Legal Forms 1 20

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Submitted to Atty.Isaias Giduquio
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Submitted by: Aia Marie M.Comedid
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CAPTION OF CIVIL ACTION FALLING WITHIN JURISDICTION OF MUNICIPAL
COURT
Republic of the Philippines

Municipal Trial Court
Bogo, Cebu
JOSE PIDAL
Plaintiff
-versus- Civil Case No.2324

For: sum of money
MARIA DELA CRUZ

Defendant
x________________________x
CAPTION OF CIVIL ACTION FALLING WITHIN JURISDICTION OF REGIONAL

TRIAL COURT

Regional Trial Court
Branch 14, Cebu City
JOSE PIDAL
Plaintiff
-versus- Civil Case No.2324

For: sum of money
MARIA DELA CRUZ

Defendant
x________________________x
CAPTION OF CIVIL ACTION FALLING WITHIN JURISDICTION OF COURT OF

APPEALS

COURT OF APPEALS
Manila
JOSE PIDAL
Plaintiff
-versus- CA-G.R. CV No.234
MARIA DELA CRUZ

Defendant
CAPTION OF CIVIL ACTION FALLING WITHIN JURISDICTION OF SUPREME
CURT

SUPREME COURT
Manila
JOSE PIDAL
Plaintiff
-versus- G.R. No.1234234
MARIA DELA CRUZ

Defendant
x________________________x
CAPTION OF SPECIAL PROCEEDINGS

Branch 14, Cebu City
In the Matter of ____________
Juan dela Cruz

Petitioner S.P.PROC. No.4342
x____________________x
Acknowlegdment
ACKNOWLEDGMENT:
Republic of the Philippines )

PROVINCE OF CEBU ) S.S.
BEFORE ME, a Notary Public for and in the City of Naga Cebu, Philippines, personally
came and appeared
NAME GOVERNMENT ISSUED ID NO.

GARRY A. POGADOR SSS ID NO. 06-234567-3
JUAN RICARDO TORRES SSS ID NO. 06-6442875-2
Known to me to be the persons who executed the foregoing Deed of Absolute Sale and
acknowledged to me that the same is their free act and voluntary deed.
This instrument, consisting of TWO (2) pages, including the page on which this
acknowledgment is written, has been signed on the left margin of each and every page thereof by
the concerned parties and their witnesses, and sealed with my notarial seal.
WITNESS MY HAND AND SEAL on this 28th day of May 2003 at the City of Naga,
Cebu Philippines
Atty. GREG GOMEZ

Notary Public
Until December 31, 2003
PTR No. 0379919; 01-04-2005; Cebu City.
IBP NO.512046;C1-03-2003;Cebu City
Roll No.123455,Cebu City chapter
Doc. No. 473

Page No. 87
Book No. 60
Series of 2019
JURAT
SUBSCRIBED AND SWORN TO before me, by the above named affiant, this December
13, 2018 who is personally known to me and to me know personally to be the same person
who signed this VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING in
Province of Naga, Cebu, Philippines.
Doc. No. 347
Page No. 91
Book No: 65
Series of 2018
ERIKA JUDI LOMOCSO

Notary Public
Commission Expires on December 31,2018
IBP O.R.No. 12345/Cebu City/12-13-2018
PTR O.R.No. 34454545/Naga Cebu/12-3-2018
MCLE Compliance No.V-92342445,Cebu City,12/2/2018
Roll.no. 656452
NOTICE OF HEARING
THE BRANCH CLERK OF COURT

RTC BRANCH 65-CITY OF NAGA
Please submit the foregoing for the consideration and approval immediately upon receipt
hereof sans argument and appearance of counsel. Thank you very much.
Aia Marie Comedido

Counsel for Defendant
4523 Door 4, Diplomat Hotel.,
Ramos St. Cebu City
AFFIDAVIT OF PROOF OF SERVICE

Republic of the Philippines}
Province of Cebu } S. S
AFFIDAVIT OF PROOF OF SERVICE
I, PRIMITIVO SANTOS, of legal age, and resident of 22 Rizal Street, Tisa, Cebu City.
After being sworn in accordance with law depose and say:
1. That I am the messenger of Atty.Aia Marie M. Comedido;
2. That I on December 15,2018 personally delivered Defendant’s answer to

Plaintiff NATALIA C. SANTOS with address Barangay Pakigne, Minglanilla,
Cebu and Atty.Rachel E. Bonita plaintiff’s counsel at her office Suite 205, Silver
Tower Bldg.,Lahug,Cebu City;
3. The Answer was received by plaintiff herself and her counsel.
PRIMITIVO SANTOS
Affiant
SSS ID NO: 06-1234567-03
Doc. No. 376

Page No. 91
Book No: 65
Series of 2018
ERIKA JUDI LOMOCSO

Notary Public
MCLE Compliance No.V-92342445,Cebu City,12/4/2018
Roll.no. 656452
Secretary's Certificate
SECRETARY’S CERTIFICATE
I, (name of Corporate Secretary), of legal age, Filipino, being the duly elected and
qualified Corporate Secretary of (name of applicant firm), a corporation duly organized and
existing under the laws of the Philippines, with office address at (office address of applicant
firm), under oath, do hereby certify that at the special meeting of the Board of Directors of the
Corporation held on (date of special meeting), the following resolution was unanimously
adopted:
RESOLVED, that (name of officer of firm), (position of officer) be as it hereby,

authorized to transact, execute and sign all documents in behalf of the Corporation pertaining to
its application for registration under the Renewable Energy Act of 2008 (Republic Act No. 9513)
with the Board of Investments for its (proposed project activity) as Renewable Energy Developer
under the Mandatory List of the 20___ Investment Priorities Plan.
IN WITNESS WHEREOF, I have hereunto affixed my signature this __________ day

of _____________, 20___ at __________________________.
____________________
Corporate Secretary
Subscribed and Sworn to before me this __________________ at _______________,

affiant exhibited to me his CTC No. ____________________ issued on ___________________
at ___________________.
Doc. No. _______

Page No. _______
Book No. _______
Series of _______
VERIFICATION AND CERTIFICATION AGAINST NON-FORUM SHOPPING,

SPLITTING A SINGLE CAUSE OF ACTION AND MULTIPLICITY OF SUITS
I, __________________________________, of legal age, Filipino,
married/single/widow/widower, and a resident of
______________________________________________________, on oath, state:
1. That I am the _____________________ in the above-entitled case have caused this

_______________________________ to be prepared; that I read and understood its
contents, which are true and correct of my own personal knowledge and/or based on true
records;
2. That I have not commenced any action or proceeding involving the same issue or subject
matter, and specifically the same check/s in the Supreme Court, the Court of Appeals or
any other tribunal or agency, particularly before the Office of the City Prosecutor of
_______________________; that to the best of my knowledge, no such action or
proceeding is pending in the Supreme Court, the Court of Appeals or any other tribunal or
agency, and that, if I should learn thereafter that a similar action or proceeding has been
filed or is pending before these courts or tribunal or agency, I undertake to report that fact
to the Court within five (5) days therefrom.
3. That the filing of this case is not in violation of the rule against splitting a single cause of
action or multiplicity of suits.
4. That I knowingly and voluntarily waive and forego the institution of any criminal
complaint for Violation of Batas Pambansa Blg. 22 against the defendant herein based on
the same check/s subject matter of this Small Claims Complaint.
IN WITNESS WHEREOF, I have hereunto set my hand this ___________ day of

_____________________, 20_____.
__________________________
Affiant
SUBSCRIBED AND SWORN TO before me this _____ day of _________________.
Doc. No. _____

Page No. _____
Book No. _____
Series of _____
SAMPLE COMPLAINT FOR COLLECTION OF SUM OF MONEY

6TH JUDICIAL REGION
Branch _____
Iloilo City
MIA C. SANCHEZ, Civil Case No. ________

Plaintiff FOR: COLLECTION FOR
A SUM OF MONEY WITH
DAMAGES
- versus -
PAOLO D. CRUZ,
Defendant.
x -----------------------x
COMPLAINT
Plaintiff, through the undersigned counsel unto this Honorable Court, hereby respectfully
avers:
1. That plaintiff is of legal age, Filipino, married, and a resident of Alta Tierra Village,
Jaro, Iloilo City, Philippines while the defendant is also of legal age, married, Filipino and a
resident of Brgy. Dungon A., Jaro, Iloilo City, Philippines where summons and court processes
may be served;
2. That on February 14, 2013, the defendant borrowed from the plaintiff a sum of money
amounting to One Million Pesos (PhP1,000,000.00) with an agreed interest of five percent (5%)
per month as evidenced by a promissory note herein attached as Annex “A” and form an integral
part of this complaint;
3. That as shown in the attached promissory note, the indebtedness of the defendant has
become due and demandable on February 14, 2014;
4. That despite plaintiff's repeated demands, both written and verbal, defendant failed,
neglected and refused to fulfill obligations without just and valid grounds to the continued
damage and prejudice of plaintiff, as evidenced by Annex “B” – Demand Letters;
5. That the plaintiff in order to enforce his rights and interests, has sought the services of
a legal counsel with attorney’s fees amounting to One Hundred Thousand Pesos (PhP
100,000.00) and an appearance fee of Two Thousand Pesos (PhP 2,000.00) per hearing as
evidenced by Annex “C” – Contract for Legal Services;
6. That the plaintiff has paid for litigation expenses amounting to Twenty Thousand Pesos
(PhP 20,000.00) as evidenced by Annex “D” – Official Receipt;
7. That the plaintiff has suffered moral damages at the sum discretion of the Honorable
Court;
WHEREFORE, premises considered, it is hereby respectfully prayed before the

Honorable Court to render decision in favor of the plaintiff and order the defendant to pay the
following:
a. the sum of One Million Pesos (PhP 1,000,000.00) plus interest at the rate of five
percent (5%) per month as stipulated in the promissory note;
b. moral damages, exemplary damages at the sum discretion of the court;
c. attorney’s fees amounting to One Hundred Thousand Pesos (PhP 100,000.00)

and an appearance fee of Two Thousand Pesos (PhP 2,000.00) per hearing;
d. litigation expenses amounting to Twenty Thousand Pesos (PhP 20,000.00).

Other reliefs and remedies deemed just and equitable under the foregoing premises are
likewise prayed for.
Iloilo City, December 6, 2014.
ATTY. VINCENT ENRIQUE A. VARONA

Counsel for Petitioner
Varona Law Office, Alta Tierra Village, Jaro, Iloilo City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/14, Iloilo City
IBP NO. 123456, 01/04/14, Iloilo City
MCLE Comp. No. IV-0009876, 01/02/14
REPUBLIC OF THE PHILIPPINES)

PROVINCE OF ILOILO ) SS.
x----------------------------x
VERIFICATION AND CERTIFICATION

I, MIA C. SANCHEZ, of legal age, Filipino, married, and a resident of Alta Tierra
Village, Jaro, Iloilo City, Philippines, after being sworn in accordance with law, hereby depose
and say:
(1) That I am the Plaintiff in the above-entitled case;
(2) That I have caused the preparation of the above Complaint and I have read the
same and understood the contents thereof;
(3) That the allegations contained therein are true and correct of my own personal
knowledge and based on authentic records;
IN WITNESS WHEREOF, I have hereunto set my hand this 6th day of December 2014
at Iloilo City, Philippines.
MIA C. SANCHEZ
Affiant
TIN 98765-003; Iloilo City
SUBSCRIBED AND SWORN to before me, this 6th day of December 2014, affiant
exhibiting to me his Tax Identification Card as shown above below his name as competent
evidence of his identity.
ATTY. VINCENT ENRIQUE A. VARONA

Counsel for Petitioner
Varona Law Office, Alta Tierra Village, Jaro, Iloilo City
PTR NO. 654321, 01/06/14, Iloilo City
IBP NO. 123456, 01/04/14, Iloilo City
MCLE Comp. No. IV-0009876, 01/02/14
Doc. No. ____

Page No. ____
Book No. ____
Series of ____
COMPLAINT FOR SUM OF MONEY: PLAINTIFF AS NATURAL PERSON

National Capital Judicial Region
REGIONAL TRIAL COURT
Branch 101, Makati City
ESTA PADORA,
Plaintiff,
Civil Case No. 000882

- versus –
For: Sum of Money
MANGGA GANTSO,
Defendant.
x -------------------------- x
COMPLAINT
PLAINTIFF, by counsel, respectfully states that:
1. Plaintiff is a Filipino, of legal age, and resident of 6750 Forbes Park, Makati City;
defendant is also a Filipino, of legal age and resident of 6752, Forbes Park, Makati City, where
he may be served with summons and other processes.
2. Sometime in January 2005 and over a period of six (6) months, defendant borrowed
certain amounts from plaintiff. Defendant promised to pay these amounts on an installment basis
monthly. These amounts now total Nine Hundred Thousand Pesos (P900,000.00).
3. Despite repeated demands, both oral and written, defendant failed or has refused to
pay any amount to plaintiff as no installment payment has even been made. A copy each of
plaintiff’s two (2) demand letters is attached as ANNEX A and B.
4. Resort to the Barangay Conciliation process proved fruitless as defendant failed to

appear, despite notice on him to appear. Thus, a Certification to File Action, a copy of which is
attached as ANNEX C, was issued by the Barangay Chairman.
5. Defendant’s obligation is due and demandable and plaintiff is entitled to the payment
of the entire amount of Nine Hundred Thousand Pesos (P900,000.00) plus legal interest.
6. By reason of defendant’s unreasonable failure or refusal to pay his due and
demandable obligation, plaintiff was forced to engage the services of counsel to vindicate his
rights thereby committing himself to pay legal expenses amounting to Fifty Thousand Pesos
(P50,000.00).
WHEREFORE, plaintiff respectfully prays for judgment in his favor through a Decision
directing defendant to pay him NINE HUNDRED THOUSAND PESOS (P900,000.00), with
legal interest, as ACTUAL DAMAGES and FIFTY THOUSAND PESOS (P50,000.00) as
Attorney’s Fees.
Other just and equitable reliefs are also prayed for.
Quezon City for Makati; 13 April 2007.
(Sgd.) ATTICUS FINCH

