compiled-finals - Copy.doc

No.1(a)

Republic of the Philippines

REGIONAL TRIAL COURT

NATIONAL CAPITAL Judicial Region

Branch _____,

METRO MANILA

ALEXANDER SISON

Plaintiff,

Civil Case No. _____________

- versus -

FOR:Collection of Sum of Money

JUAN MARO, With Damages

Defendant,

x - - - - - - - - - - - - - - - - x

COMPLAINT

PLAINTIFF, through the undersigned counsel and to this Honorable Court, respectfully avers that:

1.Plaintiff ALEXANDER SISON is of legal age, Filipino, married, and a resident of 111 Libertad St., Sampaloc, Manila. For purposes of this action, plaintiff may be served with all orders, notices, and other processes of this Honorable Court through the office address of the undersigned counsel indicated below;

2.Defendant JUAN MARO is of legal age, Filipino, single, and may be served with summons and other process of this Honorable Court at his residence address at #222 Juan Luna St., Tondo, Manila;

3.Sometime on January 3, 2008, Defendant obtained from and was granted a loan accommodation by the Plaintiff in the principal amount of ONE MILLION PESOS (Php 1,000,000.00), Philippine Currency. A true and faithful machine reproduction of the Promissory Note made by the Defendant on the said date is hereto attached as Annex A and made an integral part hereof;

4.As shown in the attached promissory note, Defendant promised to pay the said loan on or before January 3, 2009 or one (1) year from the date of the note plus an interest rate of Twelve percent (12%) per annum . However, Defendant failed to pay it on such time and as of February 28, 2015, Defendant still has an Outstanding Balance to Plaintiff amounting to ONE MILLION PESOS (PhP 1,000, 000.00) plus One Hundred Twenty Thousand Pesos (Php 120,000.00) representing the total annual interest.

5.Despite Plaintiff's repeated demands, both written and verbal, Defendant failed, neglected and refused, and continues to fail and refuse to pay and to settle the said Outstanding Balance, without just and valid grounds, to the continued damage and prejudice of Plaintiff. A true and faithful machine reproduction of the Plaintiff's demand letter to Defendant hereto attached as Annex B and made an integral part hereof;

6.Plaintiff likewise initiated proceedings before the Lupong Tagapamayapa of Juan Luna St., Tondo, Manila, however, defendant failed to appear during the scheduled mediation proceeding despite proper notice, prompting the Lupong Tagapamayapa to issue Certificate to File Action. A copy of Notice of Hearing and Certification to File Action are hereto attached as Annex C and D and made an integral part hereof;

7.Consequently, Plaintiff was constrained to engage the services of counsel to whom she obligated herself to pay as Attorney's Fees the amount equivalent to ONE HUNDRED THOUSAND PESOS (PhP 100, 000.00), ten percent (10%) of the total amount due from Defendant to Plaintiff.

PRAYER

WHEREFORE, premises considered, after due notice and hearing, Plaintiff respectfully prays that judgment be rendered against the Defendant as follows:

1.Ordering the Defendant to pay Plaintiff the sums of:

a.The amount of ONE MILLION PESOS (Php 1,000, 000.00), representing Defendant's Outstanding Balance, plus One Hundred Twenty Thousand Pesos representing the total annual interest at twelve percent (12%) per annum as stipulated upon in the Promissory Note;

b.ONE HUNDRED THOUSAND PESOS (PhP 100, 000.00), twelve percent (10%) of the total amount due as Attorney's Fees plus Appearance Fee at the rate of PhP 3, 000.00 per court hearing / conference;

c.Five percent (5 %) of the total amount due as Collection Charges / Liquidated Damages;

d.The costs of suit.

2.Plaintiff likewise prays for such other reliefs as may be just and equitable in the premises.

City of Manila, Philippines, April 1, 2015.

ATTY. CECILIA L. OCHAVO-SAYCON

Counsel for Complainant

#87-C E. Lopez Street, Jaro, Metro Manila

Roll of Attorney No. 55123

PTR No. 27027, City of Manila, January 10, 2014

IBP No. 22427, City of Manila, January 4, 2014

MCLE Compliance No. IV-000927

Republic of the Philippines)

PROVINCE OF ILOILO) SS.

x - - - - - - - - - - - - - - - - - - - - - - - - - - - - x

VERIFICATION AND CERTIFICATION

I, ALEXANDER SISON of legal age, Filipino, married, and a resident of 111 Libertad St., Sampaloc, Manila, after being sworn in accordance with law, hereby depose and say:

That I am the Plaintiff in the above-entitled case; That I have caused the preparation of the above Complaint and I have read the same and understood the contents thereof; That the allegations contained therein are true and correct of my own personal knowledge and based on authentic records.

