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REPUBLIC OF THE PHILIPPINES


NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH __
MAKATI CITY

RESTITUTO D. MAGCASE, JR.,


EDWIN S. MAGCASE,
MELINA M. LICUANAN,
JOSELYN M. BRUGADA, and
ANTONIO T. MAGCASE,
Plaintiffs,

versus
Civil Case No. ____________
AMBROSE M. AZUCENA, For: Revocation/
Defendant. Cancellation of Donation

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ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTERCLAIM

Now comes the DEFENDANT Ambrose BU M. Azucena in the above-


entitled case, by his undersigned counsel, respectfully shows:

ADMISSIONS AND DENIALS

1. That Paragraphs 1, 2, 3, 4, 5, and 6 of the Complaint are admitted;

2. That Paragraph 7 of the Complaint is admitted only insofar as to the date,


age, place of death, and personal circumstances of Marino M. Magcase,
herein referred to as the DECEDENT, but that the allegation contained
therein is specifically denied for lack of information or knowledge sufficient
to form a belief as to its veracity or falsity, the truth being that, despite
allegations of the PLAINTIFFS that Bel-Air Property was included in the estate
of the DECEDENT, the Order of Branch 32 of the Regional Trial Court of San
Pablo City dated 15 November 2010 has already provided that:

On whether the Bel-Air and Alabang properties should be included in the


estate of Marino Magcase, this Court holds the view that in view of the
undisputed fact that the said properties were already disposed of during the
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lifetime of Marino Magcase and long before his death, the same should no
longer be included in the estate of the decedent for settlement among the
heirs xxx (cf. Paragraph 1, Page 2, Order dated 15 November 2010). A copy
of the Order dated 15 November 2010 is hereto attached and marked as
Annex 5 and made an integral part hereof;

3. That Paragraph 8 of the Complaint is specifically denied for being


unsubstantiated and for lack of information or knowledge sufficient to form
a belief as to the veracity or falsity of the allegation, the truth being that
stated in the Affirmative Defenses below;

4. That Paragraph 9 of the Complaint is specifically denied for being


irrelevant to the issues raised by the PLAINTIFFS;

5. That Paragraph 10 of the Complaint is specifically denied for being


unsubstantiated and for lack of information or knowledge sufficient to form
a belief as to the veracity or falsity of the allegations;

6. That Paragraphs 11, 12, and 13 of the Complaint is specifically denied for
being irrelevant to the issues raised by the PLAINTIFFS;

7. That Paragraph 14 of the Complaint is admitted only insofar as to the fact


that Guadalupe M. Azucena was the DECEDENTs last remaining surviving
sibling, but that the allegations contained therein are specifically denied for
being hearsay and for lack of information or knowledge sufficient to form a
belief as to its veracity or falsity;

8. That Paragraph 15 of the Complaint is specifically denied for being patently


false, unsubstantiated, and for lack of information or knowledge sufficient to
form a belief as to the veracity or falsity of the allegations;

9. That Paragraph 16 of the Complaint is specifically denied for being


unsubstantiated, hearsay, and for lack of information or knowledge
sufficient to form a belief as to the veracity or falsity of the allegations;

10. That Paragraph 17 of the Complaint is specifically denied for being


unsubstantiated, hearsay, and for lack of information or knowledge
sufficient to form a belief as to the veracity or falsity of the allegations;

11. That Paragraph 18 of the Complaint is specifically denied for being


patently false, self-serving, and for lack of information or knowledge
sufficient to form a belief as to the veracity or falsity of the allegations;

12. That Paragraph 19 of the Complaint is specifically denied for being


patently false, hearsay, and for lack of information or knowledge sufficient
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to form a belief as to the veracity or falsity of the allegations, the truth being
that the first time the Deed of Donation was to be executed in 2008, the
personal physician of DECEDENT Marino M. Magcase, Dra. Maria Asuncion,
averred that the best person to attest to the mental health of the DECEDENT
was a neurologist and it was precisely due to this reason that the execution
of the Deed of Donation was moved to a latter date to accommodate this
averment as laid down in the Affidavit of Judge Bienvenido V. Reyes dated 8
October 2012, and not because DECEDENT said No to the Deed of Donation
as alleged by PLAINTIFFS.

A copy of the Affidavit dated 8 October 2012 is hereto attached and marked
as Annex 3, and made an integral part hereof;

13. That Paragraph 20 is admitted only insofar as there was a recognition


that a neurologist would be the best person to attest to the soundness of
DECEDENTS mind, which was later duly complied with as evidenced by the
Affidavit of Dr. Avelino B. Siquig dated 11 February 2008, but that the
allegation contained therein is specifically denied for being misleading, and
for lack of information or knowledge sufficient to form a belief as to its
veracity or falsity.