Counsel for Plaintiff
[Address]
COMPLAINT FOR SUM OF MONEY: DEFENDANT AS JURIDICAL PERSON
Branch 101, Makati City
ESTAFA DAMAGA,
Plaintiff,
Civil Case No. 000883

- versus –
For: Sum of Money
LIWANAG CORPORATION,
Defendant.
x -------------------------- x
COMPLAINT
1. Plaintiff is a Filipino, of legal age, and resident of 6750 Forbes Park, Makati City;
defendant is also a Filipino, of legal age and resident of 6752, Forbes Park, Makati City, where
he may be served with summons and other processes.
2. Sometime in January 2005 and over a period of six (6) months, defendant, a
corporation duly organized under the laws of the Philippines, borrowed certain amounts from
plaintiff through its president Antonio Liwanag. Defendant promised to pay these amounts on an
installment basis monthly. These amounts now total Nine Hundred Thousand Pesos
(P900,000.00).
3. Despite repeated demands, both oral and written, defendant failed or has refused to
pay any amount to plaintiff as no installment payment has even been made. A copy each of
plaintiff’s two (2) demand letters is attached as ANNEX A and B.
4. Resort to the Barangay Conciliation process proved fruitless as defendant failed to

appear, despite notice on him to appear. Thus, a Certification to File Action, a copy of which is
attached as ANNEX C, was issued by the Barangay Chairman.
5. Defendant’s obligation is due and demandable and plaintiff is entitled to the payment
of the entire amount of Nine Hundred Thousand Pesos (P900,000.00) plus legal interest.
6. By reason of defendant’s unreasonable failure or refusal to pay his due and

demandable obligation, plaintiff was forced to engage the services of counsel to vindicate his
rights thereby committing himself to pay legal expenses amounting to Fifty Thousand Pesos
(P50,000.00).
WHEREFORE, plaintiff respectfully prays for judgment in his favor through a Decision
directing defendant to pay him NINE HUNDRED THOUSAND PESOS (P900,000.00), with
legal interest, as ACTUAL DAMAGES and FIFTY THOUSAND PESOS (P50,000.00) as
Attorney’s Fees.
Other just and equitable reliefs are also prayed for.
Quezon City for Makati; 13 April 2007.
(Sgd.) ATTICUS FINCH

Counsel for Plaintiff
[Address]
JURIDICAL PERSON AS PARTIES: REPUBLIC OF THE PHILIPPINES AS PARTY
Republic of the Philippines, thru

The Department of Health,
Plaintiff,
-versus- Civil Case No.
ABC Construction Co., Inc.,

Defendant.
x-------------------------------------x
JURIDICAL PERSON AS PARTIES: PRIVATE CORPORATION OR OTHER

JURIDICAL ENTITIES DULY REGISTERED, AS PARTIES.
XYZ Company, Inc.,

Plaintiff,
Juan De la Cruz,
Defendant.
x---------------------------------------x
Allegations showing it is a juridical entity:
Plaintiff XYZ Company, Inc., is a corporation duly organized and existing under and by
virtue of the laws of the Philippines, with principal offices at 1234 Ayala Ave., Makati City,
where it may be served with summons and other legal processes.
CORPORATION DE FACTO AS PLAINTIFF.
XYZ Corporation,
Plaintiff,
David Fermosa,
Defendant.
x-------------------------------------x
Plaintiff XYZ Company, Inc., is a corporation with principal offices at 1234 Ayala Ave.,
Makati City, where it may be served with summons and other legal processes (keeping silent as
to the fact that the plaintiff corporation was not duly-registered as a corporation because the rule
is that where a corporation, not registered, is suing a third person on a contract the latter entered
into with it, he may not be heard to dispute the existence of said corporation, as he is stopped
from denying the corporate existence) ;
Allege cause of action…

REAL PARTIES-IN-INTEREST

CITY OF IMUS ) S.S.
AFFIDAVIT OF INSURANCE CLAIMS
I, Miranda Curl, of legal age, Filipino, married, and presently residing at Blk 55, Lot 66,
Ibarra Homes, Tulingan, Cavite, after having been duly sworn to in accordance with law, depose
and state:
1. I am the owner of a certain registered motor vehicle, which I inherited from my
deceased father through intestate succession, with the particular description as follows, to
wit:
MAKE: Honda
BODY: Sedan SERIES:
Civic MODEL: 1998
PLATE NO.: UTS 101
Serial/Chassis No.: US15- 2B3509
MV FILE No.: 2477- 33438
2. On 03 October 2013 at 2 o’clock in the afternoon, the said motor vehicle met an
accident.
3. This had happened while i was parking in front of a hardware store between the two
motor vehicles, at the left side was an elf van, and while at the right was a car. At that
time, I was carefully looking at the car on my right, that I did not notice the elf van in the
parking area. When I made a reverse turn, i hit the elf by my tail light and bumper
4. It is for that reason that i am executing this affidavit to file a claim for insurance.
5. I therefore have executed this Affidavit to attest the truth I mentioned herein and for
whatever legal purposes it may serve.
IN WITNESS WHEREOF, I have hereunto set my hand this 30th day of January 2014
in Imus City, Cavite, Philippines.
MIRANDA CURL
Affiant
Philippine Passport No. 123456
valid until January 13, 2018
SUBCRIBED AND SWORN TO before me this 30th day of January 2014 in Imus City,
Cavite, Philippines, affiant exhibiting to me her competent evidence of identity indicated below
his above- stated name.
Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2014.
REPRESENTATIVE PARTIES

CITY OF IMUS ) S.S.
AFFIDAVIT OF PARENTAL CONSENT TO MARRIAGE

WE, KENDALL RUNNER and RON JEREMY, both of legal age, Filipinos, husband and
wife, respectively, and presently residing at Blk 55, Lot 66, Ibarra Homes, Tulingan, Cavite, after
having been duly sworn to in accordance with law, depose and state:
1. I am/we are the parents of Rocco Siffredi born in born on 18 October 1998 in Grace
Park, Caloocan City
2. My/Our child is intending to contract marriage with Nana Oguya in Meycauayan,
Bulacan;
3. I we are giving our consent to our child, Rocco Siffredi, marrying said Nana Oguya;
4. We are executing this Affidavit for the purpose of informing the authorities concerned
of the veracity of the foregoing facts and for whatever legal purposes it may serve.
IN WITNESS WHEREOF, we have hereunto set our hands this 27th day of January,
2014 in Imus City, Cavite, Philippines.
KENDALL RUNNER
Affiant (Mother)
RON JEREMY
Affiant (Father)
SUBCRIBED AND SWORN TO before me this 30th day of January 2014 in Imus City,
Cavite, Philippines, affiant exhibiting to me her Philippine Passport No. 123456 issued in Manila
on January 12, 2014 and valid until January 13, 2018.
Doc. No. _____;
Page No. _____;
Book No. _____;
Series of 2014.
STOCKHOLDER SUING IN A DERIVATIVE SUIT
Juan de Bagyo and Perdo Pobre

and ABC Corporation, the former
suing as representative of said corporation,
and other stockholders,
Plaintiffs,
-versus- Civil Case No. ____
Derivative suit
Jose Gabiano, Ricardo Tria, Rumolo

Castillo, Jay Padilla
Defendants.
x---------------------------------------x
Allegations showing requirements of derivative suits:

Plaintiffs Juan de Bagyo and Pedro Pobre, both of legal age, are minority stockholders of
plaintiff ABC Corporation, a corporation duly-organized and existing under and by virtue of the
laws of the Philippines, with principal offices at 532 Ayala Ave., Makati City, and are suing in
this derivative suit in the name and as representatives of said corporation.
Defendants are members of the board of directors of said corporation, who in breach of
trust, committed acts inimical to the interests of the corporation, namely: allege facts showing
violations of Sec. 31 of the Corporate Code, to the damage and prejudice of the corporation.
Allege other requirements of derivative suit, as prescribed in Rule 8 of the Interim Rules
of Procedure for Intra-Corporate controversies, such as that plaintiffs exerted all reasonable
efforts, particularly describing such efforts, to exhaust all remedies available under the articles of
incorporation, by-laws or rules governing the corporation to obtain relief they desire; that no
appraisal rights nuisance or harassment suit.
Etc.
Actions prosecuted or defended by representatives on behalf of beneficiaries.
Claim Against the Estate.
ANSWER
In the Matter of the Claim

of Juan Dela Cruz against
of the Estate of Miguelito Cruz,
Administrator for the Estate of Miguelito Cruz in the above-entitled case, thru counsel, in answer
to the claim of Juan Dela Cruz in said estate, states:
That he denies the said claim on the ground that he has no knowledge of the claim to
enable him to deny or admit specifically since this was not communicated to him.
WHEREFORE, it is respectfully prayed that said claim be disapproved.
February 1, 2018, Cebu City.

Spouses as Parties
REPUBLIC OF THE PHILIPPINES

___ Judicial Region
Branch ___
(Venue)
THE PEOPLE OF
THE PHILIPPINES
Plaintiff,
Criminal Case No. ________________
- versus –
SPOUSES HENRY AND JUDITH CRUZ

Accused.
x---------------------x
INFORMATION
The undersigned Assistant Prosecutor, upon sworn complaint original filed by the
offended party, accuses Spouses Henry and Judith Cruz of the crime of CORRUPTION OF
MINORS, committed as follows:
That on or about December 21, 2017 in the city of Cebu, Philippines, within the
jurisdiction of this court, the said accused, did then and there, willfully, unlawfully, feloniously
and maliciously conceal their true name to police officer Ricardo Manggubat, duly-appointed,
qualified and acting as such, and while in the performance of his duties, asked the said accused
for their true name, and the said accused did then and there willfully, unlawfully, and feloniously
and with abuse of confidence and authority, promote and facilitate the prostitution and corruption
of a girl, named Juanita Delos Reyes, a minor of Nine years of age, for the purpose of satisfying
the carnal lust of others.
Contrary to law.
December 28, 2017, Cebu City
Assistant City Prosecutor

Witnesses:
BAIL RECOMMENDED:
Certification
Minors as Incompetent

City of Cebu S.S.
x--------------------------x
AFFIDAVIT OF GUARDIANSHIP
I, Daisy Baluyot,of legal age, widow, Filipino citizen, and presently residing at Maria
Luisa, Cebu City, after having been duly sworn to in accordance with law, do hereby depose and
say:
1. ThatI am the Mother and guardian of the following minors who have an interest in the estate
of the late Juan Baluyot payable by ___________;
Full Name of Minor/s Date of Birth Age

Jameson Baluyot 09/28/2015 3
Marie Ella 08/26/2016 2
2. That the above mentioned minors are under my care and custody;
3. That I am competent to receive in behalf of the said minors any amount/s due them; and
4. ThatI am not an imbecile, insane, a vagrant or a vicious person or ahabitual drunkard or a

habitual criminal, and have not abandoned,neglected or refused to support said minors or caused
them to commit offenses against the law.
5. ThatI am executing this affidavit to attest to the truth of all the foregoing statements and for
whatever legal purpose it may serve.
IN WITNESS WHEREOF, I have hereunto set my hand this 1st day of February 2018 at Cebu
City, Philippines.
Joinder of Permissive Parties in one Complaint.

