Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
Branch 3
Nabunturan, Compostela Valley

Bridget Abad, Plaintiff, CIVIL CASE No. 220321

- versus – FOR: Damages for injuries, Loss

of earning capacity, Moral
Davao Metro Shuttle damages and Attorney’s Fees.
Corporation, Defendant.
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FORMAL OFFER OF DOCUMENTARY EVIDENCE

PLAINTIFF by the undersigned counsel and unto this

Honorable Court, most respectfully offers the following documentary
and exhibits for the above titled case, to wit:

EXHIBITS DESCRIPTION PURPOSE/S

“A” Sinumpaang-  To correlate the testimony in

Salaysay of Ms. the Judicial Affidavit (Exh. “C”
Gloria Nitura for Plaintiff).
“A-1” Signature of Ms.  To prove that the witness duly
Gloria Arafol executed the affidavit (Exh.
“A”).
“B” Sinumpaang-  To corroborate the testimony of
Salaysay of Mr. the first witness;
Daveu Araneta  To testify to the truth of the
affidavit executed;
 To establish the circumstances
surrounding the incident in
question
“B-1” Signature of Mr.  To prove that the witness duly
Daveu Araneta executed the affidavit (Exh.
“B”).
“C” Judicial Affidavit of  To testify as the primary
Mrs. Bridget Abad witness;
 To testify to the truth of the
affidavit executed;
 To establish the circumstances
surrounding the incident in
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 question;
“C-1” Signature of Mrs.  To prove that the witness duly
Bridget Abad executed the affidavit (Exh.
“C”).
“D” Judicial Affidavit of  To prove the performance of
PO2 Dexter his duty as First Responder
Senoron and Investigator within the
scope of his duty and regular
performance of duty;
 To testify to the truth of the
affidavit executed;
 To identify the victim and the
accused.
“D-1” Signature of PO2  To prove that the witness duly
Dexter Senoron executed the affidavit (Exh.
“D”).
“E” Pinagsamang  To correlate the testimony in
Sinumpaang- the Judicial Affidavit of the
Salaysay of PO2 second witness.
Dexter Senoron
“F” Traffic Incident  To provide the court
Report information as to the
circumstances of the incident
“G” Medical Records  To submit to the court
and Certification of information of the cause of the
Permanent Total injuries sustained by the
Disability plaintiff;
 To corroborate the testimony of
the first witness;
 To prove permanent total
disability;
“H” Letter addressed to  To apprise the court of the
Mrs. Bridget Abad subsequent effects of the
re: Forced accident;
Retirement Due to  To prove the loss of earning
Disability, signed by capacity of the plaintiff;
Dep.Ed. SDS Cyrus
Bohol
“I” Medical Bills from  To prove actual expenses
Davao Doctors incurred on the part of the
Hospital plaintiff;

Aforesaid exhibits are being offered to prove the breach of

contract of carriage due to the negligence of the diver of the

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defendant, resulting to the permanent total disability of the plaintiff
due to the incident at the address indicated in the Complaint.

WHEREFORE, premises considered, it is most respectfully

prayed to this Honorable Court that the foregoing object and
documentary exhibits be admitted for which each and all said exhibits
were offered in proving the claims of the complainant and with the
formal submission of the aforesaid coupled with the testimonies of the
witness who testified thereon.

Tagum City.
July 14, 2018

LUNA MARIA DOMINIQUE S. ACOSTA

Counsel for the Plaintiff

NOTICE

The Hon. Clerk of Court

RTC Branch 3,
Nabunturan, Compostela Valley

GREETINGS:

Please submit the foregoing Formal Offer for the consideration

and approval of the Honorable Court immediately upon receipt
thereof.

LUNA MARIA DOMINIQUE S. ACOSTA

Counsel for the Plaintiff

Copy Furnished:

Counsel for the Defendant