That I further certify that: (a) I have not theretofore commenced any other action or proceeding or filed any claim involving the same issues or matter in any court, tribunal, or quasi-judicial agency and, to the best of my knowledge, no such action or proceeding is pending therein; (c) if I should thereafter learn that the same or similar action or proceeding has been filed or is pending before the Supreme Court, the Court of Appeals, or any other tribunal or quasi-judicial agency, I undertake to report such fact within five (5) days therefrom to the court or agency wherein the original pleading and sworn certification contemplated herein have been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this 1st day of April 2015 at the City of Manila, Philippines.

ALEXANDER SISON

Affiant

TIN 909-808-707; City of Manila

SUBSCRIBED AND SWORN to before me, this 1st day of April 2015, affiant exhibiting to me his Tax Identification Card as shown above below his name as competent evidence of his identity.


Notary Public for and in the

City of Manila and the National Capital Region

Commission Serial. No. 1019

Valid until December 31, 2015

#87-C E. Lopez Street, Jaro, Metro Manila


PTR No. 27027, City of Manila, January 10, 2014

IBP No. 22427, City of Manila, January 4, 2014


Doc. No. ______;

Page No. ______;

Book No. ______;

Series of 201_.

No.1(b)

SPECIAL POWER OF ATTORNEY

KNOW ALL MEN BY THESE PRESENTS

I, CARLO ENRIQUEZ, of legal age, single, Filipino, and a resident of Lopez Jaena St., Jaro, Iloilo City, do hereby name, constitute and appoint MERLYN FRANCISCO, of legal age, single, Filipino, and a resident of D.B. Ledesma St., Jaro, Iloilo City, to be my true and lawful attorney-in-fact, for me and in my name, place and stead, and in my behalf for my own benefit, to do and perform the following things and acts, to wit:

1.To sell, transfer and convey at whatever price, terms and conditions that he/she may deem proper and fit, to whosoever may buy or purchase our property consisting of a piece of land located at Lot 2 Block 3 Forbes Park, Makati City, Metro Manila City covered by TCT No. 14-13435325;

2.To accept and collect full payment in her name and/or in our joint names, the proceeds of sale of the afore described property and sign for the receipt thereof;

3.To sign and execute any and all documents of sale, transfer or conveyance of the aforementioned property;

4.To pay any and all unpaid or accrued property taxes including such capital gains and documentary stamp taxes necessary to effect the registration of the sale and the transfer of title of the said property to the buyer or purchaser of the same;

5.To engage the services of a reputable real estate broker, a lawyer, a tax professional and such other professional real estate practitioner, if necessary, to ensure the expeditious and smooth sale of the property and to pay their respective fees and/or commissions from out of the proceeds of sale of the same;

6.To do and perform any and all other lawful act and deeds necessary to undertake the execution and finalization of sale, transfer or conveyance of the said property.

HEREBY GIVING AND GRANTING unto the said attorney full power and authority to do whatsoever requisite or necessary or proper to be done in or about the premises, as fully to all intents and purpose as I might or could lawfully do if personally present, and hereby ratifying and confirming all that the said attorney shall do or cause to be done under and by virtue of these presents.

IN WITNESS WHEREOF, I have hereunto set our hands this 31st day of March 2015 at Iloilo City, Philippines.

CARLO ENRIQUEZ

Affiant

SIGNED IN THE PRESENCE OF:

BEN CHANTOSPAOLO BENTANES

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES )

CITY OF ILOILO ) S.S.

BEFORE ME, a Notary Public, for and in the City of Iloilo, this 31st day of March 2015, in the City of Iloilo, Philippines, personally appeared, CARLO ENRIQUEZ, with TIN 134-123-134, issued on March 23, 2005, at Iloilo city, Philippines, and MERLYN FRANCISCO, with TIN 546-123-134, issued on March 2, 2005, at Iloilo city, Philippines, known to me to be the same person who executed the foregoing document and acknowledged tome as their own free and voluntary act and deed.

WITNESS MY HAND AND SEAL this 31st day of March 2015at Iloilo City, Philippines.

ATTY. LAURENCE SUSAN P. ORTIZ


City and Province of Iloilo



#03 Lopez, Jaena St., Jaro, Iloilo City


PTR No. 22334, Iloilo City, January 17, 2014

IBP No. 44556, Iloilo City, January 10, 2014

MCLE Compliance No. VI-010489

Doc. No. ____;

Page No. ____;

Book No. ____;

Series of 2015.

No. 3


REGIONAL TRIAL COURT

6h Judicial Region

Branch ___

Metro Manila

PEOPLE OF THE PHILIPPINES,CRIM. CASE NO.