7th Judicial Region
Branch 11
Cebu City
AA,BB,CC,DD,EE,FF
Plaintiffs,
- versus- Civil Case No. 432
Rough Riders Bus Co.
Defendant.
x-------------------------------x
Plaintiffs are of legal age and are the heirs of the passengers of the bus owned by the
defendant as common carrier, bound for Bogo City on July 15, 2010, when said bus turned turtle
due to its driver’s driving recklessly and negligently, resulting in the death of all passengers, and
causing plaintiffs to suffer damages in the amount of no less than 300,000 PHP each for medical
expenses and loss of earnings, and involving questions of law and of fact common to all
plaintiffs.
Class suit
A, B, C, D, E, F, and G, oin their own

behalf and on behalf of class members,
Plaintiffs,

000120
Juan del, Cruz, Pedro Mansalay,

Cardo Tria, and ABC Voluntary
Association
Defendants.
x-----------------------------x
Plaintiffs are of legal age and are members of the voluntary association, known as ACD
Voluntary Association, which is composed of over 500 members, who are required to contribute
P100.00 monthly, in return for the benefits extended to its members, Plaintiffs are suing on their
own behalf as members of said association and on behalf of all other members thereof, who are
so numerous that it is impracticable to implead them all as plaintiffs.
Defendants, as officers of said association, have mismanaged its affairs, did not render
any accounting to the members, and appropriated the members’ contribution unto themselves,
thereby compelling the members thereof to compel said officers to wind up the affairs of the
association and to require defendants as officers thereof to render an accounting of the money
and property of the association.
It has been held: “An action instituted by several hundred members of a voluntary
association against their officers to compel them to wind up the associations’ affairs and render
an accounting to the money and property in their possession has been held to be a class suit. In
that case there was in truth one single right of action sought to be enforced by the numerous
plaintiffs, not separate, individual, distinct rights pertaining independently to them.
Unwilling plaintiff, impleaded as defendant.
Pedro, Juan and David, all

Surnamed Dela Cruz,
Plaintiffs
-Versus-
Myrna dela Cruz, and Samson

Dela Cruz,
Defendants.
x-------------------------------------------------x
- This is an action for partition of a parcel of land consisting of 15,000 sq,m., located in
Quezon City, and which defendants inherited from their parents, when the latter died in an
accident on March 2, 2005, and since said date, defendant Samson dela Cruz, their elder
brother, has been occupying the same and reaping all its income to himself.
- The instant suit being a suit by and among members of the same family, plaintiffs exerted all
efforts to reach an amicable settlement of the case, by talking to defendant Samson dela
Cruz, convincing him to agree to extra-judicial partition of the property and even informing
him that plaintiffs are willing to forego any and even informing him that plaintiffs are
willing to forego any claim of accounting to convince him to settle the case amicably, but,
all such efforts proved useless.
- Plaintiffs had asked Myrna dela Cruz, being a co-owner to join plaintiffs as co-plaintiff, but
the latter refused, constraining plaintiffs to implead her as a defendant.
Misjoinder and non joinder of parties
Pedro Penduko, and

James Reid
Plaintiffs Civil Case no. 003258
-Versus-
Maria Esther Dela Cruz, Yoko Nga,

And Dodoy Go.
Defendants.
x-------------------------------------------------x
MOTION FOR MISJOINDER OF PARTIES
[1] On 1 June 2006, Plaintiff James Reid was made a party to the case although he
should have not been impleaded.
[2] That plaintiff is not a party in interest to the issue in the instant case since the actual
person in interest is a certain James Red.
[3] WHEREFORE, plaintiff respectfully prays that plaintiff James Reid be dropped as a
party to the case.
Quezon City; 13 April 2007.
Unknown Identity of defendant

NATIONAL CAPITAL JUDICIAL REGION
Branch I, Manila
ACBD Corporation (Philippines), Inc.,

Plaintiff,
- versus - Civil Case No. 1298465
JOHN DOE, For: Replevin

Defendant.
x--------------------------------x
COMPLAINT
COMES NOW, the Plaintiff, through the undersigned counsel, and to this Honorable
Court alleges:
1. That Plaintiff is a domestic corporation existing under the laws of the Philippines, with
offices at 311 P. Casal St., Quiapo, Manila, while defendant is an American citizen, residing at
Room 1024, Manila Hotel, where he may be served with Summons;
2. That plaintiff is the registered owner of a motor vehicle described as a Mitsubishi

Lancer, model 1984, with Plate No. DAY-203;
3. That on October 11, 2017,defendant rented from plaintiff said Lancer car for a week
from October 11 to 18, 2016
4. That on October 20, 2017, and for the next three (3) days thereafter, plaintiff demanded
from defendant the return of the said car; but defendant avoided returning the car by giving one
reason or another;
5. That said car has not been taken for a tax assessment or fine pursuant to law, or seized
on execution or attached;
6. That the value of the said car is P1.5M;
7. That plaintiff is ready and willing to give bond executed to the defendant in double the
value of the property for the return of the property to the defendant should be adjudged, or for
the payment of such sum that defendant may recover from plaintiff in the action.
WHEREFORE, plaintiff prays that:

1. The sheriff or other proper officer be ordered to take possession of the car and dispose
of it in accordance with the Rules of Court;
2. After hearing, judgment be rendered declaring that plaintiff is entitled to the possession
of the car or, should this prove unavailing, sentencing defendant to pay the value of the car.
Manila, December 23, 2017.
ATTY. MIA C. VARGAS

XYZ Building, Manila
IBP No. 12345; 1/3/2015;Manila
PTR No.61879; 2/2/2015; Manila
Entity without juridical personality as defendant

NATIONAL CAPITAL JUDICIAL REGION
Branch I, Manila
ZHIA CRUZ,
Plaintiff,
- versus - Civil Case No. 1298465
ACBD Corporation (Philippines), Inc. For: Damages

Defendant.
x--------------------------------x
COMPLAINT
COMES NOW, the Plaintiff, through the undersigned counsel, and to this Honorable
Court alleges:
1. The plaintiff, of legal age, is a Filipino citizen residing in #123 Rose Street, Dela
Rosa Avenue, Manila, Philippines;
2. The defendant, is a corporation engaged in selling of cars which have an official

office located in #843, Magallanes Street, Osmena Avenue, Manila.
3. That on October 16, 2016, the plaintiff purchased the said Lancer car from the
defendants, Mr. XOXO, director of company guaranteed the authenticity of the car
and that it is in good condition, it amounted to P890,000;
4. That on October 20, 2016, and for the next three (3) days thereafter,the plaintiff upon
going to office tried to turn on the car but it wont start.
5. Due to dismay, the plaintiff called the defendant to inform them that the car broke and
to ask for reimbursement of the money for breach of guaranty.
6. The defendant concealed the damage of the car and despite several demands,
defendant failed to reimburse the amount paid by the plaintiff.
7. The defendant will not pay the amount as they are not liable for the mistake of its
partners like manufacturers who are at fault and that they are not a corporation and
that the acts of their agent does not bind them as to liabilities.
WHEREFORE, plaintiff prays that:

1. The honorable court shall render decision in favor of the plaintiff; and
2. To order the defendant to pay for the amount paid by the plaintiff plus damages
for the breach of warranty.
Manila, December 3, 2016.
ATTY. MIA C. VARGAS

XYZ Building, Manila
IBP No. 12345; 1/3/2015;Manila
PTR No.61879; 2/2/2015; Manila
Alternative defendants

11th
Judicial Region
Branch 54
Davao City
Fe Tuad, Plaintiff, CIVIL CASE no. 1232143
- versus –
Aurelio Laxan, Aurelio Lara

Bonifacio Cruzo, ULTRA
Speed Machine Shop FOR: Damages for death,
and A’s Metal earning capacity,Moral
Products, Defendants. Damages and Attorney's fees
x- - - - - - - - - - - -x
COMPLAINT
COMES NOW, plaintiff, Fe Tuad, by counsel, and unto this Honorable Court, most
respectfully avers THAT:
1. Plaintiff is a Filipino, of legal age, married, and residing at 32E Jacinto St., Davao City,
where he may be served with summons, papers and other process of this Honorable Court ACOP
Law Firm, Suite 704, LANDCO Bldg, Bajada, Davao City.
2. Defendant Aurelio Laxan is a Filipino, of legal age, single, and residing at Purok 14,
Mintal, Davao City, where he may be served with summons, papers and other process of
this Honorable Court.
3. Defendant Bonifacio Cruzo is a Filipino, of legal age, married, and residing at Purok Sto.
Nino, Buhangin, Davao City, where he may be served with summons, papers and other
process of this Honorable Court.
4. Defendant ULTRA Speed Machine Shop and A’s Metal Products is a juridical entity duly
registered with the Securities and Exchange Commission. It is engaged in the selling metal
products and Auto Repair. It is represented herein by Aurelio Lara, owner and manager of
ULTRA Speed Machine Shop and A’s Metal Products. It may be served with papers and other
processes of this Honorable Court at 131 R. Magsaysay Avenue Davao City.
5. Defendant Aurelio Lara is a Filipino, of legal age, married, and residing at 131 R.
Magsaysay Avenue Davao City, where he may be served with summons, papers and other
process of this Honorable Court.
6. Both parties have capacity to sue and to be sued.
7. Plaintiff herein is the wife of victim of the vehicular accident, Romeo Tuadles who is the
sole bread winner of the family.
8. Defendant Bonifacio Cruz, is the registered owner of a Cimarron Jeepney, and

particularly described as follows:
Make and Type: Cimarron Jeepney

Plate No.: LXX-349
9. Defendant ULTRA Speed Machine Shop and A’s Metal Products owned by Aurelio Lara
has legal possession of the vehicle and bound itself by an acknowledgment attached herewith
“Annex A”, to be responsible for any and all incidents that may occur while the said vehicle is in
their custody.
10. Defendant Aurelio Lara is the employer of Aurelio Laxa, being the owner of
ULTRA Speed Machine Shop and A’s Metal Products.
11. On December 29, 2010, Bonifacio Cruz brought his vehicle to ULTRA Speed
Machine Shop and A’s Metal Products by Aurelio Lara for repair and left the said vehicle at the
shop.
12. At about January 2, 2011, Aurelio Laxa, a driver of A’s Metal Products with his
co-workers on board drove the vehicle in going to the beach.
13. In driving back from the beach, Aurelio Laxa lost control of the vehicle while
negotiating a curve causing it to turn turtle resulting in the death of one of its passengers Romeo
Tuadles.
14. A demand letter for indemnification for damages was by plaintiff to defendants.
15. Defendant Bonifacio Cruz promptly denied liability for reason that his vehicle
was used and driven without his knowledge and consent by Aurelio Tuadles at the time of the
accident.
16. As a result of the death of Romeo Tuadles, his family is in financial difficulties
because they depend on him as a sole wage earner in the family. Hence, they must be made to
pay for damages for the death of Romeo Tuadles, in the amount equivalent to FIVE HUNDRED
THROUSAND PESOS (P 500,000.00).
17. Due to the sudden death of Romeo Tuadles, his wife and children suffered mental
anguish and serious anxiety.
18. Consequently, Plaintiff was constrained to engage the services of counsel to

whom it obligated itself to pay as Attorney's Fees the amount equivalent to TWENTY FIVE
PERCENT (25%) of the total amount to be adjudged in favor of plaintiffs, and the costs of this
suit.
PRAYER
WHEREFORE, the above premises considered, it is respectfully prayed of this

Honorable Court after hearing on the merits, that:
a. Defendants be ordered to pay for damages for death in the amount of FIVE
HUNDRED THROUSAND PESOS.
b. Defendants be ordered to pay moral damages in the amount of FIVE HUNDRED

THOUSAND PESOS (Php 500,000.00);
c. Defendants be ordered to pay attorney’s fees in an amount equivalent to

TWENTY FIVE PERCENT (25%) of the total amount to be adjudged in favor of
plaintiffs;
d. Defendants be ordered to pay the costs of this suit.
Other reliefs just and equitable under the premises are likewise prayed for.
DEED OF SALE
Republic of the Philippines}

Province of Cebu } S. S
DEED OF ABSOLUTE SALE
KNOW ALL MEN BY THESE PRESENTS:
This DEED OF ABSOLUTE SALE is made, executed and entered into by:
GARRY A. POGADOR, single, Filipino, of legal age, with residence and postal-office
address at Pakigne,Minglanilla, hereinafter referred to as the SELLER.
-AND-
JUAN RICARDO TORRES, single, Filipino, of leal age, with residence and postal-
office address at Purok Narra, West Poblacion, City of Naga, Cebu,hereinafter referred to as the
BUYER.
WHEREAS, as the SELLER is the registerd owener of a parcel of land located at Pakigne,
Minglanilla, Cebu and covered by Transfer Certificate of Title No. T-151446 issued by the
Register of Deeds, Province of Cebu, with a total area of SEVENTY SIX (76) SQUARE
METERS more or less and more particularly described as follows;
Transfer Certificate of Title No. T-151446
“A parcel of land (Lot No.19, Block, of the consolidation-subdivision plan,Pcs-072232-

002910, being a portion of the consolidation of Lot 41, Lot 42 and Lot 43, all of Block 1, Psd-
072232-028418), situated in the Barangay of Pakigne , Municipality of Minglanilla, Province of
Cebu, Island of Cebu. Bounded on the NE.,along line 1-2, by lot 20, Block 1, of the
consolidation-subdivision plan; on the NE., along line 2-3 by lot 4607, Talisay-Minglanilla
Estate; on the SW.,along line 4-1 by Main Road (8.00 m.wide). Beginning at a point marked “1”
on the plan, being N.78 deg. 22’W.,234.05 m. from BBm no.17,Talisay-Minglanilla Estate.
Thence N.05 deg. 34’E., 9.49 m to point 2; thence S.84 deg.26’W., 8.00m.to point of
beginning;containing an area of SEVENTY SIX (76) SQUARE METERS more or less.
WHEREAS, the BUYER has offered to buy and the SELLER has agreed to sell the above
mentioned property, including the improvements thereon, for the amount of SEVEN HUNDRED
THOUSAND (P700,000.00) Philippine currency;
WHEREAS, It is hereby mutually agreed that the buyer shall bear all the expenses including but
not limited to the Capital gains tax, transfer tax, documentary taxes and other taxes, fees and charges for
the execution and registration of this deed of sale.
WHEREAS, the SELLER, warrants valid title to and peaceful possession of the property herein
conveyed and further declares that the same is free from all liens and encumbrances of any kind
whatsoever and provisions under Article 1632 of the Civil Code has already been complied with, and
further warrants valid title to and peaceful possession of the property herein conveyed.
NOW THEREFORE, for and in consideration of the sum of SEVEN HUNDRED

THOUSAND PESOS (P700,00.00), hand paid by the buyer to the seller, the SELLER DO HEREBY
SELL, TRANSFER, and CONVEY by way of Absolute Sale unto the said BUYER, their heirs and
assigns, the certain parcel of land together with all the improvements found thereon, free from all liens
and encumbrances of whatever nature including real estate taxes as of the date of this sale.
IN WITNESS WHEREOF, We have hereunto signed this deed of sale this 28 th of May 2003, at
City of Naga, Cebu Philippines
GARRY A. POGADOR
SELLER
JUAN RICARDO TORRES

BUYER
SIGNED IN THE PRESENCE OF:
1. RIZZA JOY ALMIROL 2. REX FRIOLO
ACKNOWLEDGMENT:

BEFORE ME, a Notary Public for and in the City of Naga Cebu, Philippines, personally came
and appeared

