Republic of the Philippines

4th JUDICIAL REGION

Regional Trial Court
Branch 12, Lipa City, Batangas

GIAN CARLO BRIONES,

Plaintiff,

-versus- Civil Case: ______

For: Collection of Sum
of money

KIT LEVI SERVAN,

Defendant.
x-----------------------------------------x

COMPLAINT

Plaintiff, by counsel, states that:

The Parties

1. GIAN CARLO BRIONES, is a Filipino, single, and a resident

of 123 Brgy. Sabang, Lipa City, Batangas;

2. KIT LEVI SERVAN, is a Filipino, single and a resident of 45C

Brgy. San Jose, Lipa City, Batangas, where he may be served with
summons and other court processes;

Causes of Action

3. On 1 May 2017, Servan approached Briones with a proposal to

open a computer shop business. Briones was not interested in joining
the computer shop business but was willing to extend a loan to Servan
to use as capital;

4. On 1 June 2017, Servan borrowed Two Million Pesos (Php

2,000,000) with an agreed interest of five percent (5%) per annum as
evidenced by a promissory note herein attached as Annex “A” and
form an integral part of this complaint;
 5. The debt has become due and demandable on 31 May 2018, as
shown in the attached promissory note;

6. Despite Briones’s repeated verbal and written demands,

Servan failed to pay the debt without valid grounds to the damage and
prejudice of Briones;

7. In order to enforce his rights, Briones has sought legal counsel

with attorney’s fees amounting to One Hundred Thousand Pesos (Php
100,000) and appearance fee of Two Thousand Pesos (Php 2,000) per
hearing, as evidenced by the Contract for Legal Services attached
herein as Annex “C”;

8. Briones paid for litigation expenses amounting to Twenty

Thousand Pesos (Php 20,000) as evidenced by Official Receipt attached
herein as Annex “D”.

Relief

ACCORDINGLY, Briones asks that decision be rendered

ordering Servan to pay the following:

1. Principal debt of Php 2,000,000;

2. Interest amounting to Php 100,000;

3. Attorney’s fees amounting to Php 100,000 and appearance fee

of Php 2,000 per hearing;

4. Litigation expenses amounting to Php 20,000.

Other reliefs just and equitable are also prayed for.

Lipa City, 1 August 2019.

(Sgd.) Ciara Mae U. Tang

Counsel for Plaintiff
Bayad Yu Tang Law Office, Sampaguita
Homes, Brgy. Sampaguita, Lipa City,
Batangas
Roll of Attorneys No. 99519
PTR 89772; 01/07/19; Lipa City
IBP 24210; 01/07/19; Lipa City
MCLE Comp. No. IV-0011092; 01/04/18
Republic of the Philippines)
Lipa City, Batangas) SS.

Verification and Certification

I, GIAN CARLO BRIONES, state under oath that I have read the
above complaint and the allegations in it are true and correct of my
personal knowledge and/or based on authentic record. I also certify
under oath that (a) I have not previously filed any action involving the
same issues in any court, tribunal or quasi-agency; (b) that, to the best
of my knowledge, no such action is pending in any of them; and (c) if
I should learn of the filing of such action, I shall report it to the court
within five days from notice.

Lipa City, Batangas; 1 August 2019.

(Sgd.) GIAN CARLO BRIONES

Affiant

Signed and sworn before me this 1 August 2019 at Lipa City,

Batangas after affiant exhibited to me his driver’s license, issued on 27
February 2018 at Lipa City.