Plaintiff,FOR: Robbery with Homicide

-versus-

EDGAR BASTONERO, alias

Bugoy and CARLOS

TIRADOR, alias Pogi,

Accused.

x------------------------------------------x

INFORMATION

The undersigned Assistant City Prosecutor accuses Edgar Bastonero alias Bugoy and Carlos Tirador alias Pogi of the crime of Robbery with Homicide, defined and penalized under Article 295, paragraph 1 of the Revised Penal Code, committed as follows:

That on September 13, 2009 at 6 oclock in the evening at the coner of Dapitan and Castillas Sts., Sampaloc, Manila and within the jurisdiction of the Honorable Court, the above-named accused EDGAR BASTONERO, alias Bugoy and CARLOS TIRADOR, alias Pogi, conspiring and confederating together and mutually helping one another, by means of force and violence employed upon the person of one JOHNNY ESCOLAR, in repeatedly stabbing with sharp bladed instruments the latter on the chest, with intent of gain and against the will and consent of said Johnny Escolar, did then and there willfully, unlawfully and feloniously take, steal and rob from the latter, his cellular phone and wrist watch more or less, to the damage and prejudice of said Thelma Padua- Aruelo in the amount of P15,200.00, and which cellular phone has never been recovered: that also as a consequence of the force and violence employed by the herein accused upon the person of Johnny Escolar, prompted by deliberate intent to kill, the latter sustained mortal wounds which caused his untimely death.

Contrary to law.

Metro Manila, January 19, 2010

ATTY. RIZALEE J. PEREZ

Assistant City Prosecutor

WITNESSES:

WILLIAM TAN HENRY UY

CERTIFICATION

I hereby certify that a preliminary investigation was conducted in the above-entitled case and there is prima facie evidence that the crime of Robbery with Homicide has been committed and that the accused are probably guilty thereof.

ATTY. RIZALEE J. PEREZ

Assistant City Prosecutor

Bail Recommended: None

No. 4

LEASE CONTRACT

KNOW ALLMEN BY THESE PRESENTS:

This CONTRACT OF LEASE is made and executed at the City of Iloilo, this 4th day of April, 2015, by and between:

JOSE UY, of legal age, single, Filipino, and with residence andpostal addressat 3 352 Jayme St., Jaro, Iloilo, hereinafter referred to as the LESSOR.

-AND-

JOHN PRATS, likewise of legal age, single, Filipino and with residence andpostal addressa No. 39, Blk. 42, Puerto Real Subdivision, La Paz, Iloilo City, hereinafter referred to as theLESSEE.

WITNESSETH; That

WHEREAS,theLESSORis the owner of the Third Floor of Panaderia ni Pa-a Building, hereinafter referred to as THE LEASED PREMISES, acommercial building, situated at Jaro, Iloilo City;

WHEREAS,theLESSORagrees to lease-out the said property to the LESSEE and the LESSEE is willing to lease the same;

NOW THEREFORE, for and inconsiderationof the foregoing premises, the LESSOR leases unto the LESSEE and the LESSEE hereby accepts from the LESSOR the LEASED premises, subject to the following:

TERMS AND CONDITIONS

1.PURPOSES: That premises hereby leased shall be used exclusively by the LESSEE for mandatory continuing education and review classes for the Bar examinationspurposesonly and shall not be diverted to other uses. It is hereby expressly agreed that if at any time the premises are used for otherpurposes, the LESSOR shall have the right to rescind this contract without prejudice to its other rights under the law.

2.TERM: This term of lease is for ONE (1) YEAR from April 1, 2015 to April 1, 2016 inclusive. Upon its expiration, this lease may be renewed under such terms and conditions as my be mutually agreed upon by both parties, written notice of intention to renew the lease shall be served to the LESSOR notlater than thirty (30) days prior to the expiry date of the period herein agreed upon.

3. RENTAL RATE: The monthly rental rate for the leased premises shall be in TWENTY FIVE THOUSAND PESOS (P 25,000.00), Philippine Currency. All rental payments shall be payable to the LESSOR.

4. DEPOSIT: That the LESSEE shall deposit to the LESSOR upon signing of this contract and prior to move-in an amount equivalent to the rent for THREE (3) MONTHS or the sum of SEVENTY FIVE THOUSAND PESOS (P 75,000.00), Philippine Currency, wherein the two (2) months deposit shall be applied as rent for the 11th and 12th months and the remaining one (1) month deposit shall answer partially for damages and any other obligations, for utilities such as Water, Electricity, CATV, Telephone, Association Dues or resulting from violation(s) of any of the provision of this contract.

5. DEFAULT PAYMENT: In case of default by the LESSEE in the payment of the rent, such as when the checks are dishonored, the LESSOR at its option may terminate this contract and eject the LESSEE. The LESSOR has the right to padlock the premises when the LESSEE is in default of payment for Two (2) months and may forfeit whatever rental deposit or advances have been given by the LESSEE.