GARRY A. POGADOR SSS ID NO. 06-234567-3
JUAN RICARDO TORRES SSS ID NO. 06-6442875-2
This instrument, consisting of TWO (2) pages, including the page on which this acknowledgment
is written, has been signed on the left margin of each and every page thereof by the concerned parties and
their witnesses, and sealed with my notarial seal.
WITNESS MY HAND AND SEAL on this 28th day of May 2003 at the City of Naga, Cebu
Philippines
Atty. GREG GOMEZ

Notary Public
PTR No. 0379919; 01-04-2005; Cebu City.
Doc. No. 473

Page No. 87
Book No. 60
Series of 2003
PRETRIAL BRIEF
7th Judicial Region
Branch 65
City of Naga, Cebu
NATALIA C. SANTOS,
Plaintiff,
-versus- Civil case no.__________

For Accion Reivindicatoria
Quieting of Title
With Prayer for Preliminary
Mandatory Injunction
JUAN RICARDO G. TORRES,
Defendant.
X-------------------------------------------------------x
PRE-TRIAL BRIEF
DEFENDANT, by counsel, respectfully submits the Pre-Trial Brief, as follows:
I. WILLINGNESS TO ENTER INTO AN AMICABLE SETTLEMENT AND

POSSIBLE TERMS OF ANY SUCH SETTLEMENT
1.1 Subject to a concrete proposal that is fair and reasonable and a reciprocal
manifestation of openness from plaintiff, defendant is open to the possiblity of amicably
settling the dispute.
1.2 Pursuant to Rule 18 of the 1997 Rules of Civil Procedure, defendant respectfully
submits that the desired terms of any amicable settlement would involve, first, a clarification
of the real owner of a parcel of land at a residential area in Barangay Pakigne, Minglanilla,
Cebu which is the subject of the action awaiting confirmation as to the genuineness and
authenticity of the Transfer of Title and Deed of Absolute Sale presented by both parties.
II. ADMITTED FACTS
The allegations in paragraph 1 of the complaint as to the personal circumstances of the

plaintiff and paragraph 2
III. BRIEF STATEMENTS OF CLAIMS AND DEFENSES
A.The Plaintiff has NO CAUSE OF ACTION against the defendants as evidenced by the
following facts:
1. The Transfer Certificate of Title attached as “Annex -A” in the complaint lacks
genuineness and authenticity. It is just a certified true copy and did not contain the succeeding 3
pages of the title; the original owner’s duplicate copy is in the hands of the defendant. Hence,
there was no conveyance of legal title and ownership in the name of the plaintiff.
2. The lot is covered by the declaration of real property No. 20-0013-17460 issued by the
Minglanilla Assessor’s office on October 18, 2012, with an assessed value of thrity seven
thousand Five Hundred pesos (37,500.00); certified Xerox copy from duplicate file is attached
in the defendant’s answer and made an integral part as “Annex- E”.
Rule 2 of the Rules of Court defines a cause of action as:
SEC.2 Cause of action, defined- A cause of action is the act or omission by which a party
violates the right of another.
Circumstances considered, there was no right that was violated on the part of the plaintiff to
speak of since the absolute and registered owner is the defendant and not the plaintiff.
B. No cloud of title exists nor is there a need for a quieting of title that affects the lot
mentioned by the Plaintiff in the complaint.
In order that an action for quieting of title may prosper, two requisites must concur: 1.) the
plaintiff or complainant has a legal or equitable title or interest in the real property subject of
the action; and, (2) the deed, claim, encumbrance, or proceeding claimed to be casting cloud on
his title must be shown to be in fact invalid or inoperative despite its prima facie appearance of
validity or legal efficacy.
Defendant most respectfully submits that the complaint hardly qualifies for a quieting of title
because the plaintiff has not established equitable or legal title to the parcel of land in question.
IV. PROPOSED STIPULATION OF FACTS
As provided under Rule 26 of the Rule on Civil Procedure, defendant requests plaintiff to
admit the genuiness and due execution of the following documents within 15 days after service
thereof, otherwise each of the following documents presented by the defendant shall be deemed
admitted:
1. Transfer Certificate of Title No._______
2. Tax Declaration No. 20-0013-7460
V. PROPOSED ISSUES TO BE RESOLVED
Whether or not plaintiff has the legal or equitable title to the parcel of land in question
Whether or not plaintiff has a cause of action for the defendant
VI. TESTIMONIAL EVIDENCE
Defendant intends to present 1 or 2 witnesses to prove that he indeed purchased the land in
question from Gary Pogador as evidenced by the Absolute Deed of Sale indicating the name of
the defendant as the buyer.
VII. AVAILMENT OF MODES OF DISCOVERY
The defendant reserves the right to avail the modes of discovery in addition to the
aforementioned request for stipulation.
VIII . APPLICABLE LAWS AND JURISPRUDENCE
The defendants grounds its answer on the provision of the New Civil Code and 1997 Rules
of Procedure.
IX. RESERVATION
The defendant respectfully reserves the right to present additional and documentary evidence
as may become necessary in the course of the trial.
X. SPECIFIC TRIAL DATES
It is respectfully requested that the trial dates be set during the pre-trial conference to dates
most convenient to this Honorable Court and to all the parties.
RESPECTFULLY SUBMITTED.
City Naga, Cebu, January 26, 2019.
A&A LAW OFFICES

Counsels for the Defendant
Ramos St. Cebu City
262-6612
A&A lawfirm@gmail.com
By:
AIA MARIE COMEDIDO

IBP O.R. NO.3454/12-30-2018/CEBU CITY
PTR O.R.NO.12345/12-30-2018/CEBU CITY
MCLE COMPLIANCE NO.111-12345/December 1,2018
ROLL NO:4565
Copy furnished through personal service:

Atty.Rachel E. Bonita
Atty.Richelle Jane Bayona
Atty.Angela Joann G. Canares
Atty.Jose Neil D. Lumongsod
Counsels for the Plaintiff
Suite 205, Silver Tower Bldg.,
Lahug,Cebu City
MOTION TO WITHDRAW COMPLAINT

MUNICIPAL CIRCUIT TRIAL COURT
OF LILOY AND TAMPILISAN
Liloy, Zamboanga del Norte
-oOo-
MRS. LIDIA A. UY, CIVIL CASE NO. 5OO

Plaintiff,
-versus- for:
PO2 ALEXANDER A. BORA, “COLLECTION OF SUM OF MONEY

Defendant. WITH DAMAGES”
/----------------------------------------------------------------------------------------/
EX-PARTE MOTION TO
WITHDRAW COMPLAINT
COMES NOW plaintiff, by the undersigned counsel, in the above-captioned case, and
unto the Honorable Court, most respectfully alleges in THAT;
1. On July 17, 2OO7, Plaintiff, through counsel, instituted the instant case
against defendant for collection of sum of money;
2. Defendant has not yet submitted an Answer or any responsive pleading in
the above-captioned case;
3. Recently, Defendant approached Plaintiff and thereupon personally offered to
amicably settle the case instead by way of a Compromise Agreement upon which offer Plaintiff readily
agreed;
4. Pursuant to such mutual intention by herein parties to resolve the issue in
this case out of court in order to avoid incurring further unnecessary litigation expenses entailing if the
instant case reaches full-blown trial, and under such equitable terms and conditions that the parties have
duly and mutually reached upon, Plaintiff now desires to drop her case against herein Defendant, hence,
she is now moving for the withdrawal of her Complaint in this case;
5. That Plaintiff is no longer interested in further pursing this case against
Defendant due to the reason above-cited;
6. Finally, this Motion is made in good faith and is never interposed for
whatever illicit intentions or purpose;
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of the Honorable Court
granting the withdrawal of Plaintiff’s Complaint in this case and that by virtue thereof, an order be
correspondingly issued dismissing the instant case without prejudice.
Plaintiff likewise prays for such other reliefs and orders proper and appropriate in the premises.
August 1, 2007, Liloy, Zamboanga del Norte.
Atty. FLORDABBIE T. DAAROL

Counsel for the Plaintiff
PTR NO. 1O4O175 (01-24-O7)
IBP No. 659O9O (01-1O-O7)
Roll No.. 41734
VERIFICATION

Municipality of Liloy ) S.S.
Province of Zamboanga del Norte )
/------------------------------------------------/
I, MRS. LIDIA A. UY, of legal age, married, and a resident of Fatima, Liloy, Zamboanga del
Norte, after being sworn to an oath in accordance with law, hereby depose and state in that:
1. I am the Plaintiff/Movant in the above-captioned case;
2. I have read and personally caused the preparation and submission of the
foregoing motion and that the allegations therein are true and correct of my own personal
knowledge or based on authentic records;
IN WITNESS WHEREOF, I have hereunto set my hand this 2ND day of August, 2OO7 at Liloy,
Zamboanga del Norte, Philippines.
MRS. LIDIA A. UY
Plaintiff
SUBSCRIBED AND SWORN TO before me, this 2nd day of August, 2OO7 at Fatima, Liloy,
Zamboanga del Norte, Philippines by the above-named affiant who is personally known to me, who
signed the foregoing freely and voluntarily, and she declared to me, under penalty of law, that the same is
true and in accordance to the purpose the document contained.
WITNESS MY HAND AND SEAL.
The Clerk of Court

6th MCTC of Liloy-Tampilisan
Greetings!
Kindly submit the foregoing ex-parte motion for the kind consideration and resolution of the
Honorable Court immediately upon receipt hereof without need of further oral argument.
Thank you very much.
Flordabbie T. Daarol
Counsel
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing motion was duly sent and served upon defendant by
way of Registered Mail on August 2, 2OO7 as evidenced by RR No. ____________ of the Liloy Post
Office instead of personal service as the latter could not be possibly done due to extreme geographical
distance between counsel’s address to that of Defendant’s last known address.
Flordabbie T. Daarol
Counsel
COMPROMISE AGREEMENT
7th MUNICIPAL CIRCUIT TRIAL COURT
OF LILOY @ TAMPILISAN
-oOo-
MRS. DOLORES FLORES, CIVIL CASE NO.343

Plaintiff,
-versus- for:
Spouses JONATHAN and “COLLECTION OF SUM OF

PELEGRINA MONTERO, MONEY”
Defendants.
/----------------------------------------------------------------------------------------/
COMPROMISE AGREEMENT
This agreement is freely and voluntarily entered into by and between:
a.) Mrs. DOLORES FLORES, who is of legal age, widow, and a

resident of Causwagan, Liloy, Zamboanga del Norte, hereinafter called
as the Plaintiff, and:
b.) Mr. and Mrs. JONATHAN and PELIGRINA MONTERO, both of
legal age, married to each other, and residents of Causwagan, Liloy,
Zamboanga del Norte, and are collectively called as the Defendants;
That the above-named parties are the litigants in Civil Case No. 512 for Collection of
Sum of Money now pending consideration before the 7th MCTC of Liloy, Zamboanga del Norte;
That the parties have mutually decided to settle their case and end the litigation, and to
reinstate their former harmonious relationship, by the manner following:
1. That both of them freely and mutually fixed the amount of

indebtedness that Defendants would have to pay Plaintiff to the
amount of TWO HUNDRED SEVENTY THOUSAND PESOS
(P270,000.00);
2. That upon the execution of this agreement, the defendants shall pay to
the plaintiffs the amount of NINETY THOUSAND PESOS
(P90,000.00);
3. By the execution and signing by the plaintiff of this compromise
agreement, she then acknowledges the full and complete receipt of the
said initial payment of P90,000.00 from the defendants;
4. That the balance of ONE HUNDRED EIGHTY THOUSAND
PESOS (P180,000.00) shall be paid by the defendants to the plaintiff
on installment basis at the rate of not less than FIVE THOUSAND
PESOS (P5,000.00) PER MONTH payable beginning November,
2009 until the whole remaining obligation is paid and satisfied;
5. That the monthly payments shall be made directly to the plaintiff by
the defendants on or before the last day of every month WITHOUT
NEED OF FURTHER DEMAND;
That the parties, by virtue of hereof, shall jointly ask the court hearing their case to
approve the foregoing agreement;
IN WITNESS WHEREOF, the above-named parties have hereunto set their hands this
th
25 day of August, 2009 at Fatima, Liloy, Zamboanga del Norte.
MRS. DOLORES FLORES MR. JONATHAN MONTERO

Plaintiff Defendant
MRS. PELIGRINA MONTERO

Defendant
With our active assistance:
Atty. FLORDABBIE T. DAAROL Atty. RUELO S. SALADAGA

