of the Plaintiff clinically proven by your
findings?
A: yes sir.

14. Q: Is the same disorder grave and incurable?

A: yes sir.

15. Q: And what is your inference with regards to the personality of the
Defendant?
A: I inferred that the respondent suffers from a Major Neurocognitive
Impairment, sir.

16. Q: Mister witness, did you put your findings in writing?

A: yes sir.

17. Q: if the said written report you mentioned will be shown to you, will you
be able to identify it?
A: yes sir.

18. Q: I have here a document which purports to be a psychiatric evaluation

report, dated __________, can you please kindly go over it and tell this
Honorable court its relation to the document you are referring to.
A: Sir, this is the same psychiatric evaluation report that I have made.

19. Q: Found on the last page of the same document is a signature above the
typewritten name Dr. Erickson A. Amion MD, whose signature is that?
A: It is my signature, sir.

20. Q: I have no further questions. Do you have anything to add or retract,

Madam Witness?
A: No sir.

21. Q: Are you willing to sign your statement?

A: Yes sir.

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

________, 2017 here in the City of Manila.

Gian Vyron B. Dimabayao

Affiant

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 SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in and for
the City of Manila this ___ day of _________2017. Affiant personally came and
appeared with __________________________, bearing his photograph and
signature, known to me as the same person who personally signed the foregoing
instrument before me and avowed under penalty of law to the whole truth of the
contents of said instrument.

ATTY. JOSEPH JOJO D. DAJAY

Notary Public
Manila
Roll No, ________________________
IBP Roll No. _____________________
PTR No. ________________________
MCLE Compliance Cert. No._________
Doc. No. __________
Page No. _________
Book No. _________
Series 2017

ATTESTATION

I, Jesus Claro T. Cebrian Jr., of legal age, Filipino and with office
address at 3rd Flr., Best Bldg., T.M. Kalaw cor. Taft Avenue, Ermita, Manila, after
first having been duly sworn, do hereby depose and say that:

1. I was the lawyer who conducted the examination of the witness

ERICKSON A. AMION at my aforementioned office in Manila;

2. I have faithfully recorded or caused to be recorded the questions I

asked and the corresponding answer that the witness gave;

3. I nor any other person then present or assisting her coached the
witness regarding her answers;

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

_______ 2017 at the City of Manila.

ATTY. JESUS CLARO T. CEBRIAN

Jr.

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 SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in and for
the City of Manila this ___ day of ________ 2017. Affiant personally came and
appeared with Professional Drivers License No. D110020419 issued by the Land
Transportation Office on September 01, 2015 and valid until July 7, 2009 at the
City of Manila, bearing his photograph and signature, known to me as the same
person who personally signed the foregoing instrument before me and avowed
under penalty of law to the whole truth of the contents of said instrument.

ATTY. JOSEPH JOJO D. DAJAY

Notary Public
Manila
Roll No, ________________________
IBP Roll No. _____________________
PTR No. ________________________
MCLE Compliance Cert. No._________
Doc. No. __________
Page No. _________
Book No. _________
Series 2017

COPY FURNISHED:

By Personal Service:
Atty Laarni A. Cabrera
Cabrera Law Offices

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