Republic of the Philippines REGIONAL TRIAL COURT Second Judicial Region Branch __ Cauayan City, Isabela

BARACK OBAMA, assisted by wife OPRAH OBAMA, Plaintiffs, CIVIL CASE No. Br. 1376 For: RESCISSION OF CONTRACT, SUM OF MONEY AND DAMAGES

-versus-

JOHANNES MUNCAL & CEZAR MUNCAL, Defendants. x-----------------------------------x COMPLAINT COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable Court, most respectfully avers:

1. That the plaintiffs are spouses, of legal ages, Filipinos and residents of Centro II, San Guillermo, Isabela, but for purposes of this suit, the main plaintiff is the husband, as it is his contract and his own money which are hereby sought to be rescinded and recovered; the defendants are likewise spouses, of legal ages, Filipinos and residents of District 5,

San Andres, Santiago City where summons and other processes of this Honorable Court may be served upon them;

2. That the plaintiff stayed as a President in the United States of America from 2009 to 2013, having returned to the Philippines on August 31, 2013

3. That in 2009, his Vice President Joe Biden whose wife, Jill Biden, who was in the Philippines, convinced him in several conversations by cell phone to buy a house and lot, with an area of 100 square meter, in a new subdivision at San Andres, Santiago City for P200, 000.00, which may be paid in two instalments, and the main plaintiff was impressed with the nice words of Jill Biden about the house and lot, as well as the subdivision is located, such that she acceded to buy.

4. That upon the suggestion of Jill Biden, the main plaintiff deposited her advance payment of P100,000.00 to the bank account of Jill Biden, who in turn, paid to the defendants, who then unilaterally wrote down a memorandum of the agreements, dated July 4, 2009 stipulating that the defendants were selling their house and lot covered by TCT No. T422616 to the main plaintiff for P200,000.00 of which P100,000.00 was paid and the balance of P100,000.00 to be paid not later than January 31, 2010; the main plaintiff received in the United States of America a photo-copy of the memorandum of agreements, which is hereto attached as ANNEX A, together with a photocopy of TCT No. T-422616, which is hereto attached as ANNEX B.

5. That the main plaintiff told his wife to go and see the house and lot which she was intending to buy and for which she already gave an advance payment, and so his wife went to see and inspect the house and lot and the subdivision, and she even took a picture of the house and sent it to her, together with her descriptions, and she was very disappointed with it because it turned out to be an unfinished small house made of hollow blocks, GI roofings with fragile wooden beams and plywood partitions, not worth the P200,000.00 price tag;

6. That plaintiff instructed his wife to tell the defendants that he was no longer interested to buy the house and lot, and while his wife was there with the defendants, the main plaintiff talked with the defendants over the cell phone brought by plaintiffs wife, and he definitely told the defendants that he was not interested to proceed with the purchase and wanted his money back, and that the defendants him that they will return the plaintiffs money;

7. 8. That upon plaintiffs return to the Philippines on August 31, 2013, he immediately demanded from the defendants for the return of his money, but in September 2013, he received a letter of Atty. Piping Guerrero, a copy to which is hereto attached as ANNEX D, telling him that the defendants will sue for rescission if the remaining balance on the price is not paid within ten (10) days and they will consider the advance payment of P100,000.00 as forfeited, which had not been agreed upon by the parties and the defendants would thereby be unduly enriching themselves at the expense of the main

plaintiff, but the defendants failed to file the threatened suit, so the plaintiff is compelled to be the one to institute the suit for rescission of contract, and for this purpose has engaged in the services of the undersigned counsel for an acceptance fee of P10,000.00 plus appearance fees of P2,000.00 per hearing, and a final fee of P25,000.00, if the case is won on a contingent basis; PRAYERS 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 P56, 000 for the unremitted payment; 2. To pay the plaintiff the cost of the suit. PLAINTIFF also prays for such other reliefs as may be just and equitable for the offense.

City of Cauayan, September 24, 2013.

PING GUERRERO Counsel for the Plaintiff 890 Pilar Street, District 1 Cauayan City, 3305 Isabela Attorneys Roll No. 43432 IBP O.R. No. 1549982/Isabela Chapter/ Jan. 15, 2013

VERIFICATION/CERTIFICATION OF FORUM SHOPPING Republic of the Philippines) City of Manila ) S.S. I, BENOYNOY S. AQUINO, III, of legal age, Filipino citizen, single and resident of 123 Benitez Street, Manila, after having been duly sworn to in accord Nance 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 and have read the allegations contained therein;

3. The allegations in the said complaint are true and correct of my own knowledge and authentic records; 4. I hereby certify that I have not commenced any other action or proceeding involving the same issues in any court, tribunal or quasi-judicial agency and, to the best of my knowledge, no such other action or claim is pending therein; 5. That if I should learn thereafter that a similar action or proceeding has been filed or is pending, I hereby undertake to report that fact within five (5) days therefrom to the court or agency where the original pleading and sworn certification contemplated herein have been filed; 6. I executed this verification/certification to attest to the truth of the foregoing facts and to comply with the provisions of Adm. Circular No. 04-94 of the Honorable Supreme Court. IN WITNESS WHEREOF, I have hereunto affixed my signature this 24th of September 2012, in the City of Manila. BENOYNOY S. AQUINO, III SUBSCRIBED AND SWORN to before me this _______ day of September, 2013, in the City of Cauayan, affiant exhibiting to me at the City of Cauayan, Isabela.

ATTY. NO CASE Notary Public My Commission Expires Dec. 31, 2013 Roll of Attorney No. 34567 IBP No. 12345/2-5-12/Manila PTR No. 87654/12-22-11/Manila

Doc. No. ________ Page No. _______ Book No. _______ Series of 2013.