Plaintiff’s counsel Defendants’ counsel
DEMURRER TO EVIDENCE

JUDICIAL REGION BRANCH
PEOPLE OF THE PHILIPPINES,

Plaintiff,
-versus- Crim. Case No.
JUANA DELA CRUZ,

Accused.
x x
MOTION TO DISMISS BASED ON DEMURRER TO EVIDENCE
ACCUSED, by counsel, unto this Honorable Court, with prior leave of court, most respectfully
moves to dismiss the above-entitled criminal case against accused Juana Dela Cruz, by way of
demurrer, due to insufficiency of the prosecution’s evidence, and respectfully avers:
STATEMENT OF THE CASE AND FACTS
Juana Dela Cruz was indicted for the crime of QUALIFIED THEFT under an
Information, which alleges:
“That on or about the 1st day of July 2002, in Quezon City, Philippines, the said accused, being then
employed as vault keeper of Big Time Pawnshop represented by Alex Pingas y Garcia, located at No. 21-C
Shorthorn St., Brgy. Pinyahan, Quezon City, and as such have free access to the place where the properties are kept
and with grave abuse of confidence reposed to her by her employer, with intent to gain and without the knowledge
and consent of the owner thereof, did then and there willfully, unlawfully and feloniously take, steal and carry away
various jewelry (sic) worth P400,000.00 and cash in the amount of P26,000.00 belonging to Big Time Pawnshop
represented by Alex Pangan y Garcia, to the damage and prejudice of said offended party in the total amount of
P426,000.0, Philippine Currency.
CONTRARY TO LAW.”
During arraignment, accused with the assistance of her counsel de parte in the person of
Atty. Martin Mystica, pled not guilty to the information. Thereafter trial proceedings ensued.
The prosecution sought to prove the guilt of the accused through circumstantial evidence
through the testimonies of its four (4) witnesses, namely: complainant Mr. Alex Pingas, SPO2
Felix Pajaging, PC/Insp. Ruel Declaro, and Estrellita Estemalipala.
ALEX PINGAS, the complainant in this case, substantially testified that accused Juana
Dela Cruz was his employee for more or less ten (10) years in his pawnshop business. Accused
was hired as a teller at Subasta Pawnshop located La Loma, Quezon City. Accused was later
assigned as a vault custodian and appraiser at Big Apple Pawnshop located at 21 Shorthorn
Street, Brgy. Pinyahan,7 Quezon City.
On July 1, 2002, at around 8:15 o’clock in the morning, while he was at the Subasta
Pawnshop, he received a telephone call from Juana Dela Cruz informing him that she just arrived
at Big Time Pawnshop to open the said shop. According to Juana Dela Cruz, his pawnshop was
robbed. He proceeded to the Big Time Pawnshop to see for himself what happened thereat.
There, he examined that vault and noticed that the said vault was not forcibly opened, nor
destroyed. He reported the matter to Police Station 3 at Pinyahan, Quezon City, where SP03
Felix Pajaging went back with him the Big Time Pawnshop to investigate. Operatives from the,
SOCO (Scene of the Crime Operation) also arrived at the Big Time Pawnshop to gather some
fingerprints.
After the SOCO operatives left, he instructed accused Juana Dela Cruz to close the Big
Time Pawnshop, and that both of them are to proceed to Subasta Pawnshop.
He instructed accused Juana Dela Cruz, to continue reporting for work, which Juana
complied, as the latter came to work for the next three days after the robbery incident, after
which, he decided to suspend accused from her work for fifteen (15) days. He reasoned that the
cause of Juana’s suspension from her work was due to the on-going investigation and accused
might overhear his conversation with the investigator on the phone and that Juana was his main
suspect in the robbery.
Juana, however, did not report back to work anymore even after the lapse of her fifteen
(15) days suspension. He strongly suspects accused Juana Dela Cruz to be responsible for the
robbery because of his observation that the vault was opened without having been destroyed. In
support of his speculation, that accused Juana Dela Cruz is his suspect for the robbery, he opined
that in his 15 years in the (pawnshop) business, he has never heard of a case where the vault was
opened by the robbers, without destroying the dial. He added that it was only accused Juana Dela
Cruz who has custody of the keys as
well as the combination.
During cross-examination, complainant Alex Pingas was steadfast in his claim that it was
Juana who committed the crime, thus:
“Q That Juana Dela Cruz was your employee for almost ten years and her employment was cut short by
your decision to dismiss her from your employment, is that correct?
A No, sir.
Q How was she separated from her work?
A We suspended her for fifteen days and she did not come back, sir.
Q And the reason why you suspended her for fifteen days was because of your suspicion that she may
have some connivance with the thieves who entered your pawnshop, is that correct?
A Not only suspicion, I know she is the main suspect in the robbery, sir.”9
xxx xxx xxx
“Q You mentioned during your direct examination that three days after the robbery incident, you
suspended the accused Juana Dela Cruz for fifteen days but you are really suspecting her of being
involved in that robbery?
A Yes, sir.
Q But you have no direct evidence yet that she was directly involved?
A Yes, sir.
Q So you have no basis yet to suspend her from her work considering that you have no evidence yet to
suspect that she had something to do with that robbery?
A No direct evidence but circumstantial evidence, sir.
Q Despite the fact that she has been working for you for ten years, you still suspected her?
A Yes, sir, because the combination was not destroyed.
Q At the time you suspended her from work, did you personally inform her that she was your suspect and
that is why she was being suspended?
A I told her that she was being suspended because a robbery was committed in the shop and she was the
one- in-charge and that the robbery is under investigation.
Q But there were no findings yet by the police or by the SOCO that she was directly linked to that crime,
you suspended her nevertheless, despite the fact that the case is still under investigation?
A I also conducted my own investigation, sir. Q What kind of investigation did you do?
A I checked everything and because she was the only one in the shop during that time.”10
9 TSN, Aug. 18, 2004, pp. 4-5.
xxx xxx xxx
“Q After you told her that she is suspended for fifteen days, she never again reported back to work?
A That is right, sir.
Q And were you even surprised why she never reported back for work after you suspended her, having
suspected her of being involved in that robbery?
A No, sir, because when she did not come back, I presumed that she has done something.
Q Did it occur to you that the reason why she did not report anymore for work was because you might
have hurt her feelings, because you had the temerity of accusing her for having something to do with the
robbery?
A No, sir.
Q It did not occur to you that you might have hurt her feelings?
A No, sir, I received a complaint from the NLRC.
Q So, Juana filed an illegal dismissal case against you? A Yes, sir.”
SPO2 FELIX PAJAGING, the assigned investigator in this case testified that on July 1, 2002 at
around 10:30 o’clock in the morning complainant Alex Pingas arrived at his office at Station 3 and
reported that his pawnshop was robbed. He notified the Crime Laboratory, particularly the SOCO team, to
gather fingerprints at the pawnshop. He went with Mr. Pingas at the Big Time pawnshop and arrived
thereat between 9:00 a.m. and 10:00 a.m.
Upon arrival thereat, he noticed that the padlock of the passage toward the residential apartment
was opened. He identified in court the pictures taken by Mr. Alex Pingas which were shot on July 16,
2002. The SOCO team headed by Pol. Insp. Declaro arrived and gathered finger prints. He likewise
admitted that there were no suspects at the time, thus:
“Q At the time you took the statement of Mr. Pingas in this case, did you have any suspects at that
time?
A At that time sir, I have no suspects at that time but according to complainant Pingas he said that [he]
has a suspect who did the crime and it was Juana Dela Cruz.
xxx xxx xxx
Q What was the basis of Mr. Pingas, the private complainant in this case when he said that he has a
suspect, and this was the accused in this case when you conducted the investigation on July 1, 2002.
A According to Mr. Pingas the person who has an access and at the same time who keeps the key of the
vault is Juana Dela Cruz.”12
xxx xxx xxx
“Q What was your conclusion regarding this incident as reflected in your report?
A After [I] took all the statements of the complainant and witnesses, I had the conclusion, based on the
testimonies of the private complainant and the witnesses, I made a conclusion of a circumstantial
evidence based on the testimony of Florida and Estrellita. And one of the basis is the vault itself, the vault
was opened without any force, so it might be open[ed] by Juana Dela Cruz who knows the combination or
there are other person who
knows the combination.”13
During cross-examination, SPO2 Pajaging admitted that the referral to the prosecutor’s office was
immediately forwarded based only on the suspicions of complainant Alex Pingas that Juana Dela Cruz is
the suspect, despite the fact that the SOCO team has yet to submit its report on the evidence gathered at
the crime scene, thus:
“Q So, Mr. Witness, you would agree with me that the accused was present when you arrived at the
Big Time Pawnshop?
A She was present, sir.
Q She did not try to run away when you and the other persons arrived?
12 TSN, Oct. 6, 2004, pp. 11-12.

13 Ibid., p. 17.
A No, sir.
Q And some operatives arrived? A The SOCO team, sir.

Q Now, what was the result o the investigation of the SOCO?
A Up to the present I don’t have a copy of the result coming from the Crime Laboratory, sir.
Q Are you saying Mr. Witness, that you proceeded with the recommendation of this case for referral to
the Prosecutor’s Office even without waiting for the result of SOCO crime laboratory?
A Only based on my investigation and the testimonies of two witnesses I gathered and the documentary
evidence.
Q As an experienced investigator, did you find it unnecessary to await the SOCO result before referral of
this case to the Prosecutor’s Office against the accused?
A I wasn’t able to wait for the result of the SOCO but the case was already filed with the Prosecutor’s
Office.”14
xxx xxx xxx
“Q Mr. Witness, did Mr. Pingas tell you how he discovered this robbery of his pawnshop?
A Actually, according to him he suspected that Juana Dela Cruz as the one who robbed his pawnshop.
xxx xxx xxx
Q Would you say that as a result of your investigation, there was no suspect at first?
A During the time of my investigation?
Q Yes, you have no suspect in your mind? A Yes, sir.

Q And it was only complainant Pingas who told you that Juana Dela Cruz was his suspect who robbed his
pawnshop, and you considered the case solved?
A Based on his statement, sir.”15
The next witness to testify was PC/ Insp. RUEL DECLARO, the representative from the SOCO. Declaro
testified that on July 1, 2002, he received a telephone call from SPO2 Felix Pajaging and informed him
about a robbery which occurred at the Big Time Pawnshop located at No. 21-C Shorthorn Street,
Barangay Pinyahan, Quezon City. A SOCO team was formed composed of the team leader, fingerprint
technician, photographer, driver and the evidence clerk. They proceeded to the place of the incident and
arrived at 11:45 a.m.
Upon arrival thereat, they determined the whole area of the crime scene, conducted crime interpretation
and started to process the possible evidence gathered. According to Declaro there was no forcible entry.
As far as he knows, the robbers entered and exited through the back door. He presented in court
photographs of the scene. Declaro noted that there was no force applied in opening the vault, because the
lock can still be moved.
Declaro likewise admitted that although latent fingerprints were gathered from the crime scene, the
SOCO office never submitted its report to the investigator or prosecutor’s office, nor did it bothered to
process the results to determine to whom the said fingerprints belonged to. The SOCO team never asked
the accused, and other personnel of Big Time Pawnshop to give samples of their fingerprints for
comparison with the said fingerprints lifted from the crime scene.
Thus, he testified, to wit:
“Q At the time you went to the crime scene, was there already a suspect?
A It was not yet established, sir.
Q You mentioned about the taking of fingerprints, do you have any result of the fingerprints taken
from the crime scene?
A Since there was no suspect at that time, we have not arrived to any examination, sir.
Q There was no examination on the fingerprints lifted from the crime scene?
A Yes, sir.”16
On cross-examination, Vacaro testified:
“Q When did you submit your report to Pajaging? A We did not submit that report, sir.
Q So this was never received by Pajaging, the investigator? A No, sir.
Q In fact, this is the first time that you produced this report, it was never submitted in the Prosecutor’s
Office neither to Pajaging?
A We prepared it on the indicated date, sir.
Q My question was, you did not submit this to Pajaging, the investigator in this case, and neither was this
submitted to the Prosecutor’s Office?
A No, sir.
Q This is the first time you are bringing this document? A Yes, sir.
xxx xxx xxx
Q Mr. witness, you mentioned that your investigation turned up zero, there was no suspect in this case
per your SOCO investigation?
A We gathered latent prints, subject to examination but the particular person as to whom these belong or
the suspect is based on the follow-up investigation conducted by the office on case. We told them we
gathered latent prints that remain in our office for future reference.
Q Until now, there is no result as to whom those prints belong?
A No result yet, sir.
Q You have no record whatsoever as to whom those prints belong?
A No record, sir.
Q Up to this time you have not processed anything about those prints?
A Not yet, sir. They remain in our office.
Q Is it not that the reason why you did not submit this to Pajaging, not even to the Prosecutor’s Office,
was because there is no suspect?
A During the preparation of the report, the suspect was not yet established, sir.
COURT
What is your reason in not submitting that report to the investigator or the prosecutor’s office?
A We cannot arrive at the final report because there was no person taken for fingerprinting, your
honor.
COURT
Is that SOP in your office?
A In our office, your honor, the questioned latent prints remain in our office for future reference.
COURT
Is that your SOP, non-submission of your report to the Fiscal’s Office or office of the investigator?
A Yes, your honor. C O U R T