A copy of the Affidavit dated 11 February 2008 is hereto attached and


marked as Annex 1, and made an integral part hereof;

14. That Paragraph 21 of the Complaint is admitted only insofar as to the


date of death of the DECEDENT, but allegations are specifically denied for
being unsubstantiated, self-serving, and for lack of information or knowledge
sufficient to form a belief as to its veracity or falsity;

15. That Paragraph 22 of the Complaint is specifically denied for being


irrelevant to the issues raised by the PLAINTIFFS; 16. That Paragraph 23 of
the Complaint is specifically denied for being patently false, the truth being
that PLAINTIFFS have expressly admitted that one of those they represent in
the instant Complaint, particularly Wilfredo Magcase, leases and occupies
the Bel-Air Property and acknowledges the herein DEFENDANT as owner and
lessor of the Bel-Air Property, contrary to the Complaint, as shown by a
handwritten note dated 23 February 2012, to wit:

I am sending to first 6 checks Jan, Feb, March, April, May, June 2012 for Bel-
Air rental. Will send the rest next time. xxx A copy of the handwritten note
dated 23 February 2012 is hereto attached and marked as Annex 7, and
made an integral part hereof;
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16.1 That the acknowledgment of DEFENDANTs ownership to the Bel-Air
Property is further reinforced by rental payments to the said Property,
continuously paid to the DEFENDANT, as evidenced by post-
dated checks dated November 2012 and December 2012 issued and
delivered to the herein DEFENDANT. Copies of the post-dated checks dated
3 November 2012 and 1 December 2012 are hereto attached and marked as
Annexes 8 and 9, and made integral parts hereof;

16.2 That the foregoing are patent pieces of evidence that the PLAINTIFFS
could not have been surprised by the alleged turn of events and even if
indeed they were surprised, there was a consequent recognition of the
cancellation of Transfer Certificate of Title (TCT) No. 113638 [S-22712] and
the issuance of TCT No. 225984;

17. That Paragraph 24 of the Complaint is specifically denied for being


patently false, unsubstantiated, and for lack of information or knowledge
sufficient to form a belief as to the veracity or falsity of the allegations, the
truth being that, contrary to the allegations of the PLAINTIFFS, the
DECEDENTs mental faculty, after falling ill in 2004 until his death, remained
lucid and sharp immediately even before he passed away as certified by the
Affidavit of Dr. Avelino B. Siquig dated 11 February 2008 (Annex 1), who is
a licensed physician and practicing Neurologist, to wit: On further mental
examination, I found that Mr. Magcase had lucid mental capacity as to the
execution of documents, and that he was able to understand the implications
of the same.

18. That Paragraph 25 of the Complaint is specifically denied for being


patently false, unsubstantiated, misleading, and for lack of information or
knowledge sufficient to form a belief as to the veracity or falsity of the
allegations, the truth being that PLAINTIFFS have manifestly erred in their
appreciation of the law for confusing contracts which are voidable from
contracts which are void, to wit, the Civil Code of the Philippines provides
that:

Art. 1390. The following contracts are voidable or annullable, even though
there may have been no damage to the contracting parties:xxx

(2) Those where the consent is vitiated by mistake, violence, intimidation,


undue influence or fraud. (Emphasis supplied) Verily, assuming arguendo
that the Deed of Donation suffers from having been executed and signed
under undue duress and influence from the family of the defendant, the
same is not void ab initio but is, in fact, a voidable contract, which is binding,
unless they are annulled by a proper action in court. They are susceptible of
ratification (Art. 1390, Civil Code of the Philippines).
Be that as it may, the Complaint must be dismissed for lack of cause of action;
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19. That Paragraph 26 of the Complaint is specifically denied for being


patently false, mere conclusions of fact and law, unsubstantiated, and for
lack of information or knowledge sufficient to form a belief as to the veracity
or falsity of the allegations, the truth being stated in the Affirmative Defenses
below;

20. That Paragraph 27 of the Complaint is specifically denied for being


unsubstantiated, misleading, mere conclusions of fact and law, and for lack
of information or knowledge sufficient to form a belief as to the veracity or
falsity of the allegations, the truth being that the PLAINTIFFS contradict
themselves by averring that he left no will but had substantial assets in
Paragraph 21 of their Complaint.