(SGD.) Daniel Adrian R. Cañizo

Notary Public for Lipa City
56 P. Torres St., Lipa City
Commission Serial 14747
Until Dec. 31, 2019
Roll of Attorney 75398
PTR 88553; 1-15-19; Lipa City
IBP 21421; 1-15-19; Lipa City
MCLE Comp. No. IV-0011093; 01/04/18

Doc. 30;
Page 30;
Book III
Series of 2019
 Republic of the Philippines
4th JUDICIAL REGION
Regional Trial Court
Branch 12, Lipa City, Batangas

JOMEL B. LOZADA,
Plaintiff,

-versus- Civil Case: ______

For: Collection of Sum
of money with prayer
for writ of preliminary
attachment

CAMILLE ANNE PEREZ,

Defendant.
x-----------------------------------------x

COMPLAINT

Plaintiff, by counsel, states that:

The Parties

1. JOMEL B. LOZADA, is a Filipino, single, and a resident of 99

Kap. Simeon Luz St., Brgy. 6, Lipa City, Batangas;

2. CAMILLE ANNE PEREZ, is a Filipino, single and a resident

of 42 J.P. Rizal St., Tanauan, Batangas, where she may be served with
summons and other court processes;

Causes of Action

3. On 25 April 2018, Perez borrowed One Million Pesos (Php

1,000,000) with an agreed interest of five percent (6%) per annum as
evidenced by a promissory note herein attached as Annex “A” and
form an integral part of this complaint;

4. The debt has become due and demandable on 25 October 2018,

as shown in the attached promissory note;
 5. Despite Lozada’s repeated verbal and written demands, Perez
failed to pay the debt without valid grounds to the damage and
prejudice of Lozada;

6. In order to enforce his rights, Lozada has sought legal counsel

with attorney’s fees amounting to One Hundred Thousand Pesos (Php
100,000) and appearance fee of Two Thousand Pesos (Php 2,000) per
hearing, as evidenced by the Contract for Legal Services attached
herein as Annex “C”;

7. Lozada paid for litigation expenses amounting to Twenty

Thousand Pesos (Php 20,000) as evidenced by Official Receipt attached
herein as Annex “D”.

Allegations for the Issuance of Preliminary Attachment

8. Lozada has a valid and sufficient cause of action against Perez

regarding the collection of sum of money which is already due and
demandable

9. Perez has removed or disposed of, or is about to remove or

dispose of her property, with intent to defraud her creditors thereby
rendering nugatory and ineffective whatever money judgment this
honorable court may render in this case.

10. Perez does not have sufficient security for the claim sought
for by Lozada against her.

11. Lozada is willing to put up a bond for the issuance of

preliminary attachment in an amount fixed by the court, not exceeding
One Million Pesos (Php 1,000,000) which is the plaintiff’s claim.

Relief

ACCORDINGLY, Lozada asks that, pending hearing of this case,

a writ of preliminary attachment be issued against the property of the
defendant to serve as security for the satisfaction of any judgment that
may be recovered herein; and after due hearing, judgment be rendered
ordering Perez to pay the following:

1. Principal debt of Php 1,000,000;

2. Interest of 6% per annum;

 3. Attorney’s fees amounting to Php 100,000 and appearance fee
of Php 2,000 per hearing;

4. Litigation expenses amounting to Php 20,000.

Other reliefs just and equitable are also prayed for.

Lipa City, 13 August 2019.

(Sgd.) Jackson Luna

Counsel for Plaintiff
Luna and Luna Law Office, M.K. Lina
St., Lipa City, Batangas
Roll of Attorneys No. 90909
PTR 84521; 01/08/19; Lipa City
IBP 34879; 01/08/19; Lipa City
MCLE Comp. No. IV-0009123; 01/09/18
Republic of the Philippines)
Lipa City, Batangas) SS.

Verification and Certification

I, JOMEL B. LOZADA, state under oath that I have read the

above complaint and the allegations in it are true and correct of my
personal knowledge and/or based on authentic record. I also certify
under oath that (a) I have not previously filed any action involving the
same issues in any court, tribunal or quasi-agency; (b) that, to the best
of my knowledge, no such action is pending in any of them; and (c) if
I should learn of the filing of such action, I shall report it to the court
within five days from notice.

Lipa City, Batangas; 13 August 2019.