Continue PUBLIC ATTORNEY:
Mr. Witness, did anyone tell you, whether the complainant or investigator handling this case, that there is
already a suspect?
A We received subpoena on February 17 and then we received another subpoena directing me to report in
this office to testify, I had no idea if there is a suspect, sir.
Q So, therefore, SOCO office never bothered to get the fingerprints of the accused to compare with the
latent fingerprints you lifted from the crime scene?
A No, sir.”
The last witness to testify was Estrellita Estemalipala, an employee of complainant Alex Pingas. The gist
of her testimony was that she resigned from her work at Subasta Pawnshop as she planned to work
overseas. She turned over to accused Juana Dela Cruz all the keys to the pawnshop after she resigned.
However, her plan did not materialize, thus she was re-employed by Alex Pingas as a cashier at Subasta
Pawnshop. On July 16, 2002, while at the Subasta Pawnhop, she saw her employer Alex Pingas placed
the bunch of keys on top of a table. She noticed that the padlocks from the Big Time Pawnshop and some
keys were missing. She called the attention of Mr. Pingas to the fact of said missing keys. Thereafter, Mr.
Pingas accompanied her to the police station to report the loss of the
missing keys.
DISCUSSION
The prosecution miserably failed to prove the supposed unbroken chain of circumstantial
evidence that accused Juana Dela Cruz committed the crime of Qualified Theft.
The prosecution was emphasizing the fact that the vault of complainant’s pawnshop was
opened by the robbers without destroying the said vault. However, the prosecution presented as
one of its exhibits (Exh. “E”) a photograph showing the destroyed portion of the grill above the
door, supposedly where the robbers passed through. Noteworthy that if accused Juana Dela Cruz
would be the one who committed the theft at the said pawnshop, it would be absurd for her to go
through all the trouble of destroying the grills above the pawnshop door, despite having
possession of all the keys to the said pawnshop.
It should be remembered at the outset, the circumstantial evidence consists only of speculations
and probabilities that accused was responsible for the theft/robbery that occurred at Big Apple
Pawnshop.
Noteworthy that prosecution witness PC/Insp. Ruel Declaro, a member of the
responding SOCO team, admitted in court that the latent fingerprints that he lifted was not even
processed for identification to either confirm or establish that the same indeed belonged to
accused Juana Dela Cruz, OR whether said latent fingerprints belonged to persons other that the
accused. The identification of the said latent fingerprints would have ruled out any participation
of accused in the robbery if it were proven that it belonged to other persons, not necessarily
accused Juana Dela Cruz.
As in all criminal cases, speculation and probabilities cannot take the place of proof required to
establish guilt beyond reasonable doubt.
Evidence showing a mere possibility of guilt, no matter how strong, is

insufficient to warrant a conviction.
In the appreciation of evidence in criminal cases, it is a basic tenet that the prosecution
has the burden of persuasion in establishing the guilt of the accused for the offense he is charged
–ei incumbit probation non qui negat. The conviction of the accused must rest not on the
weakness of his defense but on the strength of the prosecution’s evidence.21 It failed to do so in
this case.
Otherwise, we will see the absurdity of an accused being put in a more difficult position
where the prosecution’s evidence is vague and weak than where it is strong.22
The presumption of innocence is founded upon the basic principles of justice and is a substantial
part of the law, it cannot be overcome by mere suspicion or conjecture.23 Under our criminal
justice system, the overriding consideration is not whether the court doubts the innocence of the
accused but whether it entertains a reasonable doubt as to his guilt. This applies with more vigor
in the case at bar where the evidence of the prosecution is purely circumstantial. A judgment of
conviction must rest on nothing less than moral certainty.25
In summation, the defense respectfully submits that the pieces of circumstantial evidence
are insufficient to prove the guilt beyond reasonable doubt of accused Juana Dela Cruz for the
crime of Qualified Theft. They do not pass the requisite moral certainty, as they admit of the
alternative inference that other persons, not necessarily the accused, may have perpetrated the
crime. Where the evidence admits of two interpretations, one of which is consistent with guilt,
and the other with innocence, the accused must be acquitted. Indeed, it would be better to set free
ten (10) men who might be probably guilty of the crime
charged than to convict one innocent man for a crime he did not commit.
PRAY E R
WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court that
the Information for Qualified Theft against accused Juana Dela Cruz be DISMISSED for
insufficiency of evidence.
Quezon City, November 03, 2005.
Department of Justice
PUBLIC ATTORNEY’S OFFICE
DOJ Agencies Building,
NIA Road corner East Avenue,
Diliman, Quezon City
By:
Public Attorney_
Roll No. IBP No.
MCLE Compliance No. Date:
NOTICE OF HEARING
The Branch Clerk of Court This Court
Prosecutor’s Office
City/Municipality Greetings:
Please take notice that the Public Attorney’s Office is submitting the foregoing
motion for the consideration and resolution of the Honorable Court on at 2:00 o’clock in the
morning.
ATTY.
Copy furnished:
Hon. City Prosecutor Prosecutor’s Office

ANSWER WITH COMPULSORY COUNTERCLAIM

7th JUDICIAL REGION
BRANCH 65
City of Naga, Cebu
NATALIA C. SANTOS,
Plaintiff,
-versus-
Civil Case No.___________
For Accion Reivindicatoria,
Quieting of Title and Damages
With Prayer for Preliminary
Mandatory Injunction
JUAN RICARDO G. TORRES,

Defendant.
x--------------------------x
ANSWER
(with Counterclaim)
COMES NOW the Defendant JUAN RICARDO G. TORRES,

represented by the undersigned counsels, before the Honorable Court, most
respectfully submits this Answer with counterclaim, averring that:
ADMISSIONS AND DENIALS

1. The allegations in paragraph 1 of the complaint as to the personal
circumstances of the plaintiff is admitted;
2. Paragraph 2 is admitted;
3. Paragraphs 3, 3.1, 3.2, 3.3, 3.4 are denied. As regards the ownership of the
Plaintiff of the subject parcel of land situated at a residential area in
Barangay Pakigne, Minglanilla, Cebu, the Transfer Certificate of Title
attached as Annex A in the complaint is specifically denied for want of
genuineness and authenticity. The Transfer Certificate Title is just a certified
true copy and did not contain the succeeding 3 pages of the title, the original
owner’s duplicate copy of such is in the possession of the defendant;
4. Paragraph 3.2 as regards to the Deed of Absolute Sale attached as Annex B

to B-1 in the complaint is specifically denied for being spurious the truth
being stated in the affirmative and special defenses hereunder;
Paragraph 3.3 is denied for lack of information or knowledge sufficient to

form a reasonable belief thereof;
Paragraph 3.4 with regard to the Tax Declaration marked as Annex D in the
complaint is specifically denied for want of genuineness and authenticity, the
assessed value in numerical form is inconsistent with the amount appearing
in words, it is provided that the assessed value is P 37,500.00 but the
assessed value in words as stated in the document is Eighteen Thousand
Eight Hundred Fifty Pesos Only;
5. Paragraph 4 is denied for lack of information or knowledge sufficient to

6. Paragraph 5 is denied as to the allegation that defendant intruded in the lot,

the truth being stated in the affirmative and special defenses hereunder;
7. Paragraph 6 is denied, defendant did not receive any verbal demand from the
Plaintiff;
8. The allegation of the plaintiff in paragraph 7 is likewise denied. Contrary to
the assertion of the plaintiff, the defendant did not receive any demand letter
to vacate the premises. As to the signature appearing on the Registry Return
Receipt in Annex G of the complaint specifically denied under oath for it
appears to be a forged signature of the defendant, copy of the defendant’s
Passport is herein attached as Annex “A” and the signature as Annex “A-1”
and Driver’s License as Annex “B” and the signature as Annex “B-1” to
prove the correct and authentic signature of the defendant;
9. Paragraph 8 is denied for lack of information or knowledge sufficient to

10.The allegation on Paragraph 8.1 as to the alleged statement of the defendant

that, “ he would not vacate the lot contending they bought the same for value
from a certain Katrina Ante sometime in 2016” is specifically denied. The
defendant never made such statement; it was not even mentioned in the
minutes provided by the plaintiff in their complaint in Annex I;
11.Paragraph 8.2 is denied for lack of information and knowledge sufficient to

form reasonable belief thereof ( the plaintiff failed to attached the said
certification in the complaint);
12.Save for the legal provisions quoted in paragraph 9,9.1,9.2,9.3, the rest of
the allegations are denied, the truth being that stated in the affirmative and
special defenses hereunder;
13.Save for the legal provisions quoted in paragraph 10, 10.1,10.2, the rest of
the allegations are denied, the truth being that stated in the affirmative and
special defenses hereunder;
14.Save for the legal provisions quoted in paragraph 11,12,13,14, the rest are
denied, the truth being that stated in the affirmative and special defenses
hereunder. As regards the receipt attached as Annex J in the complaint, it is
specifically denied for want of genuineness and authenticity for it is not even
the official receipt of the concern Barangay;
15.The allegations in paragraph 15,16,17,18 are denied as the same is an
erroneous conclusion made by the plaintiff;
16.The foregoing are subject to the special and affirmative defenses hereunder
presented.
SPECIAL AND AFFIRMATIVE DEFENSES
17. The Plaintiff has NO CAUSE OF ACTION against the defendants;
Rule 2 of the Rules of Court defines a cause of action as:

Sec.2.Cause of action, defined- A cause of action is the act or
omission by which a party violates of another.
The essential elements of a cause of action are (1) a right in
favor of the plaintiff by whatever means and under whatever law it
arises or is created; (2) an obligation on the part of the named
defendant to respect or not to violate such right; and (3) an act or
omission on the part of such defendant in violation of the right of the
plaintiff or constituting a breach of the obligation of the defendant to
the plaintiff for which the latter may maintain an action for recovery
of damages or other appropriate relief.
The Defendant is the absolute and registered owner of the Seventy-Six (76)
Square meter lot situated at a residential area in Barangay Pakigne,
Minglanilla,Cebu. The said lot was purchased by the Defendant from Garry A.
Pogador on May 28,2003; an original copy of the Deed of Absolute attached
herewith and made an integral part hereof as ANNEX “C” to ANNEX “C-1”.The
title to the said lot was transferred to the name on the defendant on June 7, 2003; a
copy of the original owner’s duplicate copy is attached herewith and made an
integral part hereof as ANNEX “D” to ANNEX “D-1”.
The lot is covered by Tax Declaration of Real Property No. 20-0013-17460

issued by the Minglanilla Assessor’s Office on October 18, 2012, with an assessed
value of Thirty Seven Thousand Five Hundred Pesos (P37,500.00); certified Xerox
copy from duplicate file is attached herewith and made an integral part hereof as
“ANNEX E”.
Therefore there was no right that was violated on the part of the plaintiff to
speak of since the absolute and registered owner is the defendant and not the
plaintiff.
18.No cloud of Title exists nor is there a need for a quieting of title that
affects the lot mentioned by the Plaintiff in the Complaint.
In order that an action for quieting of title may prosper, two requisites
must concur: (1) the plaintiff or complainant has a legal or equitable
title or interest in the real property subject of the action; and (2) the
deed, claim, encumbrance, or proceeding claimed to be casting cloud
on his title must be shown to be in fact invalid or inoperative despite
is prima facie appearance of validity or legal efficacy.
Defendant most respectfully submits that the Complaint hardly qualifies for
a quieting of title because they have not established equitable or legal title to the
parcel of land in question.
COUNTERCLAIMS
In the rare event that the Honorable Court shall resolve to proceed with the
trial of the case despite the above special and affirmative defenses, the
Defendant submit the following compulsory counterclaims and for this
purpose, hereby restate and repleads all the allegations in the preceding
paragraphs by way of reference and incorporation:
1. Due to the plaintiff’s willful and patent disregard of the defendants’

rights, the defendant suffered inconvenience, embarrassment and
humiliation thereby causing them mental anguish, serious anxiety,
wounded feelings and social humiliation, resulting in moral damages for
which the plaintiff should be held liable in the amount of One Hundred
Fifty Thousand Pesos (P150,000.00), Philippine currency;
2. To deter others from following after the plaintiffs wanton acts and
evident bad faith, she should be held liable to pay the plaintiff exemplary
damages in the amount of Fifty Thousand Pesos (P50,000.00), Philippine
currency, by way of example or correction for the public good;
PRAYER
WHEREFORE, PREMISES CONSIDERED, it is most respectfully

prayed that-
1. The Special and Affirmative shall be immediately set for preliminary
hearing;
2. After the said preliminary hearing, to issue an Order dismissing the
plaintiff’s complaint for Accion Reivindicatoria, Quieting of Title and
Damages and for the issuance of a Writ of Preliminary Mandatory
Injunction;
3. In the remote event that the Honorable Court shall proceed with the trial,
the defendant pray for a judgment denying the reliefs prayed for by the
plaintiff for lack of merit;
4. On the compulsory counterclaims – to order the plaintiff to pay the
defendants-
a. Moral damages in the amount of One Hundred Fifty Pesos
(P150,000.00),Philippine currency;
b. Exemplary damages in the amount of Fifty Thousand
Pesos(P50,000.00), Philippine currency;
c. Attorney’s fee in the amount of Five Hundred Thousand Pesos
(P500,000.00),Philippine currency;
d. Appearance fee of Two Thousand Pesos (P2,000.00) Philippine
currency, per court appearance;
e. Other litigation expenses as may be proved during trial.
Other reliefs just and equitable under the premises are likewise prayed
for.
City Naga, Cebu, December 15,2018.
A&A LAW OFFICES

Counsels for the Defendant
Ramos St. Cebu City
262-6612
@gmail.com
By:
AIA MARIE COMEDIDO

IBP O.R. NO.3454/12-30-2018/CEBU CITY
PTR O.R.NO.12345/12-30-2018/CEBU CITY
MCLE COMPLIANCE NO.111-12345/December 1,2018
ROLL NO:4565
VERIFICATION
I, JUAN RICARDO G. TORRES, Filipino, single, legal age and is curretly

residing at Purok Narra, West Poblacion, City of Naga, Cebu,Philippines, underoath, depose and
say that:
1. I am the defendant in the above-entitled case;
2. I caused the preparations of the foregoing Answer with Counterclaims’
3. I read all the allegations thereof and that the same are true and correct based on my own
knowledge and authentic records;
4. That Defendant specifically denies under oath the genuineness and due execution of the
instrument a copy of which is attached to Plaintiff’s complaint as Annex “G”, the truth
being that his signature thereon is forged and that he did not in fact sign the said
instrument.
IN TRUTH WHEREOF, I have hereunto affixed my signature below this 13 th day of
December 2018, at Province of Naga, Cebu.
JUAN RICARDO TORRES

Affiant
Passport No.P61197641 Valid until February 20,2028
Doc. No. 347
Page No. 91
Book No: 65
Series of 2018
ERIKA JUDI LOMOCSO