6. SUB-LEASE: The LESSEE shall not directly or indirectly sublet, allow or permit the leased premises to be occupied in whole or in part by any person, form orcorporation, neither shall the LESSEE assign its rights hereunder to any other person or entity and no right of interest thereto or therein shall be conferred on or vested in anyone by the LESSEE without the LESSOR'S written approval.

7. PUBLIC UTILITIES: The LESSEE shall pay for its telephone, electric, cable TV, water, Internet, association dues and other publicservicesand utilities during the duration of the lease.

8. FORCE MAJEURE: If whole or any part of the leased premises shall be destroyed or damaged by fire, flood, lightning, typhoon, earthquake, storm, riot or any other unforeseen disabling cause of acts of God, as to render the leased premises during the term substantially unfit for use and occupation of the LESSEE, then this lease contract may be terminated without compensation by the LESSOR or by the LESSEE by notice in writing to the other.

9. LESSOR'S RIGHT OF ENTRY: The LESSOR or its authorized agent shall after giving due notice to the LESSEE shall have the right to enter the premises in the presence of the LESSEE or its representative at any reasonable hour to examine the same or make repairs therein or for the operation and maintenance of the building or to exhibit the leased premises to prospective LESSEE, or for any other lawfulpurposeswhich it may deem necessary.

10. EXPIRATION OF LEASE: At the expiration of the term of this lease or cancellation thereof, as herein provided, the LESSEE will promptly deliver to the LESSOR all corresponding keys and in as good and tenable condition as the same is now, ordinary wear and tear expected devoid of all occupants, movable furniture, articles and effects of any kind. Non-compliance with the terms of this clause by the LESSEE will give the LESSOR the right, at the latter's option, to refuse to accept the delivery of the premises and compel the LESSEE to pay rent therefrom at the same rate plus Twenty Five (25) % thereof as penalty until the LESSEE shall have complied with the terms hereof. The same penalty shall be imposed in case the LESSEE fails to leave the premises after the expiration of this Contract of Lease or termination for any reason whatsoever.

11. JUDICIAL RELIEF: Should any one of the parties herein be compelled to seek judicial relief against the other, the losing party shall pay an amount of One Hundred (100) % of the amount clamed in the complaint as attorney's fees which shall in no case be less than P30,000.00 pesos in addition to other cost and damages which the said party may be entitled to under the law.

12. ThisCONTRACT OF LEASEshall be valid and binding between the parties, their successors-in-interest and assigns.

IN WITNESS WHEREOF,parties herein affixed their signatures on the date and place above written.

JOSE UY JOHN PRATS LESSOR LESSEE

Signed in the presence of:

HENRICH P. LIM CIBIL CODESA

ACKNOWLEDGEMENT

Republic ofthe Philippines)

City of Iloilo ) S.S

x--------------------------------x

BEFORE ME, personally appeared:

Name CTC Number Date/Place Issued

JOSE UY 1920810 February 24, 2014 / Iloilo City

JOHN PRATS 0928490 January 07, 2014 / Iloilo City

Known to me and to me known to be the same persons who executed the foregoing instrument and acknowledged to me that the same is their free and voluntary act and deed.

This instrument consisting of four (4) pages, including the page on which this acknowledgement is written, has been signed on each and every page thereof by the concerned parties and their witnesses, and sealed with my notarial seal.

WITNESS MY HAND AND SEAL, on the date and place first above written.

Doc No. ______;

Page No. ______;

Book No. _____;

Series of 2015.

No.5

REPUBLIC OF THE PHILIPPINES)

CITY OF ILOILO ) S.S.

x-------------------------------------------------x

AFFIDAVIT OF LOSS

I, RIZALEE J. PEREZ, female, of legal age, single, Filipino, and a resident of 210 Lopez Jaena St., Jaro, Iloilo City, after having been duly sworn to in accordance with law hereby depose and state, that:

I am a licensed Certified Public Accountant (CPA);

I am the owner of a CPA professional license, with license no. 1596483672;

Some time on March 15, 2015, I discovered that the said license, which is usually kept in my wallet, cannot anymore be found therein;

Despite diligent efforts to locate the said license, the same could no longer be found and therefore is considered lost and beyond recovery;

I am executing this affidavit to attest to the truth of the foregoing facts, for the purpose of requesting for the reissuance/renewal of said license with the Professional Regulation Commission (PRC), and for any other intent this may duly serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 30th day of March, 2015 at Iloilo City, Philippines.

RIZALEE J. PEREZ

Affiant

SUBSCRIBED AND SWORN TO before me this 30th day of March 2015 at Iloilo City. Affiant exhibited to me his Tax Identification Card with No.000-860-567 as competent proof of identity.

Doc. No. _________;

Page No. _________;

Book No. _________;

Series of 2015.

