Formal Offer of Evidence

REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT
PASIG CITY
Branch No. 209
SINGIL BANK,
Plaintiff,
-versus-
CIVIL CASE NO. 45679
For: Action for Collection of Sum
of Money with Damage
ALLAN NAPERA
SHAH HABULIN,
Defendant/(s).
x- - - - - - - - - - - - - - - - - - - - - - - - -x
FORMAL OFFER OF EVIDENCE
COMES NOW the defendants, ALLAN NAPERA and SHAH

HABULIN, jointly and through the undersigned counsel, most
respectfully submits its Formal Offer of Evidence for the marking and
admission of the following:
EXHIBIT “1-A - 1-I” Official Receipts issued by Singil Bank,

with the following numbers:
● OR No. 09234
● OR No. 09345
● OR No. 09457
● OR No. 09587
● OR No. 09632
● OR No. 09741
● OR No. 09814
● OR No. 09947
To prove the payment of defendant Allan

Naper of amortizations from January 2022
to August 2022.
EXHIBIT “2” Email dated 30 August 2022 sent by
defendant Napera regarding the offer of
novation of the contract through assignment
of Common Shares with Companic Inc.
To prove the offer made by defendant
Napera for the novation of the contract by
assignment of his common shares with
Companic, Inc.
EXHIBIT “3” Certificate of Stock Number 023 issued by
Companic Inc under the name of Allan
Napera as evidence of Two Million
Common Shares with Companic, Inc.
To prove the existence of the shares of

stock being offered by defendant Napera
with Companic, Inc as attached in the
email.
EXHIBIT “4” Reply of a certain Nor A. Honor on 30
August 2022 agreeing to the offer of the
defendant.
To prove that a personnel from Singil Bank

accepted the offer of novation through
email.
EXHIBIT “5” Certificate from Singil Bank stating that
Ms. Nor A. Honor is an accounts officer of
the bank.
To prove that Ms. Honor, the person who

accepted the offer, is a duly authorized
accounts officer of plaintiff bank.
EXHIBIT “6” Certificate from Singil Bank stating that the
email address loans@singilbank.com is an
authentic corporate email address used by
the plaintiff bank for its formal transactions.
To prove that the email address in the email

thread in Exhibit “3” is a valid and
authentic email address of plaintiff bank.
EXHIBIT “7” Certificate from Singil Bank that Mr Martin
Coco is an assistant accounts officer of
plaintiff bank.
To prove that the person who replied to

defendant Napera on 1 September 2022 is
an Assistant Accounts Officer of plaintiff
bank.
EXHIBIT “8” The modified loan agreement that was sent
to defendant Napera on 1 September 2022.
To prove that the loan agreement was

novated such that the remaining obligation
amounting to Two Million Pesos shall be
paid by assigning Two Million Common
shares with Singil Bank.
EXHIBIT “9” The modified loan agreement dated 1
September 2022 as signed by defendant
Napera.
To prove the due execution of the modified

loan agreement.
EXHIBIT “10” The acknowledgment email from Ms. Nor
A. Honor on 1 September 2022.
To prove that the signed modified loan

agreement was transmitted to Singil Bank.
EXHIBIT “11” Deed of assignment dated 1 September
2022 evidencing the transfer of shares with
Companic Inc.
To prove that the Two Million common

shares were assigned to Singil Bank.
EXHIBIT “12” Certificate of Stock Number 035 issued by
Companic Inc under the name of Singil
Bank as evidence of the transfer ofTwo
Million Common Shares with Companic,
Inc. to plaintiff bank.
To prove that the Two Million common

shares previously owned by defendant
Napera was transferred to Singil Bank.
EXHIBIT “13” Demand letter dated 6 September 2022 sent
by plaintiff bank.
To prove that defendants received a demand

letter from the bank.
EXHIBIT “14-A to Print-out of email dated 6, 15, 22 and 29
14-D” September 2022 sent by defendant Napera
to Ms. Nor A. Honor reiterating the
assignment of his shares with Companic,
Inc., attaching soft copies of the deed of
assignment and the Certificate of Stock,
signed novated loan agreement, and the
email thread related to the negotiation.
To prove that defendant Napera

continuously communicated with Singil
Bank in relation to the settlement of the
remaining balance and that all documents
had already been sent to them.
EXHIBIT “15” Judicial affidavit of defendant Allan Napera
To prove the matters alleged in the Answer

