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REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
National Capital Judicial Region
Branch 77, Quezon City
WILLIE FERNANDO S. MAALIW,
Complainant,
- Versus - Civil. Case No. Q-99-38219
For: Damages
REYNATUS SAN JUAN, ET AL.,
Accused.
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FORMAL OFFER OF EVIDENCE
COMPLAINANT, by counsel, to this Honorable Court, Formally Offer’s
his Evidence to wit:
EXHIBIT PARTICULARS
“A” Memo to the Vice President of PMED dated 29 August
1997
“A-1 to A-2” Signatures of the PMED Staff
PURPOSE: To show the malicious and baseless complaint of
defendants against complainant that caused damages to the latter. It is also
offered to prove the lack of basis on the part of defendants to make such complaint
against herein complainant.
EXHIBIT PARTICULARS
“B” Memo from the VP-FMEG Re: Request for Formal
Investigation dated September 15, 1997
PURPOSE: To show and prove that the baseless complaint contrived by
defendants was given due course that ultimately brought damage and prejudice to
complainant;
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EXHIBIT PARTICULARS
“C” Memo from Willie Maaliw Reply to memo of PMED
Staff dated August 29, 1997
“C -1- C-19” Continuation of Memo from W. Maaliw
PURPOSE: To show and prove that the Administrative complaint against
Maaliw that was given due course was baseless as explained in the document and
the complaint was calculated to cause damage and prejudice to Maaliw;
EXHIBIT PARTICULARS
“D” Memo from the Office of the General Counsel
dated Sep. 16, 1999
“D-1” Dispositive Portion from the Memo from the Office of
the General Counsel
PURPOSE: To show and prove that Maaliw was proven not liable to the
malicious complainant of Gross Discourtesy in the Course of Official duty contrived
by defendants.
EXHIBIT PARTICULARS
“E” Statement of Account of the Complainant from Citibank
dated 09/13/88 amounting to P 54,639.88
“F” Statement of Account of the Complainant from Citibank
dated 09/27/88 amounting to P 31,201.00
“G” Written Formal Complaint with Preliminary Attachment
form the Counsel of City bank dated August 21, 2000 .
PURPOSE: To show and prove the damage suffered by Maaliw from the
contrived complaint of defendants as a consequence of the forfeiture of Maaliw’s
employment benefits. The damage suffered under the documents is financing
charges for failure to pay monthly dues on purchases with Citibank card in the total
amount of P 305,190.67 as of August 21, 2000. Further, the exhibits are offered to
show that complainant is under threat of being sued causing anxiety and besmirch
reputation.
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“H” Statement of Account of the Complainant from Bankard
Dated 09/22/88 amounting to P 18,041.32
PURPOSE: To show and prove the damage suffered by Maaliw from the
contrived complaint of defendants as a consequence of the forfeiture of Maaliw’s
employment benefits. The damage suffered under the document is financing charges
for failure to pay monthly dues on purchases with BANKARD and financing
charges in the total amount of P 18,041,32 as of October 18, 1998.
“I” Demand Letter from the Counsel of Far East bank dated
March 16, 2000.
PURPOSE: To show and prove the damage suffered by Maaliw from the
contrived complaint of defendants as a consequence of the forfeiture of Maaliw’s
employment benefits. The damage suffered under the document is financing charges
for failure to pay monthly dues on purchases with FAREASTCARD in the total
amount of P 47,890.60 as of February 10, 200. Further, the exhibit is offered to
show that complainant is under threat of being sued causing anxiety and besmirch
reputation.
EXHIBIT PARTICULARS
“J” Statement of Account of the Complainant from
Hongkong Bank Dated 07/27/98 amounting to P
27,255.07
PURPOSE: To show and prove the damage suffered by Maaliw from the
contrived complaint of defendants as a consequence of the forfeiture of Maaliw’s
employment benefits. The damage suffered under the document is financing charges
for failure to pay monthly dues on purchases with HONGKONG BANK CARD in
the total amount of P 27,255.07 as of July 27, 1998.
EXHIBIT PARTICULARS
“K” Demand Letter from the Counsel of Solidcard dated
September 23, 2000.
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PURPOSE: To show and prove the damage suffered by Maaliw from the
contrived complaint of defendants as a consequence of the forfeiture of Maaliw’s
employment benefits. The damage suffered under the documents is financing
charges for failure to pay monthly dues on purchases SOLIDCARD in the total
amount of P 67,572.34 as of February 23, 2000. Further, the exhibit is offered to
show that complainant is under threat of being sued causing anxiety and besmirch
reputation.
EXHIBIT PARTICULARS
“L” Department Order No. 05 from Land Bank dated
January 31, 1997
PURPOSE: To show and prove that Maaliw was an Executive Assistant IV
and designated as Acting BEO I and head of the Cost & Quantity surveying Unit
(CQSU), which office is different from the office of defendants.
EXHIBIT PARTICULARS
“M” Performance Target Worksheet & Appraisal Report
of the Complainant
PURPOSE: To show and prove the functions and works of Maaliw; To
prove the lack of basis of the complaint of the defendants against Maaliw at the
Land Bank.
EXHIBIT PARTICULARS
N PMED Organizational Chart
PURPOSE: To show and prove that defendants have no working relation
with complaint at Land Bank. Consequently, defendants have no basis in fact and
in law to complain against herein complainant before the Land Bank
EXHIBIT PARTICULARS
“O” Memorandum from the Asst. Vice –President of Lang
Bank. Re: Filling-up of Positions by New Hires.
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PURPOSE: To prove the process of appointment of Bank employees; To
show that Maaliw has nothing to do with hiring and firing of bank employees; To
negate the wild and baseless accusation against Maaliw at the Land Bank that lead
to the forfeiture of Maaliw’s employment benefits
All the foregoing documentary exhibits are also offered as part of the
testimony of complainant.
With the admission of the foregoing exhibits, together with the testimonies
of the complainant, complainant rests his case.
Quezon City for August 8, 2002
BENJAMIN A. MORALEDA, JR.
Counsel for Complainant.
PTR # 2855271; 01-02-02; Q. C.
IBP # 529819; 01-02-02; Q. C.
3rd Floor, Vargas Building
103 Kalayaan Avenue
Diliman, Quezon City
Copy furnished:
ATTY. ERNESTO P. FERNANDEZ
Counsel for Defendants.
#76 Dollar Street, St. Michael Homes
Meycauyan, Bulacan
EXPLANATION
The copy for Atty. Fernandez was served by registered mail due to time
constraints.
BENJAMIN A. MORALEDA, JR.