No. 6

CHATTEL MORTGAGE

KNOW ALLMEN BY THESE PRESENTS:

This CHATTEL MORTGAGE, made and entered into by and between-

TESS BUZZ,of legal age,single, withpostal addressatBrgy. Sambag, Jaro, Iloilo City, hereinafter known as the MORTGAGOR,

-and -

RIZAL COMMERCIAL BANKING INSTITUTION, a banking institution duly organized under the laws of the Philippines, with principal office at 302 Roosevelt Avenue, San Francisco Del Monte, Quezon City, Metro Manila, represented by its Jaro, Iloilo City Branch ManagerJOSIE C. DIZON, hereinafter known as the MORTGAGEE

WITNESSETH

That the MORTGAGOR is indebted unto the MORTGAGEE in the sum ofEIGTH HUNDRED THOUSAND PESOS (PhP 800,000.00),Philippine Currency, receipt of which is acknowledged bythe MORTGAGOR upon the signing of thisinstrument,payable within a period of three (3) years,with interest thereon atthe rateof 10% per annum;

That for, and consideration of,this indebtedness, andto assure the performance of said obligation to pay, theMORTGAGOR hereby conveys by way of CHATTEL MORTGAGE unto the MORTGAGEE, his heirs and assigns, the following personality now in the possession ofsaid MORTGAGOR

MAKE : Honda Civic

MOTOR NO. : 5467893

SERIES :67

SERIAL/CHASSIS NO. : 52479

TYPE OF BODY: Coupe

PLATE NO. : FEW 456

YEAR MODEL:2010

FILE NO. : 700034

That the condition of this obligation is that shouldthe MORTGAGORperformthe obligation to pay the hereinabove cited indebtedness of EIGTH HUNDRED THOUSAND PESOS (PhP 800,000.00),Philippine Currency, togetherwith accrued interest thereon, this chattel mortgage shall at once become null and void and of no effect whatsoever,otherwise, it shall remain infull forceand effect.

IN WITNESS WHEREOF, the parties have hereuntoset their hands, this 28th day of March 2015 at Iloilo City, Philippines.

TESS BUZZ JOSIE C. DIZON

MORTGAGOR MORTGAGEE

IN THE PRESENCE OF:

JOAN BLAIRE V. SIOROSEMINDA A. VARONA

ACKNOWLEDGEMENT

REPUBLIC OFTHE PHILIPPINES)ILOILO CITY ) S.Sx------------------------------------------------x

BEFORE ME, personally appeared: Name TINDate/Place Issued TESS BUZZ 3489302 January 5, 2009/ Iloilo CityJOSIE C. DIZON 2390294 May 3, 2010/ Iloilo CityKnown to me and to me known to be the same persons who executed the foregoing instrument and acknowledged to me that the same is their free and voluntary act and deed.

WITNESS MY HAND AND SEAL this 31st day of March 2015 at Iloilo City, Philippines.

ATTY. VINCENT ENRIQUE A. VARONA

Notary Public for and in the City and Province of Iloilo

My Commission No. is 58

Expires on December 31, 2015

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

Doc. No. ;

Page No. ;

Book No. ;

Series of 2015.

AFFIDAVIT OFGOOD FAITH

We, the undersigned MORTGAGOR AND MORTGAGEE hereby jointly and severally swear that we executed the foregoing Chattel Mortgage in order to secure the indebtedness therein and for no other purpose or purposes contrary to law.

TESS BUZZ JOSIE C. DIZON

MORTGAGOR MORTGAGEE

TIN 3489302, 01/05/09, Iloilo CityTIN 2390294, 05/03/10, Iloilo City

SUBSCRIBED AND SWORN to before me, this 31st day of March 2015, affiants exhibiting to me their Tax Identification Card as shown above below their names as competent evidence of their identities.


Notary Public for and in the City and Province of Iloilo

My Commission No. is 58

Expires on December 31, 2015




IBP NO. 123456, 01/04/14, Iloilo City

MCLE Comp. No. IV-0009876, 01/02/14

Doc. No. ;

Page No. ;

Book No. ;

Series of 2015;

No. 7(a)

GELITO LAW OFFICE

Room 5, 2nd Floor, Buencamino Building

No. 338-F Project 4, Quezon City

July 1, 2007

JUN MIRANDA

No. 9, West Aguila, Green Cross Subdivision

Quezon City, Philippines

Dear Mr. Miranda:

I wrote this letter in behalf of my client, IAN ALBA, on the matter of your non-fulfillment of your obligation.

My clients records provide that you have an outstanding liability due to my client in the aggregate amount of THREE HUNDRED THOUSAND PESOS (P300,000.00) comprising of the monthly rental of FIFTY THOUSAND PESOS (P50,000.00) from January 1, 2007 to June 30, 2007.