(Sgd.) JOMEL B. LOZADA

Affiant

Signed and sworn before me this 13 August 2019 at Lipa City,

Batangas by affiant whom I personally know.

(SGD.) Daniel Adrian R. Cañizo

Notary Public for Lipa City
56 P. Torres St., Lipa City
Commission Serial 14747
Until Dec. 31, 2019
Roll of Attorney 75398
PTR 88553; 1-15-19; Lipa City
IBP 21421; 1-15-19; Lipa City
MCLE Comp. No. III-0011072; 09/04/18

Doc. 41;
Page 14;
Book IV
Series of 2019
 Republic of the Philippines
NATIONAL CAPITAL JUDICIAL REGION
Regional Trial Court
Branch 92, Quezon City

SKYLINE PIGEON FINANCE

COMPANY, INC.
Plaintiff,
Civil Case: ______
-versus-
For: Sum of Money plus
damages with prayer for
issuance of writ of replevin

RUSSEL MARC BANAG

Defendant.
x--------------------------------------------x

COMPLAINT

Plaintiff, through counsel, states that:

1. Plaintiff, SKYLINE PIGEON FINANCE COMPANY, INC., a

domestic corporation engaged in consumer and retail lending business
duly organized and existing under Philippine laws, having its
principal office at 9E, Mataas Bldg., Mapagkawanggawa St., Teachers
Village, Quezon City, represented by Loan Services Manager PRINCE
MAC A. LIMOT. Copy of the Secretary Certificate is hereto attached
as Annex “A”, and is made an integral part hereof;

2. Defendant, RUSSEL MARC BANAG, is a Filipino, single, of

legal age, and a resident of 19 Zamora St., Brgy. Parada, Valenzuela
City, where he may be served with summons and other processes of
this Honorable Court;

3. Banag obtained a loan from Skyline Pigeon Finance Company

in the sum of ONE MILLION TWO HUNDRED EIGHTY-ONE
THOUSAND NINE HUNDRED PESOS (Php 1,281,900). For value
received, Banag executed the corresponding Promissory Note, and as
security of the loan, he mortgaged to Skyline Pigeon a motor vehicle
specifically described as follows:

Make : Ford Ranger Wildtrak

 Type/Year Model : 2018
Motor : 7F18-655767
Chassis : FR610W-395742
Plate: : ZZZ 999

Photocopies of the Promissory Note and the Chattel Mortgage

Contract are hereto attached as Annexes “B” and “C” respectively, and
are made integral part hereof;

4. The Chattel Mortgage was duly notarized and registered with

the Registry of Deeds and the Land Transportation Office. Photocopy
of the Certificate of Registration with encumbrance in favor of Skyline
Pigeon is hereto attached as Annex “D”

5. The Chattel Mortgage Contract provides that:

“Section 5. In case the MORTGAGOR fails to

pay any of the installment payment as and when the
same falls due as herein above-provided, or to pay
the interest and/or compounded interest that may
be due hereunder or otherwise violates any of the
terms and conditions of this agreement, then the
MORTGAGEE shall have the right, at its option to
declare the entire amount of all the obligation due
and payable, and may file an ordinary civil action for
the collection of the said indebtedness as herein
below provided, said MORTGAGOR hereby
expressly renounce and waive his entire right to the
benefits provided for in Art. 1484 of the Civil Code
or in such similar future laws;

Section 8. At any time after the breach or

default in the performance of any condition herein
stipulated, more particularly his/their failure to any
installment as above provided or to pay when due,
any other obligation which said MORTGAGOR(S)
may incur, or upon the occurrence of any of the
contingencies provided for in the preceding
paragraphs, the MORTGAGEE may foreclose this
mortgaged immediately before the expiration of
thirty (30) days from the date of default and even
before default in the payment of two (2) installments
provided in Article 1484 of the New Civil Code, the
MORTGAGOR(S) by these presents waiving and
 renouncing expressly whatever right he/they
has/have or may have to any terms, right or
privilege granted to him/them by the Chattel
Mortgage Law (Act No. 1509) or any other law which
may be enacted in the future.”