Notary Public
MCLE Compliance No.V-92342445,Cebu City,December 4,2018
Roll.no. 656452
Copy furnished through personal service:
Atty.Rachel E. Bonita
Atty.Richelle Jane Bayona
Atty.Angela Joann G. Canares
Atty.Jose Neil D. Lumongsod
Counsels for the Plaintiff
Suite 205, Silver Tower Bldg.,
Lahug,Cebu City
THE BRANCH CLERK OF COURT

RTC BRANCH 65-CITY OF NAGA
Please submit the foregoing for the consideration and approval immediately
upon receipt hereof sans argument and appearance of counsel. Thank you very
much.
Aia Marie Comedido

Counsel for Defendant
Ramos St. Cebu City
PETITION FOR CORRECTION OF ENTRIES IN THE CERTIFICATE OF LIVE BIRTH

Branch 28
IN THE MATTER OF THE PETITION FOR SPL. CIVIL CASE #_____

CORRECTION OF ENTRIES IN THE
CERTIFICATE OF LIVE BIRTH OF MARGIE
DAGAYLO-AN HAMITO,
WENIFREDA DAGAYLOAN JAMITO

Petitioner
-versus-
THE LOCAL CIVIL REGISTRAR OF

LILOY, ZAMBOANGA DEL NORTE,
Respondent
/----------------------------------------------------------------------------------------/
PETITI O N
COMES NOW the petitioner, by the undersigned counsel, in the above-captioned case, and
unto the Honorable Court, most respectfully alleges in that;
1. Petitioner is of legal age, married to JERSON JAMITO, and a resident of
Fatima, Liloy, Zamboanga. On the other hand, Respondent is a government agency which has an address
at Liloy, Zamboanga del Norte and to where it can be served with the notices and legal processes of the
Honorable Court;
2. Petitioner is the biological mother of one MARGIE DAGAYLOAN JAMITO who
was born on November 9, 1972 in Goin, Liloy, Zamboanga del Norte. That the facts surrounding the birth
of the said MARGIE DAGAYLOAN JAMITO were duly reported and registered with the respondent’s
office as evidenced by her Certificate of Live Birth issued by the respondent, a machine copy of which is
annexed as part hereof and marked as Annex “A”;
3. Just as Margie was preparing all of her papers and other documents for
purposes of employment overseas, she discovered that her Certificate of Live birth contained erroneous
entries, all of which, if left uncorrected, would effectively cast doubt and confusion as to her real person
and identity, viz;
a. Therein, and as appearing in Entry no. 3 of Annex “A”, Margie’s middle name was
incorrectly spelled to DAGAYLO-AN when the same should had been spelled as
DAGAYLOAN;
b. Likewise, Margie’s family name was incorrectly spelled to HAMITO when it should
had been correctly spelled as JAMITO;

c. The spelling of the surname of Margie’s father, JERSON, as shown under Entry No.
8 of Annex “A” was also incorrectly spelled to HAMITO when it should had been
JAMITO as stated above;
d. Finally, Petitioner’s name, in her capacity as the mother of Margie, was likewise
erroneously entered into as WENEFREDA DAGAYLO-AN when the same should
had been inscribed thereat as WENIFREDA DAGAYLOAN;
4. In support of all of the above-contentions, Petitioner is attaching herewith
the following documents, to wit:
a. Petitioner’s Certificate of Marriage with her husband, JERSON JAMITO, issued by
the Respondent and herein marked as Annex “B”;
b. The Certification coming from the Office of the Municipal Mayor of Liloy,
Zamboanga del Norte marked as Annex “C”;
c. Petitioner’s Voter’s Registration Records issued by the COMELEC which is marked
as Annex “D”; and
d. The Voter’s Registration Records of Petitioner’s husband, JERSON JAMITO, issued
by the COMELEC which is marked as Annex “E”;
5. All told, it therefore now becomes fitting and proper that the aforesaid
erroneous entries appearing in the Certificate of Live Birth of Petitioner’s daughter be corrected in order
to eliminate the doubts and confusions on the personality and identity of Petitioner’s daughter brought by
the same, thus, this Petition;
PRAYER
WHEREFORE, premises considered, it is hereby most respectfully prayed of the Honorable
Court that an order be issued directing respondent, the Local Civil Registrar of Liloy, Zamboanga del
Norte, to correct the erroneous entries appearing in the Certificate of Live Birth of Petitioner’s daughter,
Margie, by:
a. Making Margie’s middlename to DAGAYLOAN from DAGAYLO-AN;
b. Making her surname to JAMITO from HAMITO;
c. Making the surname of Petitioner’s husband to JAMITO from HAMITO;
d. Making Petitioner’s first name as WENIFREDA instead of WENEFREDA; and
e. Making Petitioner’s maiden name as DAGAYLOAN instead of DAGAYLO-AN;
Petitioner likewise prays for such other reliefs and orders proper and appropriate in the premises.
Fatima, Liloy, Zamboanga del Norte, September 26 , 2005.

Atty. FLORDABBIE T. DAAROL
PTR NO. 2159784 (04-19-05)
IBP NO. 605195 (01-04-05)
ROLL NO. 41734

Municipality of Liloy ) S.S.
/----------------------------------------/
I, WENIFREDA D. JAMITO, of legal age, married, and a resident of Fatima, Liloy, Zamboanga
del Norte, after being sworn to an oath in accordance with law, hereby depose and state in that:
1. I am the Petitioner in the above-captioned case;

2. I have read the foregoing and that the allegations therein are true and
correct of my own knowledge and belief;
3. I further certify that I have not commenced any action or filed any
claim involving the same issues in any court, tribunal, or quasi-judicial agency and, to the best of my own
knowledge, no such other action or claim is pending therein;
4. If there is such other pending action or claim, a complete statement of
the present status thereof; or If I should thereafter learn that the same or similar action or claim has been
filed or is pending, I shall report that fact within five (5) days from knowledge thereof to the Honorable
Court wherein this Complaint is filed or is pending;
WENIFREDA D. JAMITO
Petitioner
CTC# 20456698
issued on 01-10-05
at Liloy, Zamboanga del Norte
SUBSCRIBED AND SWORN TO before me, this 26th day of September, 2005 at Fatima,
Liloy, Zamboanga del Norte, Philippines.
AFFIDAVIT OF CONSOLIDATION OF OWNERSHIP
AFFIDAVIT OF CONSOLIDATION OF OWNERSHIP

I, SASHA GREY, of legal age, Filipino, single and a resident of Blk 55, Lot 66,
Ibarra Homes, Tulingan, Cavite, after having been duly sworn to in accordance with law,
depose and state:
That in the public auction conducted by the City Sheriff of Makati City on September 3,
2012 pursuant to the provisions of Act No. 3135 as amended, the undersigned affiant
became the purchaser of a certain foreclosed property with all its improvements, more
particularly described as follows:
TCT No. T-2222
A PARCEL OF LAND (Lot 32 of the consolidation-subdivision plan (LRC)

Pcs-5141, being a portion of the consolidation of Lots 1 and 2, Psu-
112287 Amd., LRC (GLRO) Rec. No. N-17511), situated in the Dist. Of
Concepcion, City of Sta. Rosa, Laguna, Island of Luzon. Bounded on the
NE., points 3 to 6, by Lot 85; on the S., points 6 to 1 by Lot 30; on the SW.,
points 1 to 2, by Lot 31; and on the N., points 2 to 3 by Lot 35, all of the
consolidation-subdivision plan. Beginning at a pont marked "1" on plan,
being N. 51 deg. 36' E., 1321.76 m. from B.L.L.M. No.1, Sta. Rosa,
Laguna
That the said Sheriff sold the above-described property with all the improvements and
buildings thereon to the undersigned affiant as the highest bidder for the sum of ONE
MILLION PESOS (P1,000,000.00), Philippine Currency;
That That a Certificate of Sale at Public Auction was issued by the said Sheriff in favor of
the undersigned affiant and the same was duly registered with the Office of the Registry
of Deeds of Makati City on September 14, 2012 as Entry No. 123 on the aforementioned
title;
That a Certificate of Sale at Public Auction was issued by the said Sheriff in favor of the
undersigned affiant is proper and in accordance with law.
WHEREFORE, by failure of the Mortgagor to redeem the said property, I am

executing this Affidavit for the purpose of consolidating title and ownership of the above-
described property with all the improvements and buildings thereon, as provided for by
law, and I am requesting the Office of the Registry of Deeds to register the same and
issue a new title in the name of the undersigned affiant.
IN WITNESS WHEREOF, I have hereunto set my hand this 27 th day of January 2014,
in Imus City, Cavite, Philippines.
SASHA GREY
Affiant
SUBCRIBED AND SWORN TO before me this 27th day of January 2014, in Imus City,
Cavite, Philippines, affiant exhibiting to me her Philippine Passport No. 123456 issued in
Manila on January 12, 2014 and valid until January 12, 2017.
Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2014.
DEED OF REPURCHASE OF LAND SOLD UNDER PACTO DE RETRO

DEED OF RESALE
I, (full name of vendor) Filipino, of legal age, (single or married to

________________), with residence and post-office address at
____________________; for and in consideration of the sum of _______________________
PESOS (P_________), Philippine currency, to me in hand paid by
(full name of vendee),
Filipino, of legal age, (single or married to ________________), with residence and post-office
address at ____________________ do hereby by these presents RESELL, RETRANSFER, AND
RECONVEY unto the said
_______________________ that certain parcel of land, with all the buildings and improvements
thereon, situated in ____________________________ and more particularly described as
follows, to wit:
(Description of land as stated in original contract of sale with pacto de retro) covered by Transfer
(or Original) Certificate of Title No. ______ of the Registry of Deeds of ________________, and
which property was previously sold to me under pacto de retro by the said _________ on
_________________, executed before Notary Public _____________, and bearing No. Reg. No.
_____, Page ______, Book ________, Series of _______ of his notarial register, copy of which is
hereto attached as ANNEX “A”.
IN WITNESS WHEREOF, I have hereunto set my hand this day of ____________ , 20

____ , in _________________, Philippines.
__________________
(Vendor)
With my consent:
_______________________
(Vendor’s wife, if any)
Signed in the presence of:
_____________________ _____________________
ACKNOWLEDGMENT:

BEFORE ME, a Notary Public for and in the City of Naga Cebu, Philippines, personally came
and appeared
This instrument, consisting of TWO (2) pages, including the page on which this acknowledgment
is written, has been signed on the left margin of each and every page thereof by the concerned parties and
their witnesses, and sealed with my notarial seal.
WITNESS MY HAND AND SEAL on this 28th day of May 2003 at the City of Naga, Cebu
Philippines
Atty. GREG GOMEZ

Notary Public
PTR No. 0379919; 01-04-2005; Cebu City.
Doc. No. 473

Page No. 87
Book No. 60
Series of 2003
MOTION FOR BILL OF PARTICULARS

Branch 9
Puerto Princesa City, Palawan
ALEX BERMEJ
Plantiff, Civil Case No.323232
-versus- For: Damages
ROEL PONCE DE LEON

Defendant
MOTION FOR BILL OF PARTICULARS
Defendant, by counsel and to this Honorable Court, respectfully

states:
The complaint alleges that defendant public official, together with herein defendant movant,
acting singly or collectively, and or in unlawful concert with one another, in flagrante
breach of public trust and of sheer fiduciary obligations as public officers with gross and
scandalous abuse of right and power and in brazen violation of the Constitution and laws
of the Philippines, embarked upon a systematic plan to accumulate ill-gotten wealth.
The foregoing allegations are conclusions of law, which plaintiff should clarify and flesh
them with facts and specific acts to enable defendant-movant to prepare and file a
responsive answer thereto which requires information as to precise nature, character,
scope and extent of plaintiff’s cause of action.
WHEREFORE, defendant prays that plaintiff be ordered to file a bill of particulars of the
facts and acts constituting the conclusions alleged in the complaint.
ATTY. PERCIVAL JAMES L.

LACEBAL
Counsel for the Defendant
NOTICE OF HEARING
Atty. Juan S. Magbanua

Counsel for the defendant
Bgy. San Pedro, Puerto Princesa City
Sir:
Please be informed that the undersigned counsel has set the foregoing Motion for Reconsideration for
hearing on November 25, 2013 at 8:30 am, for the consideration of the Honorable Court or soon
thereafter as counsel maybe heard.
ATTY. PERCIVAL JAMES L.