This serves as a FINAL DEMAND for you to settle the said amount within FIVE (5) days from receipt of this letter and to vacate the premises after the settlement of said liability. Otherwise, we will be constrained to file a necessary legal action against you to protect the interest of our client.

We trust that you will give this matter your prompt and preferential attention to avoid the expense and inconvenience of litigation.

Sincerely,

Atty. Jose Judhil F. Gelito

No. 7(b)

REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

Branch ____

Quezon City

IAN ALBA, Plaintiff, CIVIL CASE No. _____ -versus- FOR: Unlawful DetainerJUN MIRANDA, Defendant.x-----------------------------------x

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable Court, most respectfully avers:

1. That the plaintiff, IAN ALBA, is of legal age, Filipino citizen, with residence and postal address at No. 9, West Aguila, Green Cross Subdivision, Quezon City, Philippines where he may be served with summons and other court processes;

2. That the defendant, JUN MIRANDA, is of legal age, Filipino citizen, single, with residence and postal address at No. 9, West aguila, Green Cross Subdivision, Quezon City, Philippines where he may be served with summons and other court processes;

3. That the plaintiff is the owner of the subject property, a house and lot, located at No. 9, West Aguila, Green Cross Subdivision, Quezon City, Philippines;

4. That by virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid house and lot for a consideration of FIFTY THOUSAND PESOS (P50,000.00) for a term of two years starting May 1, 2006;

5. That the defendant failed to pay the agreed rental for six months starting January 1, 2007 to June 30, 2007or a total of THREE HUNDRED THOUSAND PESOS (P300,000.00).

6. That on July 1, 2007, the plaintiff sent a letter of demand, requesting the defendant to fulfill his obligation and to vacate the premises, which was received by the defendant on July 2, 2007 as shown in the registry return receipt hereto attached as Annex A;

7. That despite the said letter of demand, the defendant failed to pay his liability and to vacate the premises;

8. That by reason of the failure of the defendant to pay the unpaid rentals and to vacate the premises, the plaintiff was compelled to file this complaint engaging the services of a counsel in the amount of P25,000.00.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable Court that after hearing judgment be rendered ordering the defendant:

1. To pay the amount of THREE HUNDRED THOUSAND PESOS (P300,000.00);

2. To vacate the premises;

3. To pay the plaintiff the cost of the suit.

Quezon City, Philippines, July 8, 2007.


Counsel for the Plaintiff


IBP Lifetime No. 367700

Republic of the Philippines )City of Quezon ) S.S.

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

I, IAN ALBA, of legal age, Filipino citizen, single and resident of No. 9, West Aguila, Green Cross Subdivision, Quezon City, Philippines, after having been duly sworn to in accordance with law do hereby depose and say:

1. That I am the plaintiff in the above-entitled case;

2. That I have caused the preparation of the foregoing complaint;

3. That I have read and understood the allegations contained therein and the same are true and correct of my own knowledge and based on authentic records;

4. That I have not heretofore commenced or filed any other action or proceeding involving the same issues in any court, tribunal or quasi-judicial agency; that to the best of my knowledge, no such other action or claim is pending in any court, tribunal or agency; that if I should learn thereafter that a similar action or proceeding has been filed or is pending, I hereby undertake to inform this Honorable Court such fact within five (5) days therefrom.

IN WITNESS WHEREOF, I have hereunto set my hand this 8th day of July 2007, in the City of Quezon, Philippines.

IAN ALBA

Affiant

Drivers License No. 1234567

Valid until: December 15, 2007

SUBSCRIBED AND SWORN to before me this 8th day of July 2007, in the City of Quezon, Philippines, affiant having exhibited to me his Drivers License No.: 1234567 issued on December 15, 2005 at Quezon City.


Notary Public until December 31, 2008

Reg. No. 2013-040

PTR No. 4905269, Quezon City, January 5, 2007

Roll No. 41990

IBP Lifetime No. 367700

MCLE Compliance No. IV- 0007890

Doc. No. 5;

Page No. 2;

Book No. 1;

Series of 2007.

No. 8

DEED OF ABSOLUTE SALE

KNOW ALL MEN BY THESE PRESENTS:

That I, GERRY CRUZ, of legal age, single, Filipino and residents of No. 31, Blk. 78, Happy Villages , Sampaloc, Manila, Philippines, do hereby state and declare:

WITNESSETH:

That I am the registered owner of a parcel of land, hereunder particularly described as follows:

TCT NO. 12345

A parcel of land (Lot No. 42, Block 6 of the subdivision plan Psd-77339, being a portion of Lot 2399-F of plan Psd-50077, L.R.C. Record No.), situated in the Brgy. Sampaloc, City of Manila. Bounded on the NW., along line 1-2 by Lot 41, Block 6 of the subdivision plan; on the NE., along line 2-3 by Lot 2399-B of Plan Psd-5077; on the SE, along line 3-4 Lot 43, Block 6; and on the SW., along line 4-1 by Road Lot 9, both of the subdivision Plan. Containing an area of ONE THOUSAND (1,000) square meters, more or less.