6. Default in payment of the Promissory Note or violation

of the provisions of the Chattel Mortgage makes the whole
amount of the obligation due and demandable. The plaintiff may
then take actual possession and control of the mortgaged vehicle
and has the special power to sell the mortgaged property at
public auction or private sale, at the Mortgagee’s option.

7. Banag has a remaining balance of SEVEN HUNDRED

FIFTY SIX THOUSAND NINE HUNDRED EIGHTY-ONE
PESOS AND SIXTY NINE CENTAVOS (Php 756,981.69).

8. Skyline Pigeon made several demands upon Banag to

either pay the entire balance or surrender the vehicle. The last
Demand Letter was personally sent and actually received by
Banag on 15 July 2019. Photocopy of which is attached as Annex
“E” and made integral part hereof;

9. Despite such demands, Banag failed and refused to

either pay the obligation or surrender the vehicle.

10. To protect and enforce its claim, Skyline Pigeon was

forced to engage the services of counsel causing it to incur
attorney’s fees in the amout of Fifty Thousand Pesos (Php
50,000);

11. Pursuant to Section 2 of Rule 60 of the Revised Rules of

Court, an Affidavit of Plaintiff’s representative is hereto attached
as Annex “F” and made integral part hereof, in support of the
prayer for the issuance of a Writ of Replevin;

12. Skyline Pigeon is willing to file a good, sufficient, and

solvent bond double the value of the mortgaged vehicle should
Banag be later adjudged to be entitled thereto.

13. Should it not be possible or practicable to return the

vehicle to Skyline Pigeon for purposes of foreclosure, Banag
should be held liable to pay Skyline Pigeon Php 756,981.69. In
addition, Banag should also be held liable to legal interest from
the last date of demand, and P50,000 Attorney’s fees.

Relief

ACCORDINGLY, Skyline Pigeon asks that:

1. A Writ of Replevin be issued ordering the seizure of the

vehicle described under Paragraph 3 of this Complaint and
directing the delivery to Skyline Pigeon for purposes of
foreclosure;

2. After due hearing,

a. Confirm Skyline Pigeon’s right over the vehicle;

b. Order Banag to pay Attorney’s fees, costs of

litigation and any deficiency if the cost of the car sold is
less than the outstanding obligation;

3. Alternatively, in case the return of the vehicle is

impracticable or impossible, to render judgment in favor of
Skyline Pigeon and direct Banag to pay:

a. Php 756,981.69 as the principal amount of the

outstanding balance;

b. Attorney’s fees

c. Cost of suit

Other reliefs just and equitable are also prayed for.

Quezon City, 14 September 2019.

(SGD.) MIRALYN ABELLA

Counsel for Plaintiff
5 Mapagkawanggawa St.,
Teachers Village, Quezon City
Roll of Attorney 87651
PTR 97022; 1-7-19; Quezon City
IBP 15882; 1-7-19; Quezon City
MCLE Comp. No. IV-0011099;
03/04/18
Republic of the Philippines)
Quezon City) SS.

Verification and Certification

I, PRINCE MAC A. LIMOT, in behalf of and as duly authorized

representative of Skyline Pigeon Finance Company Inc., state under
oath that I have read the above complaint and the allegations in it are
true and correct of my personal knowledge and/or based on authentic
record. I also certify under oath that (a) I have not previously filed any
action involving the same issues in any court, tribunal or quasi-agency;
(b) that, to the best of my knowledge, no such action is pending in any
of them; and (c) if I should learn of the filing of such action, I shall
report it to the court within five days from notice.

Quezon City, 14 August 2019.

(Sgd.) PRINCE MAC A. LIMOT

Affiant

Signed and sworn before me this 14 August 2019 at Quezon City,

by affiant whom I personally know.

