R E P U B L I C O F T H E P H IL I P P I N E S )

CITY OF ILOILO ) Sc.

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ABC Corporation, CASE No. 1893-1902

Claimant
versus Complaint for Specific
Performance and Damages

GE Philippines Inc.

Respondent
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AFFIDAVIT OF ANNIE BATUMBACAL

I, Annie Batumbacal, 42 years old, married, and living in Avida Towers Atria 2, Don
Donato Pison Avenue, Atria Park District, San Rafael, Mandurriao, Iloilo City, witness for
the Respondent in this case, states under oath that:

PRELIMINARY STATEMENT

The persons examining me are Atty. Justine Patricio and Atty. Jocedale Araneta with office
address at Rm 303, Rada Building, General Luna Street, Iloilo City, Philippines, Iloilo City.
The examination is being held at the same address. I am answering their questions
voluntarily, to the best of my knowledge and fully conscious that I do so under oath and
may face criminal liability for false testimony and perjury.

PURPOSE

This affidavit/testimony of witness ANNIE BATUMBACAL is being offered to provide

information as to the employment of MR. JEROME RAY BENNETT with Chicosci
Manpower, Incorporated and his duties and responsibilities stated in his contract of
employment.

This Affidavit is being offered to prove the following:

1. That Mr. Jerome Ray Bennett is under the employ of Chicosci Inc. as hired by the
Annie Batumbacal, being the HR Manager of Chicosci.
 2. That Mr. Jerome Ray Bennett has understood his contract with his employer,
Chicosci;
3. That Mr. Jerome Ray Bennett has been properly oriented with the terms and
conditions of his contract with Chicosci Inc.
4. That Mr. Jerome Ray Bennett’s affidavit as a witness in this current case is
prohibited pursuant to the terms and conditions he had previously signed
voluntarily and competently, as embodied in his employment contract with Chicosci
Inc;
5. That Mr. Jerome Ray Bennett is one of the Healthcare Field Engineers of Chicosci
recommended by the company to the GE Philippines Inc.

Q. Please state your name and other personal circumstances for the record.

A. I am Annie Batumbacal, 42 years old, married, and living in Avida Towers Atria 2, Don
Donato Pison Avenue, Atria Park District, San Rafael, Mandurriao, Iloilo City, Philippines.

Q. What is the main business of Chicosci Manpower, Inc.?

A. The company is an outsourcing company that provides engineering services that best
suit the needs of dynamic market environment. Many of the world's most competitive firms
turn to contract engineering services to meet their needs. This is true for companies with no
in-house engineering as well as companies with extensive in-house expertise. Chicosci
Manpower Inc. routinely works with both. With the right provider, outsourced engineering
teams can develop complete products and transition them to production, or they can
develop only critical subsystems. In both cases, outsourcing a project to an engineering
services firm can free management resources and bring products to market faster. In short,
contract engineering services provide surge capacity and flexibility that companies require
when they are developing complex systems under aggressive schedules.

Q. What is your position with Chicosci Manpower, Inc.?

A. I am the HR Manager of Chicosci Manpower, Inc.

Q. How long have you been an HR Manager of Chicosci Manpower, Inc?

A. 18 years since the company started in 1999.

Q. What is your role and responsibilities as HR Manager of Chicosci Manpower, Inc?

A. As an HR manager, I perform a variety of tasks, which is leading the company’s HR

programs and policies and apply to employee relations, compensation, benefits, safety,
performance and staffing levels. Typically, I use my recruitment and interviewing skills to
identify staff vacancies and select candidates for open positions, have the hired employee
sign the contract of employment and give instructions relating to their pre-employment.
Also, typically skilled in promoting healthy relationships between staff and management
through mediation, handling labor disputes and guiding department managers through
employee issues. I also conduct employee training and orientation, administer a benefits
program, analyze compensation and other competitive data and prepare budgets and other
tasks as the company may deem proper.
Q. How did Chicosci Manpower, Inc. and GE Phils get involved?

A. GE Phils., Inc. hired Chicosci to supply the needed manpower for certain projects. The
GE Philippines usually tap the company on-call whenever they are looking for installation
experts and specialists for their projects.

Q. Is Mr. Jerome Ray Bennett an employee of Chicosci?

A. Yes. He is one of the Healthcare Field Engineers of Chicosci Inc.

Q. Were you the one who hired Mr. Jerome Ray Bennett?

A. Yes.

Q. Did Mr. Jerome Ray Bennett fully understood his contract of employment with Chicosci?

A. Yes. It was explained to him before he signed his contract. All parts of the contract were
fully accepted by Mr. Jerome Ray Bennett.