That for and in consideration of the sum of ONE MILLION PESOS (P1,000,000.00), receipt of the said amount, we do hereby acknowledge to our full and complete satisfaction from ANGELO SANTOS of legal age, Filipino, married to Angela Reyes, and a resident of Democracia Street, Sampaloc, Manila, by these presents, do hereby SELL, CEDE, TRANSFER and CONVEY, unto the said ANGELO SANTOS, his heirs and assigns, a portion of the above-mentioned described parcel of land consisting an area of One Thousand (1,000.00) square meters, more or less, free from all liens and encumbrances.

That the above-described parcel of land is residential and is not covered by the provisions of the Comprehensive Agrarian Reform Law.

IN WITNESS WHEREOF, I have hereunto set my hand this 26th day of September 2005, at Iloilo City, Philippines.

GERRY CRUZ ANGELO SANTOS

Vendor Vendee

CTC No. 090810CTC No. 123701

Issued at Manila, PhilippinesIssued at Manila, Philippines

Issued on 1/1/2015Issued on 2/7/2015

SIGNED IN THE PRESENCE OF

_________________________________________________________________

ACKNOWLEDGEMENT

REPUBLIC OF THE PHILIPPINES)

CITY OF ILOILO ) SS.

X - - - - - - - - - - - - - - - - - - - - - - - X

BEFORE ME, a Notary Public for and in the Province and City of Manila, Philippines, this 26th day of September 2005, personally appeared the above-named VENDORS, with their CTCs appearing below their respective names, all known to me to be the same persons who executed the foregoing instrument and they acknowledged that the same is their free and voluntary act and deed.

This instrument consists of two (2) pages, including this page wherein this acknowledgement is written, refers to a Deed of Absolute Sale, signed by the VENDORS and their instrumental witnesses on each and every page hereof.

WITNESS MY HAND AND SEAL, on the date and place above-written.

Doc. No. _________;

Page No. _________;

Book No. _________;

Series of 2015.

No. 9


6th Judicial Region

Regional Trial Court

Branch 10

Iloilo City

JOHN LLOYD CRUZ,CIVIL CASE NO. 2014-0123Plaintiff,FOR: Nullity of Marriage

-versus-

SHAWIE CUNETA,

Defendant.

x------------------------------------x

MOTION TO WITHRAW AS COUNSEL

COMES NOW, Counsel of record for the defendant and to this Honorable Court respectfully moves to withdraw as counsel of said defendant without the express consent of said defendant, due to a recent appointment as a clerk of court in the Regional Trial Court Branch 10.

That upon approval of this Honorable Court, all pleadings, notice and papers in connection with this case be addressed to SHAWIE CUNETA with address at Alta Tierra Village, Jaro, Iloilo City.

Jaro, Iloilo City, Philippines this 31st day of March, 2015.

ATTY. JUAN DE LA CRUZ

Counsel for the plaintiff

Copy furnished through personal service:

Atty. Pedro Penduko

Counsel for the Defendant

#03 Lopez, Jaena St.,

Jaro, Iloilo City

WITHDRAWAL OF APPEARANCE

THE BRANCH CLERK OF COURT


Branch 10, Iloilo City

Please make of record the WITHDRAWAL of the undersigned as counsel for plaintiff, JOHN LLOYD CRUZ, due to irreconcilable professional differences with plaintiff, for which reason the express conformity of plaintiff cannot be obtained. Henceforth kindly address all pertinent notices to plaintiff at her address given in the Complaint.

RESPECTFULLY SUBMITTED.

Jaro, Iloilo City; 31st day of March 2015.


Counsel for the plaintiff

No.10


6TH Judicial Region


Branch 42

Iloilo City

MIA C. SANCHEZ,

Plaintiff,

- versus - Civil Case No. 34857

FOR: COLLECTION OF A

SUM OF MONEY

PAOLO D. CRUZ,

Defendant.

x -----------------------x

NOTICE OF APPEAL

DEFENDANT,PAOLO D. CRUZ, by counsel, and unto this Honorable Court, most respectfully gives notice that he is appealing to the Regional Trial Court, both questions of fact and law, the Decision dated January 23, 2015, a copy of which was received on January 26, 2015.

Respectfully submitted.

February 4, 2015, Iloilo City, Philippines.