(SGD.) Dhina Malabanan

Notary Public for Quezon City
18 Cordillera St.,Brgy. Don Manuel
Quezon City
Commission Serial 10047
Until Dec. 31, 2019
Roll of Attorney 81238
PTR 88003; 1-15-19; Quezon City
IBP 28811; 1-15-19; Quezon City
MCLE Comp. No. II-0009092; 01/04/18

Doc. 8;
Page 35;
Book V
Series of 2019
Affidavit
 Republic of the Philippines
NATIONAL CAPITAL JUDICIAL REGION
Metropolitan Trial Court
Branch 82, Valenzuela City

RACHEL MAE POLINIO,

Plaintiff,

-versus- Civil Case: ______

For: Unlawful Detainer

LOU CHRISTIAN JOSEPH OCENAR,

Defendant.
x-----------------------------------------x

COMPLAINT

Plaintiff, by counsel, states that:

The Parties

1. RACHEL MAE POLINIO, is a Filipino, single, and a resident

of 21 Burgos St. Fortune 7 Village, Brgy. Parada, Valenzuela City;

2. LOU CHRISTIAN JOSEPH OCENAR, is a Filipino, single and

a resident of 28C Brgy. Paso de Blas, Valenzuela City, where he may
be served with summons and other court processes;

3. Polinio is the owner of a land over which an apartment had

been constructed located at 28 Brgy. Paso de Blas, Valenzuela City;

Cause of Action

4. By virtue of a contract of lease, Polinio leased unto Ocenar

unit C of the apartment for a consideration of Php 6,500 a month as
rental to be paid within the first seven (7) days of each month stating
1 October 2018;

5. Ocenar failed to pay the agreed rental for several months

starting 8 February 2019 up to the present;
 6. On 7 June 2019, Polinio sent a letter of demand to vacate the
unit which was received by Ocenar, as shown in the registry return
receipt attached hereto as Annex “A” and form an integral part
hereof;

7. Despite the letter of demand and several oral demands,

Ocenar failed and still refused to pay the rentals and to vacate the
apartment;

8. Because of Ocenar’s non-payment and refusal to vacate the

premises, Polinio was compelled to file this complaint and engage the
services of counsel in the amount of Php 15,000.

Relief

ACCORDINGLY, Polinio asks that judgment be rendered in her

favor ordering Ocenar:

1. To vacate the subject premises;

2. To pay the amount of Php 5,000 for every month of reasonable

use as compensation until he finally vacates the premises;

3. To pay the cost of the suit.

Valenzuela City, 10 September 2019.

(SGD.) NIMFA SANCHEZ

Counsel for Plaintiff
301 LB Building,
515 Paso de Blas Rd., Valenzuela City
Roll of Attorney 95432
PTR 95413; 1-7-19; Valenzuela City
IBP 19502; 1-7-19; Valenzuela City
MCLE Comp. No. II-0006792;
01/05/18

Republic of the Philippines)

Valenzuela City) SS.

Verification and Certification

 I, RACHEL MAE POLINIO, state under oath that I have read the
above complaint and the allegations in it are true and correct of my
personal knowledge and/or based on authentic record. I also certify
under oath that (a) I have not previously filed any action involving the
same issues in any court, tribunal or quasi-agency; (b) that, to the best
of my knowledge, no such action is pending in any of them; and (c) if
I should learn of the filing of such action, I shall report it to the court
within five days from notice.

Valenzuela City, 14 August 2019.

(Sgd.) RACHEL MAE POLINIO

Affiant

Signed and sworn before me this 14 August 2019 at Valenzuela

City after affiant exhibited to me her passport, issued on 28 January
2015 at Valenzuela City.

