Republic of the PhilippinesREGIONAL TRIAL COURT

SEVENTH JUDICIAL REGIONBRANCH ___________

CEBU CITY

GENIE ROSE INC., Plaintiff,

-vs- Civil Case No. ___________ For: Breach of Contract

with DamagesANA BATUMBEKI,DANNY BATUMBEKI, ANNIE BATUMBEKI,

Defendants.X-------------------------------------------------------------------------------------------------------------X

COMPLAINT

PLAINTIFF, GENIE ROSE INC., by counsel and to this HONORABLE COURT, most respectfully avers that:

PARTIES

1. Plaintiff GENIE ROSE INC., (GENIE ROSE for brevity) is a corporation duly organized and existing under the laws of the Republic of the Philippines, duly represented herein by its President & CEO, Ellen Go with current business address at Valiant Bldg., Corranderk Drive St., Arizona Ave., Cebu City, Philippines, and within the jurisdiction of the Honorable Court and maybe served with orders and processes of the Honorable Court at the address above adverted or at the undersigned counsel’s address indicated hereunder. 2. Defendants ANA BATUMBEKI and DANNY BATUMBEKI are both Filipino citizens of legal age and residents of Brgy. Nicolas,Subong,Tawi-Tawi where they may be served with summons and other processes of this Honorable Court.

3. Defendant ANNIE BATUMBEKI, 17 years old and currently residing at Lahug Cebu City is herein impleaded as the Scholar. She may be served with summons and other processes of this Honorable Court with the said address.

CAUSES OF ACTION

4. Plaintiff is engaged in Real Estate business. Plaintiff also provides Scholarship Grants to deserving students of any State University in the Philippines. Copy of Plaintiff’s Certificate of Incorporation and By Laws and General Information Sheets for the Year 2006 to 2014 are hereto attached, made integral parts hereof and duly marked as ANNEXES “A”,”B”, “C”, “D”, “E”, “F”, “G”, “H”, “I”, “J”. 5. Defendants on the other hand are the parents of Annie Batumbeki who qualified as scholar of Plaintiff.

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6. On April 10, 2007, Defendants entered into a scholarship agreement with Plaintiff.

PRAYER

WHEREFORE, PREMISES CONSIDERED, it is respectfully prayed of this Honorable Court that a Decision be rendered in favor of the Plaintiff and against the Defendants:

1. Ordering Defendants to ______2. Ordering Defendants to jointly and severally pay Plaintiff;

a. The sum of Php by way of

Plaintiff prays for such other measures of relief, as the Honorable Court may deem just and equitable under the premises.

Respectfully filed. 18 February 2015.

Cebu City, Philippines.

ARNEL PATATAGROLL NO. 44898

IBP LIFETIME NO. 809788 – 01/11/10 Cebu CityPTR NO. 5463852 – 01/05/15 Cebu City

MCLE COMPLIANCE NO. IV – 0008621 – 10/23/12 Pasig CityCounsel for Plaintiff

2nd Floor Valiant Bldg., Corranderk Drive St., Arizona Ave., Cebu City, Philippines

Tel. No. 0322546491 Local 262; 0323181551

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