Counsel for Defendant





MCLE Comp. No. IV-0009876, 01/02/14

COPY FURNISHED:

BY PERSONAL SERVICE

ATTY. MA. CASSIE JEAN D. DOLDUCO

Counsel for the Petitioner

Dolduco Law Office, Mission Extension Street, Lapaz, Iloilo City

Received on February 4, 2015

No. 11

DEED OF DONATION OF A PARCEL OF LAND

KNOW ALL MEN BY THESE PRESENTS:

This Deed of Donation, made and executed in the City of Iloilo, Philippines, by VIVIEN GARCIA CRUZ of legal age, single, Filipino citizen and with residence and postal address at 5006 Lacturan Dumangas, Iloilo, hereinafter called the DONOR.

- IN FAVOR OF -

SHAUN GARCIA CRUZ, of legal age, single, Filipino citizen and with residence and postal address at 5006 Bacay Dumangas, Iloilo, hereinafter called the DONEE.

- WITNESSETH -

That the DONOR is the owner of a parcel of land situated in Lot 1 Block 3 Rica Village, Tabuc Suba, Jaro, Iloilo City and more particularly described in Transfer Certificate of Title No. 123456 of the Registry of Deeds of Iloilo City.

That for and in consideration of the love and affection which the DONOR has for the DONEE, the said DONOR, by these presents, transfers and conveys, by way of donation, unto said DONEE, his heirs and assigns, the above described real property, free from all liens and encumbrances;

That the DONOR does hereby state, for the purpose of giving full effect to this donation, that he has reserved for himself in full ownership sufficient property to support him in a manner appropriate to his needs;

That the DONEE does hereby accept this donation of the above-described property, and does hereby express gratitude for the kindness and liberality of the DONOR.

IN WITNESS WHEREOF, the DONOR and the DONEE have signed this deed on the 1st day of March 2015 at Iloilo City, Philippines.

VIVIEN GARCIA CRUZ SHAUN GARCIA CRUZ Donor Donee

SIGNED IN THE PRESENCE OF:

MARIA LOPEZ MAKILING JUAN GO TAMAD Witness Witness

ACKNOWLEDGEMENT

Republic of the Philippines)

ILOILO City ) S.S.

BEFORE ME, this 1st day of March 2015, personally appeared (1) VIVIEN GARCIA CRUZ; (2) SHAUN GARCIA CRUZ; (3) MARIA LOPEZ MAKILING (4) JUAN GO TAMAD, all Filipinos, of legal age, and residing at Dumangas, Iloilo, having presented to me their respective competent evidence of identities as indicated below:

NAME

COMPETENT EVIDENCE OF IDENTITY

DATE / PLACE ISSUED

VIVIEN GARCIA CRUZ

TIN 342-670-456

2/28/2015, Iloilo City

SHAUN GARCIA CRUZ

TIN 1234-456-789


MARIA LOPEZ MAKILING

TIN 987-654-321


JUAN GO TAMAD

TIN 234-564-089


To me known to be the persons who executed and accepted the foregoing instrument of Deed of Donation over one (1) parcel of land including all the improvements thereon, which instruments consist of two (2) pages including the page on which this acknowledgement is written and signed at the left margin of each and every page by the party executing this instrument and their witnesses and sealed with my notarial seal and the acknowledge to me that the same is their free act and deed.

IN WITNESS WHEREOF, I have hereunto set my hand and seal this 1st day of March 2015.

ATTY. MA. CASSIE JEAN D. DOLDUCO

NOTARY PUBLIC

Commission Serial No. 72

Valid Until December 31, 2015

Dolduco Law Office,

Mission Extension Street, Lapaz, Iloilo City

Roll OF AttorneyS NO. 34875



MCLE Comp. No. IV-0007621, 3/10/14

No. 12

"Any dispute, controversy or claim arising out of or relating to this contract, or the breach, termination or invalidity thereof shall be settled by arbitration in accordance with the PDRCI Arbitration Rules as at present in force.(a) The appointing authority shall be Mr. Sander Grande;(b) The number of arbitrators shall be three;(c) The place of arbitration shall be at Jaro, Iloilo City;(d) The languages to be used in the arbitral proceedings shall be English or Filipino"

ATTY. LAURENCE SUSAN P. ORTIZ





#03 Lopez, Jaena St., Jaro, Iloilo City


PTR No. 22334, Iloilo City,

January 17, 2014

IBP No. 44556, Iloilo City,

January 10, 2014

MCLE Compliance No. VI-010489






#87-C E. Lopez Street, Jaro, Iloilo City


PTR No. 27027, Iloilo City, January 10, 2014

IBP No. 22427, Iloilo City, January 4, 2014



Notary Public Within the Territorial

Jurisdiction of the City and Province of Iloilo

No. 20, Bonifacio Drive, Iloilo City

Notarial Commission Reg. No. 91


PTR No. 4816263, Iloilo City

January 6, 2014

IBP No. 596706, Iloilo City

January 3, 2014

Roll No. 75329

TIN: 244-535-544


Doc. No. ____;

Page No. ____;

Book No. ____;

Series of 2015.

Documents

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