(SGD.) ROWENA CERILLO

Notary Public for Valenzuela City
412 South Star Building, MacArthur
Hwy., Valenzuela City
Commission Serial 31094
Until Dec. 31, 2019
Roll of Attorney 94622
PTR 97691; 1-14-19; Valenzuela City
IBP 38797; 1-14-19; Valenzuela City
MCLE Comp. No. VI-00015792;
01/05/18

Doc. 13;
Page 55;
Book VIII
Series of 2019
 Republic of the Philippines
NATIONAL CAPITAL JUDICIAL REGION
Metropolitan Trial Court
Branch 82, Valenzuela City

MARK EVANDER MARZAN,

Plaintiff,

-versus- Civil Case: ______

For: Forcible Entry

PAOLO ANTONIO GIMER,

Defendant.
x-----------------------------------------x

COMPLAINT

Plaintiff, by counsel, states that:

The Parties

1. MARK EVANDER MARZAN, is a Filipino, single, and a

resident of 334 T. Santiago St., Valenzuela City;

2. PAOLO ANTONIO GIMER, is a Filipino, single and a resident

of 45 Captain Cruz St., Valenzuela City, where he may be served with
summons and other court processes;

Cause of Action

3. Marzan is the owner of a land, through a Deed of Sale from

the original owner JOSEPH ALEXEI PADILLA, a copy of such deed is
hereto attached as Annex “A”;

4. The parcel of land, situated in 45 Captain Cruz St., Valenzuela

City, is covered by Transfer of Certificate of Title 72942 issued by the
Register of Deeds of Valenzuela City and is more particularly
described as follows:

(Description)

A copy of TCT 72942 is hereto attached as Annex “B”;

 5. On or about 10 March 2019, Gimer, through stealth and
strategy, occupied the parcel of land in question and refuses to vacate
the same despite repeated oral and written demands. A copy of the
writtend demand is attached herein as Annex “C”;

6. Gimer’s acts compelled Marzan to incur damages consisting

of attorney’s fees in the amount of Php 25,000 and filing fee, cost of
transportation and other miscellaneous accommodation of lawyers
and other personal expenses to be incurred in attending hearings in
the amout of Php 20,000.

Relief

ACCORDINGLY, Marzan asks that judgment be rendered in her

favor ordering Gimer:

1. To vacate the subject premises;

2. To pay the amount of Php 25,000 by way of attorney’s fees

and Php 20,000 by way of other litigation expenses;

3. To pay the cost of the suit.

Valenzuela City, 13 September 2019.

(SGD.) NIMFA SANCHEZ

Counsel for Plaintiff
301 LB Building,
515 Paso de Blas Rd., Valenzuela City
Roll of Attorney 95432
PTR 95413; 1-7-19; Valenzuela City
IBP 19502; 1-7-19; Valenzuela City
MCLE Comp. No. II-0006792;
01/05/18

Republic of the Philippines)

Valenzuela City) SS.

Verification and Certification

 I, MARK EVANDER MARZAN, state under oath that I have
read the above complaint and the allegations in it are true and correct
of my personal knowledge and/or based on authentic record. I also
certify under oath that (a) I have not previously filed any action
involving the same issues in any court, tribunal or quasi-agency; (b)
that, to the best of my knowledge, no such action is pending in any of
them; and (c) if I should learn of the filing of such action, I shall report
it to the court within five days from notice.

Valenzuela City, 14 August 2019.

(Sgd.) MARK EVANDER MARZAN

Affiant

Signed and sworn before me this 14 August 2019 at Valenzuela

City by affiant whom I personally know.

(SGD.) ROWENA CERILLO

Notary Public for Valenzuela City
412 South Star Building, MacArthur
Hwy., Valenzuela City
Commission Serial 31094
Until Dec. 31, 2019
Roll of Attorney 94622
PTR 97691; 1-14-19; Valenzuela City
IBP 38797; 1-14-19; Valenzuela City
MCLE Comp. No. VI-00015792;
01/05/18

Doc. 99;
Page 5;
Book X
Series of 2019