Q. Is there a non-compete/non-disclosure/non-solicitation agreement stated in the

employment contract that Mr. Jerome Ray Bennett signed?

A. Yes. It was completely explained to him.

Q. Were you notified that Mr. Jerome Ray Bennett gave his testimony in this present case,
involving Chicosci?

A. No. Mr. Jerome Ray Bennett did not notify me that he will be giving a statement, which
involves his employer, Chicosci.

Q. So there was no permission from the part of Chicosci regarding Mr. Bennett’s testimony?

A. None. There was no permission at all. I don’t even have a copy of his affidavit.

That I am declaring under oath that the above mentioned documents, stocks and
properties are now deemed lost and beyond recovery; and

That I am executing this Affidavit to attest to the truth of the foregoing statements
and to support my insurance application/claim and for whatever legal purpose it may
serve.

IN WITNESS WHEREOF, I hereby affixed my signature hereunder this 10th day of

March, 2014 in the City of Iloilo, Philippines.

ANNIE BATUMBACAL
Affiant

SUBSCRIBED AND SWORN to before me, a notary public in and for the City and
Province of Iloilo, this 12th day of February, 2018, by Annie Batumbacal who has been
personally identified by me to be the very same person who executed and signed the
foregoing Affidavit based on competent evidence of his identity.

WITNESS MY HAND AND SEAL this 12th day of February, 2018 in the City of
Iloilo, Philippines.

Doc No. _____;

Page No. _____;
Book No. _____;
SERIES OF 2018.

Atty. Bo Sanchez Notary Public for Iloilo City

6 Jupiter St., Greenland Village, Iloilo City
Appointment No. 123 Until December 31, 2018
IBP No. 123456; 01/10/18—Iloilo City PTR No. 123456;
01/10/18—Iloilo City Roll No. 1234 01/10/18
MCLE No. I 001234; 9/09/17 MCLE No. II 005678;
12/09/17 Serial No. of Commission M-12
Doc No. 12 ; Page No. 34; Book No. V; Series of 2018.
 ATTESTATION

The undersigned ATTY. JUSTINE PATRICIO, of legal age, single, and with law office
address are Room 303, Rada Building, General Luna Street, Iloilo City, Philippines, under
oath, deposes and states:

1. She is the Legal Counsel for the respondents in the above-entitled case;

2. She faithfully recorded or caused to be recorded the questions she asked and the
corresponding answers that the above-named witness gave;

3. Neither she nor any other person then present or assisting her coached the witness
regarding the latter's answers; and

4. She conducted the examination of the witness at her law office located at Room 303,
Rada Building, General Luna Street, Iloilo City, Philippines. IN WITNESS WHEREOF, I
have hereunto set my hand on this 12th day of February at Iloilo City.

JUSTINE PATRICIO
Affiant

JUSTIN PATRICIO Attorney Until December 31, 2018 PTR No. 987654 Issued on January
3, 2018 Iloilo City IBP No. 876543, 1-3-14 Atty. Roll No. 98789

SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in Iloilo City on

12th day of February 2018, Affiant personally came and appeared with Driver’s License NO.
D04-00-001234 issued by the Land Transportation office on April 10, 2010, bearing her
photograph and signature and Passport No. 0012346982 issued by the Department of
Foreign Affairs on April 10, 2004, known to me as the same person who personally signed
the foregoing instrument before me and avowed under the penalty of law to the whole truth
of the contents of said instrument.

Atty. Bo Sanchez Notary Public for Iloilo City

6 Jupiter St., Greenland Village, Iloilo City
Appointment No. 123 Until December 31, 2018
IBP No. 123456; 01/10/18—Iloilo City PTR No. 123456;
01/10/18—Iloilo City Roll No. 1234 01/10/18
MCLE No. I 001234; 9/09/17 MCLE No. II 005678;
12/09/17 Serial No. of Commission M-12
Doc No. 12 ; Page No. 34; Book No. V; Series of 2018.

Copy furnished:
Copy Furnished: (By Registered Mail)

JOHN MARTI MAGHOPOY

Counsel for Respondent
GREYHOUNDS LAW FIRM
Rm 303, Rada Building, General Luna Street, Iloilo City