and the terms in the revised loan agreement
and revised promissory note.
EXHIBIT “16” Judicial affidavit of defendant Shah
Habulin
To prove the matters alleged in the Answer

and to narrate the discussions and factual
circumstances, as well the version of the
Loan Agreement presented in the course of
execution of the Suretyship Agreement
with co-defendant Napera
PRAYER
WHEREFORE, defendants respectfully pray that the foregoing

documentary exhibits, inclusive of their sub-markings, and all other
documents submitted before the Honorable Court as is relevant to the
foregoing case be ADMITTED IN EVIDENCE for the purposes for
which they are respectively offered.
Other reliefs, just and equitable, are likewise prayed for.
Pasig City. 23rd day of November 2022.
ATTY. SANA A. MANALO

Counsel For Defendant
7th Floor Strata 100, Emerald Ave., Ortigas Center, Pasig City,
IBP Lifetime No. 23456; Pasig City
PTR No. 1111111; February 14, 2022, Pasig City
Roll of Attorney No. 12345
MCLE Compliance No. 77777777
EXPLANATION FOR SERVICE
BY REGISTERED MAIL
The foregoing Pre-trial was filed and served to the Honorable Court
and to the Counsel of Defendant by registered mail due to lack of manpower
and distance between the office and the introduction and implementation of
protocols in response to the COVID-19 pandemic.
ATTY. SANA A. MANALO
Copy furnished
ATTY. CHARITO S. ANTOS RR No. 0000000000000
Counsel for Plaintiff
20th Floor One Corporate Center, Ortigas,
Pasig City
Republic of the Philippines)
Pasig City ) S.S.
x----------x
AFFIDAVIT OF SERVICE
I, FARAN G. LEGAL of legal age, single, and a resident of Antipolo

City, Philippines, after having been duly sworn in accordance with law,
hereby depose and say that:
1. I am a Secretary / Legal Aide of the law office of Atty. Sana A.

Manalo with office address at 7th Floor Strata 100, Emerald Ave.,
Ortigas Center, Pasig City;
2. In my aforementioned capacity, I had personally served a copy of the
Motion to Lift Order of Default in the case entitled “Singil Bank vs
Allan Napera and Shah Habulin" docketed as Civil Case No 45679 by
registered mail with return card under Registry Receipt No. 00000000.
IN WITNESS WHEREOF, I have hereunto set my hand this 23rd day of

November 2022 at Pasig City, Philippines
FARAN G. LEGAL
Affiant
SUBSCRIBED AND SWORN TO before me in the City of Pasig on

this 23rd day of November 2022 affiant exhibiting before me his
Government issued identification document with ID No. 00000000 issued on
24 January 2020 at Makati City and valid until 24 January 2030.
ATTY. TAM A. BATO

Notary Public for City of Pasig
Appointment No. 00000000 until 31 December 2023
Ayala Avenue, Pasig City
Doc. No. 2 IBP Lifetime No. 00000000; Pasig City
Page No. 1 PTR No. 0000000; January 6, 2022, Pasig City
Book No. I Roll of Attorney No. 00000
Series of 2022 MCLE Compliance No. 0000000000

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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

FORMAL OFFER OF EVIDENCE

COMES NOW the defendants, ALLAN NAPERA and SHAH

EXHIBIT “1-A - 1-I” Official Receipts issued by Singil Bank,

To prove the payment of defendant Allan

To prove the existence of the shares of

To prove that a personnel from Singil Bank

To prove that Ms. Honor, the person who

To prove that the email address in the email

To prove that the person who replied to

To prove that the loan agreement was

To prove the due execution of the modified

To prove that the signed modified loan

To prove that the Two Million common

To prove that the Two Million common

To prove that defendants received a demand

To prove that defendant Napera

To prove the matters alleged in the Answer

To prove the matters alleged in the Answer

WHEREFORE, defendants respectfully pray that the foregoing

Other reliefs, just and equitable, are likewise prayed for.

Pasig City. 23rd day of November 2022.

ATTY. SANA A. MANALO

ATTY. SANA A. MANALO

I, FARAN G. LEGAL of legal age, single, and a resident of Antipolo

1. I am a Secretary / Legal Aide of the law office of Atty. Sana A.

IN WITNESS WHEREOF, I have hereunto set my hand this 23rd day of

SUBSCRIBED AND SWORN TO before me in the City of Pasig on

ATTY. TAM A. BATO

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