Office of the Chief Legal Counsel
P N B LEGAL GROUP
MANUEL C. BAHENA, JR. nk ino: 828315 fo TOODT 0001979
FVP, Officer-in-Charge Local: 2360
April 23, 2013
PEREZ, UY, MATOL-SIA & ASSOCIATES
Suite 007, 2 Floor, S & A Building
‘Avenida Veteranos cor. Paterno St. or
Gor. Jones & Trece Martirez Sts.
Tacloban City
Attention: Atty. Neil M. Sia
SUBJECT: PNB, CATBALOGAN BRANCH, REPRESENTED BY ITS MANAGER V.
PROVINCIAL AGRARIAN REFORM OFFICER (PARO) OF SAMAR, GREGORIO D.
FIEL, JR. LAND BANK OF THE PHILIPPINES (LBP), AGRARIAN OPERATIONS
CENTER VIII, TACLOBAN CITY; CIVIL CASE NO. 8071; REGIONAL TRIAL COURT,
BRANCH 29, CATBALOGAN, SAMAR
Gentlemen:
In line with our existing engagement agreement, we refer to you the subject case
for handling,
Atty. Benly Frederick C. Bergonio, our then Branch lawyer assigned to man our
‘Samar-Leyte Legal Unit, filed a Motion to Withdraw (as Counsel for the Bank) dated
February 1, 2013 (copy attached).
The subject case is now in its trial stage (awaiting Court setting).
In this regard, please enter your appearance as counsel for the Bank in the
‘subject case.
We will request Mr. Giovanni B. Sison, Legal Staff of our Samar-Leyte Legal Unit,
to forward to your end the corresponding case files relative to the subject case. You may
also coordinate with him through his mobile number (0939) 9212833 or office number
(055) 2613794.
9 Floor, PNB Financial Center, Pres. Diosdado Macapagal Bivd., Pasay CityAso, for easy monitoring, please provide us with copies of all pleadings, motions,
and court processes related to the case. Likewise, kindly submit a quarterly Status
Report observing our standard format,
Thank you very much.
Very truly yours,
C
MANUEL Cy NA, JR.
and harge
CC: Alty. Judy Anne C. Abs
PNB Legal Group
BM Rolando C. Bacalaoloyo
Catbalogan Branchfe th.
/
b
Republic of the Philippines ad
REGIONAL TRIAL COURT
Eight Judicial Region
Branch 27
Catbalogan City, Samar
PHILIPPINE NATIONAL BANK (PNB) Civil Case No. 8071
CATBALOGAN BRANCH,
REPRESENTED BY ITS MANAGER: For:
Plaintiff,
DETERMINATION OF JUST
- versus ~ COMPENSATION
PROVINCIAL AGRARIAN REFORM
OFFICER (PARO) OF SAMAR,
GREGORIO D. FIEL, JR.,
LAND BANK OF THE PHILIPPINES (LBP),
AGRARIAN OPERATIONS
CENTER VIII, TACLOBAN CITY,
Defendants.
MOTION TO WITHDRAW
COMES NOW the undersigned counsel for the Philippine National Bank,
unto this Honourable Court, most respectfully states that, due to the resignation
of the undersigned from the Bank's service effective January 31, 2013,
undersigned respectfully requests that he be allowed by this Honourable Court to
withdraw his appearance in this case, as counsel for Philippine National Bank.
Henceforth, undersigned respectfully prays that future notices/processes
of this Honorable Court and pleadings/motions/correspondence from the
opposing party in this case be sent directly to the Bank's Head Office at Legal
Group, 9/F PNB Financial Center, Pres. Diosdado Macapagal Boulevard, Pasay
City or to any counsel who may subsequently enter his appearance for the
Philippine National Bank.
PRAYER
WHEREFORE, premises considered, undersigned counsel respectfully
prays that he be allowed to withdraw his appearance in the above-captioned
case and that future notices/processes of this Honorable Court and pleadings/
motions/correspondence from the plaintiff in this case be sent directly to theabove stated address or to any counsel who may subsequently enter his
appearance for the Philippine National Bank and that undersigned be relieved of
all his responsibilities relative to this case.
Other reliefs just and equitable under the premises are likewise prayed for.
Borongan City, Eastern Samar for Catbalogan City, Samar, January 29,
2013.
BENLY FREDERICK/C/BERGONIO
Counsel for Philippi National Bank
Real St. Songco, Borongan, Eastern Samar
Roll of Attomey No. 46919
IBP No. 836495/01-18-2012/Manila
PTR No. 0286257/01-18-2012/Eastern Samar
MCLE Compliance No. III - 0016732/May 25, 2010
NOTICE OF HEARING
The Branch Clerk of Court
Regional Trial Court
Eight Judicial Region
Branch 27
Catbalogan City, Samar
Greetings!
Please be notified that the foregoing Motion to Withdraw will be submitted
to the Honorable Court for its consideration and approval without further oral
argument and appearance of the undersigned counsel.
ATTY. BENLY FREDEI Cc. BERGONIO
COPY FURNISHED AND EXPLANATION
Atty. Antonio C. Salinas ISTRY RECEIPT
LBP Regional Office No. Vil iat :
Gor) Romes panes Ce
Cor. J. Romualdez & Sen. Enage Sts. Letter/Package NO.
Tacloban City Letra neg
this recelpt for raference in case of Inquiry
Atty. Jerome Paderes Proserve this ra :
Department of Agrarian Reform (a
Catbalogan City, SamarA copy of the Motion to Withdraw were sent to opposing counsels by
registered mail due to the distance of his address and lack of personnel to effect
personal service. (Kindly disregard explanation if served parsonelly.)
ATTY. BENLY FREDERICKIC. BERGONIO