LACEBAL
Bgy. Sta. Monica. Puerto Princesa
City
AFFIDAVIT OF PERSONAL SERVICE
I, RUBEN R. PADILLA, of legal age and having been duly sworn depose and say:
That I am the messenger of Atty. Arnel B. Venturillo, Counsel for the defendant in the
case entitled Alexander Bermejo vs. Roel Ponce de Leon, Civil Case No. 65448, and that such
messenger I served upon the counsel of adverse party and other parties, the Motion for
Consideration filed in said case, as follows:
Atty. Bernardo U. Goy, counsel for the Plaintiff, by personal service by delivering
personally copy of said Motion upon said lawyer who acknowledged receipt there of as shown by
his signature or initial on the said pleading, this 23rd day of October 2013
IN WITNESS WHEREOF, I have signed this affidavit this 24 th day of October 2013 at
Puerto Princesa City.
Ruben R. Padilla
Affiant
SUBSCRIBED AND SWORN TO BEFORE ME, A Notary public in and for the City of Puerto
Princesa and the Province of Palawan this 24th day of October 2013. Affiant personally came and
appeared with Driver’s License ID No. issued by the Land Transportation Office and valid until May
1, 2015, at Puerto Princesa City, bearing his photograph and signature, known to me as the same
person who personally signed the foregoing instrument before me and avowed under penalty of law
to the whole truth of the contents of said instrument
ATTY. PERCIVAL JAMES L. LACEBAL

Notary Public
Doc. No. ______;

Page No. ______;
Book No. ______;
Series of 2013;
Copy furnished:
Atty. Marilen Saniel

Counsel for plaintiff
Bgy. San Pedro, PPcity
MOTION TO CANCEL LIS PENDENS

Branch 9
Puerto Princesa City, Palawan
ALEX BERMEJ
Plantiff, Civil Case No.323232
-versus- For:
ROEL PONCE DE LEON

Defendant
MOTION TO CANCEL LIS PENDENS
Plaintiff, by counsel and to this Honorable Court, respectfully states:
Defendant caused the annotation or registration of a notice of lis pendens on the subject matter of
the instant suit,
2. Defendant caused the recording of the lis pendens for the purpose of molesting plaintiff, and
the recordal thereof is not necessary to protect his rights to the property, his right thereto, if any, is
only indirect and contingent.
The recordal of the lis pendens is prejudicial to plaintiff’s interest to the property because, being
the owner of said property, it is burden and it restricts its transferability by sale, as no one will
buy it during the pendency of the case and for as long as the lis pendens is not canceled.
RELIEF
WHEREFORE, plaintiff respectfully prays that the notice of lis pendens be ordered cancelled.
Other just and equitable reliefs are likewise prayed for.
City of Puerto Princesa, December 2, 2013
ATTY. FELY Q. BALADAD

Counsel for the plaintiff
Brgy. San Pedro, Puerto Princesa City
Roll No. 75648
IBP No. 0457 - Palawan,
PTR No. 11456788, issued on April 13, 2012,
MCLE Compliance Cert. No. 66587
NOTICE OF HEARING
Atty. Juan S. Magbanua

Counsel for the defendant
Bgy. San Pedro, Puerto Princesa City
Sir:
Please be informed that the undersigned counsel has set the foregoing Motion for
Reconsideration for hearing on November 25, 2013 at 8:30 am, for the consideration of the
Honorable Court or soon thereafter as counsel maybe heard.
ATTY. FELY Q. BALADAD

Bgy. Sta. Monica. Puerto Princesa City
MOTION WITH LEAVE TO INTERVENE AND TO ADMIT ATTACHED

COMPLAINT- IN- INTERVENTION

SUPREME COURT
Manila
WHITE LIGHT CORPORATION

Plaintiff, G.R.DOCKET NO.868-SC-922-VI
-versus- For: Petition for Declaratory Relief
CITY OF MANILA, represented by,

MAYOR ALFREDO LIM
Defendant
x---------------------------------------------x
MOTION WITH LEAVE TO INTERVENE AND TO ADMIT

ATTACHED COMPLAINT- IN- INTERVENTION
Movant-Intervenors, by counsel, to this Honorable Court respectfully states:
This is a Complaint for Declaratory Relief with Prayer for a Writ of Preliminary Injunction and/or
Temporary Restraining Order filed on January2, 2014, to declare Ordinance 7774 prohibiting the
admission of customers on a short- time basis or for a short- time rate invalid and
unconstitutional.
Herein movants are operators and proprietors of various business establishments in the City of
Manila whose main customers are local tourists and people from far- flung areas in the country
having their vacation in the Metro.
That the passage of the aforesaid Ordinance will adversely affect herein movant’s lawful
occupation and businesses, due to the fact that the establishments they operate are tourist- and
people- fueled, and the passage of the Ordinance in controversy may affect the patronage of the
movant’s customers.
The passage of the aforesaid Ordinance 7774 will adversely affect the business operation
and occupation of movants, to their detriment and prejudice.
WHEREFORE, it is respectfully prayed that an order be rendered admitting herein Movants as

Intervenors in the above- entitled case.
Imus City for City of Manila, 7 January 2014.
LOMIBAO LAW OFFICE

406 Violago Homes, Litex, Quezon City
Tel. No. 0917- 8032- 788
Email Add.: LLawOffice@yahoo.com
by:
RICA KAYE O. LOMIBAO

IBP No. 119739 CAVITE CHAPTER
PTR No. 3181314, Imus City, 1-11-12
Attorney’s Roll No. 58500
MCLE Compliance No. VI-1111201
Notice
HONORABLE SUPREME COURT

City of Manila
Greetings:
Please submit the foregoing motion for the consideration and approval of the
Honorable Court immediately upon receipt hereof.
MOTION WITH NOTICE TO TAKE DEPOSITION

BRANCH 113
Pasay City
RAPHAEL ENRIQUE V. CORONADO,

Petitioner,
-versus-
CIVIL CASE NO. C-QTZ-24-25285-D
For: Declaration of Nullity of
Marriage
ELLEN A. ADARNA,
Respondent
x------------------------------------------x
MOTION WITH NOTICE TO TAKE DEPOSITION
PETITIONER, by counsel, to this Honorable Court respectfully

alleges:
That petitioner would be coming home solely to testify in this case on November 24 to
26, 2013.
The petitioner deems it imperative that he report for work after the last week of November
2013, as his absence from work might disrupt his monthly remittances to support his three
children with respondent.
In view hereof, it is hereby requested of this Honorable Court that petitioner be allowed to testify
prior to his departure as provided under Section 1 and 14 Rule 23 of the Rules of Court which
will continue from day to day at the same place and time until completed.
Thus in the interest of substantial justice and equity, and considering that petitioner needs to go
back to work abroad after the last week of November 2013 and shall remain there for an
indefinite period of time, petitioner respectfully moves that the Honorable Court allow the taking
of his deposition upon oral examination before the Honorable Presiding Judge pursuant to Rule
23, Section 1, 10 and 15 of the 1997 Rules of Civil Procedure, within the stated time and date,
based on the discretion of the Honorable Court.
This motion is not in any way intended to delay the proceedings but dictated solely for the
reasons stated above.
WHEREFORE, petitioner respectfully prays that the Honorable Court allow the taking of
deposition upon oral examination of petitioner on 26 November 2013 at 8:30 o’clock in the
morning pursuant to Rule 23 of the 1997 Rules of Civil Procedure on the dates and time stated
above.
Petitioner prays for such further or other relief as may be deemed just or equitable under
the premises.
Imus, City for Pasay City, 18 October 2013.

LOMIBAO LAW OFFICE
406 Violago Homes, Litex, Quezon City
Tel. No. 0917- 8032- 788
Email Add.: LLawOffice@yahoo.com
by:

IBP No. 119739 CAVITE CHAPTER
PTR No. 3181314, Imus City, 1-11-12
Attorney’s Roll No. 58500
MCLE Compliance No. VI-1111201
Notice of Hearing
THE CLERK OF COURT

RTC Branch 113
Pasay City
HON. SOLICITOR GENERAL

134 Amorsolo St., Amorsolo Bldg.,
Legaspi Village, Makati City
OFFICE OF THE CITY PROSECUTOR Pasay City
ELLEN A. ADARNA
316 Palin St., Block 27 Lot 77
Ai- Ai, General Tinio, GMA, Cavite
Greetings:
Please submit the foregoing motion for the consideration and approval of the
Honorable Court immediately upon receipt hereof.

Copy furnished:
HON. SOLICITOR GENERAL

134 Amorsolo St., Amorsolo Bldg.,
Legaspi Village, Makati City
OFFICE OF THE CITY PROSECUTOR Pasay City

ELLEN A. ADARNA
316 Palin St., Block 27 Lot 77
Ai- Ai, General Tinio, GMA, Cavite
Explanation
The foregoing motion is being filed to the Honorable Court, Office of the City Prosecutor
and to the other party by personal service with copy therefore furnished to the Office of the
Solicitor General by registered mail, due to the distance of the undersigned from the said
Honorable Solicitor General, making personal service thereof not practicable.
COMPLAINT WITH PRAYER FOR ATTACHMENT

Branch 1, Manila
Juan Tamad
Plaintiff,
Civil case no. 11111
For: Sum of Money
-versus-
Maria Makiling
Defendant
x-------------------------------------------------------------x
COMPLAINT
(with prayer for attachment)
Plaintiff, by the undersigned counsel respectfully states that:
Plaintiff Juan tamad, of legal age, residing at 22 San Miguel St. Manila; while defendant
Maria Makiling is of legal age, residing at 42 San Antonio St. Manila;
Defendand borrowed money from the plaintiff amounting to P100,000 and evidenced by
a promissory note on December 4, 2009, herein attatched as Annex A;
The defendant is about to depart the Phiippines with intent to defraud her creditors;
There is no sufficient security for the claim sought to be recovered from the defendant in
the instant action, and the amount due to plaintiff is as much as the sum for which the
order of attachment may be granted above all legal counterclaims;
Plaintiff is willing to put up a bond for the issuance of the preliminary attachment in an
amount fixed by court, which is not exceeding the amount of plaintiff’s claim;
WHEREFORE, it is respectfully prayed that, pending the hearing of the 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 on the
principal cause of this action, judgment be rendered against the defendantfor the sum of
P100,000 with interest at the stipulated rate of twelve per centum per annum (12%) from
January 20, 2010 plus cost of the suit.
City of Manila; March 3 2010.
SIGNATURE OF COUNSEL
Certification of non forum shopping

Affidavit for Preliminary Attachment
COMPLAINT WITH PRELIMINARY INJUNCTION

Branch 1, Manila
Juan Tamad
Plaintiff,
Civil case no. 11111
For: Sum of Money
-versus-
Maria Makiling
Defendant
x-------------------------------------------------------------x
COMPLAINT
Plaintiff, by the undersigned counsel respectfully states that:
Plaintiff Juan tamad, of legal age, residing at 22 San Miguel St. Manila; while defendant
Maria Makiling is of legal age, residing at 42 San Antonio St. Manila;
Plaintiff is engaged in the exclusive distribution of Nike products in the Philippines;
Defendant is also engaged in the sale of Nike products in the Phillipines;
As a result of defendants acts , plaintiff suffered damage amounting to P500,000 a month
starting January 20, 2010;
Defendant continues to commit the act of illegally interfering with the agreement
between plaintiff and Nike;
Plaintiff is entitled to the relief demanded in whole or part, such relief consists in the
discontinuing of the acts complained of for a limited time or perpetually;
Plaintiff hereby applies for a writ of preliminary injunction to restrain the defendant from
the act herein complained of, and for the purpose offers a bond in such sum this
Honorable Court may fix;
PRAYER
WHEREFORE it is respectfully prayed that, after due notice and having a preliminary
injunction be issuedforthwith to restrain defendant from doing the act complained of, to cease and
desist from selling products of Nike in the Philippine, and that after trial, said injunction be made
permanent, with costs and such orders which are deemed equitable.
City of Manila March 3 2010.
SIGNATURE OF COUNSEL
VERIFICATION AND CERTIFICATION OF NON FORUM SHOPPING

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Republic of the Philippines

-versus- Civil Case No.2324

MARIA DELA CRUZ

CAPTION OF CIVIL ACTION FALLING WITHIN JURISDICTION OF REGIONAL

Republic of the Philippines

-versus- Civil Case No.2324

MARIA DELA CRUZ

CAPTION OF CIVIL ACTION FALLING WITHIN JURISDICTION OF COURT OF

Republic of the Philippines

-versus- CA-G.R. CV No.234

MARIA DELA CRUZ

Republic of the Philippines

-versus- G.R. No.1234234

MARIA DELA CRUZ

CAPTION OF SPECIAL PROCEEDINGS

Republic of the Philippines

In the Matter of ____________

Juan dela Cruz

Republic of the Philippines )

NAME GOVERNMENT ISSUED ID NO.

Atty. GREG GOMEZ

Doc. No. 473

ERIKA JUDI LOMOCSO

THE BRANCH CLERK OF COURT

Aia Marie Comedido

AFFIDAVIT OF PROOF OF SERVICE

AFFIDAVIT OF PROOF OF SERVICE

1. That I am the messenger of Atty.Aia Marie M. Comedido;

2. That I on December 15,2018 personally delivered Defendant’s answer to

3. The Answer was received by plaintiff herself and her counsel.

Doc. No. 376

ERIKA JUDI LOMOCSO

RESOLVED, that (name of officer of firm), (position of officer) be as it hereby,

IN WITNESS WHEREOF, I have hereunto affixed my signature this __________ day

Subscribed and Sworn to before me this __________________ at _______________,

Doc. No. _______

VERIFICATION AND CERTIFICATION AGAINST NON-FORUM SHOPPING,

1. That I am the _____________________ in the above-entitled case have caused this

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

SUBSCRIBED AND SWORN TO before me this _____ day of _________________.

Doc. No. _____

SAMPLE COMPLAINT FOR COLLECTION OF SUM OF MONEY

Republic of the Philippines

MIA C. SANCHEZ, Civil Case No. ________

WHEREFORE, premises considered, it is hereby respectfully prayed before the

b. moral damages, exemplary damages at the sum discretion of the court;

c. attorney’s fees amounting to One Hundred Thousand Pesos (PhP 100,000.00)

d. litigation expenses amounting to Twenty Thousand Pesos (PhP 20,000.00).

Iloilo City, December 6, 2014.

ATTY. VINCENT ENRIQUE A. VARONA

REPUBLIC OF THE PHILIPPINES)

VERIFICATION AND CERTIFICATION

(1) That I am the Plaintiff in the above-entitled case;

ATTY. VINCENT ENRIQUE A. VARONA

Doc. No. ____

Republic of the Philippines

Civil Case No. 000882

For: Sum of Money

PLAINTIFF, by counsel, respectfully states that:

4. Resort to the Barangay Conciliation process proved fruitless as defendant failed to

Other just and equitable reliefs are also prayed for.

Quezon City for Makati; 13 April 2007.

Subscribed and Sworn to before me this ____ at _,

SUBSCRIBED AND SWORN TO before me this _ day of _____________.