Moreover, the Order of Branch 32 of the Regional Trial Court of San Pablo
City dated 15 November
2010 (Annex 5) expressly provides that there are other properties that
have been discovered and which are not included in the inventory and not
mentioned in the Compromise Agreement, which proves that DECEDENT
Marino M. Magcase did have other properties and sufficient funds in his
accounts at the time of the execution of the Deed of Donation contrary to
the allegations of the PLAINTIFFS;

21. That Paragraph 28 of the Complaint is specifically denied for being


unsubstantiated, mere conclusions of fact and law, and for lack of
information or knowledge sufficient to form a belief as to the veracity or
falsity of the allegations, the truth already being stated in Paragraph 14 of
this Answer with Special and Affirmative Defenses and Counterclaim
(Answer);

22. That Paragraph 29 of the Complaint is specifically denied for being


patently false, and for lack of information or knowledge sufficient to form a
belief as to the veracity or falsity of the allegations, the truth being that it
was they who patently admitted to excusing themselves when they were
invited by DEFENDANT to visit the DECEDENT Marino M. Magcase as
evidenced by the Complaints Annexes C and D, respectively, to wit: A
few weeks after, I got another call from Bu but I declined to come to the
house of Tito Marin because I had a very bad cough xxx (Annex C) The
next time I was invited by Bu to go to Marinos house, I excused myself
because I had a previous commitment; (Annex D); Copies of the
Complaints Annexes C and D are hereto attached and marked as
Annexes C and D, respectively, and made integral parts hereof;

23. That Paragraph 30 of the Complaint is specifically denied for being


patently false, unsubstantiated, mere conclusions of fact and law,
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misleading, and for lack of information or knowledge sufficient to form a
belief as to the veracity or falsity of the allegations, the truth being stated in
the Affirmative Defenses below;

24. That Paragraph 31 of the Complaint is specifically denied for being


patently false, misleading, and for lack of information or knowledge
sufficient to form a belief as to the veracity or falsity of the allegations, the
truth being stated in the Affirmative Defenses below;

25. That Paragraph 32 of the Complaint is specifically denied for being


patently false, unsubstantiated, mere conclusions of fact and law, and for
lack of information or knowledge sufficient to form a belief as to the veracity
or falsity of the allegations, the truth being stated in the Affirmative Defenses
below;

26. That Paragraph 33 of the Complaint is specifically denied for being


patently false, unsubstantiated, hearsay, mere conclusions of fact and law,
misleading, and for lack of information or knowledge sufficient to form a
belief as to the veracity or falsity of the allegations, the truth being stated in
the Affirmative Defenses below;

27. That Paragraph 34 of the Complaint is specifically denied for being


irrelevant to the issues raised by the PLAINTIFFS;

AFFIRMATIVE DEFENSES

28. That TCT No. 225984 dated 16 February 2009 is valid by virtue of a duly
executed Deed of Donation inter vivos, with consent from the DECEDENT
Marino M. Magcase;

28.1 That the DECEDENT duly executed a Deed of Donation inter vivos dated
14 February 2008 whereby he donated his property (hereinafter referred to
as the Bel-Air Property), which was then covered by TCT No. 113638 [S-
22712] of the Registry of Deeds for the Province of Rizal, in favor of herein
DEFENDANT.

Copies of the Deed of Donation dated 14 February 2008 and TCT No. 113638
[S-22712] are hereto attached and marked as Annexes 2 and E,
respectively, and made integral parts hereof;

28.2 Copies of the Deed of Donation dated 14 February 2008 and TCT No.
113638 [S-22712] are hereto attached and marked as Annexes 2 and E,
respectively, and made integral parts hereof;
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28.3 That as a consequence of the Deed of Donation dated 14 February 2008,
the title to the said Bel-Air Property, formerly covered by TCT No. 113638 [S-
22712] (Annex E), TCT No. 225884 dated 16 February 2009 of the Registry
of Deeds of the City of Makati was issued in favor of the herein DEFENDANT.

A copy of TCT No. 225884 dated 16 February 2009 is hereto attached and
marked as Annex 6
and made an integral part hereof;

28.4 That the PLAINTIFFS allegations that the DECEDENTs only source of
income were rentals that were derived from the properties he owned in Bel-
Air and Ayala Alabang Village, and that his funds had been depleted are mere
conclusions of fact and are not substantiated by any material piece of
evidence, the truth being already stated in Paragraph 22 of this Answer;

28.5 That the PLAINTIFFS allegation that the DECEDENT orally voiced his
disapproval of donating the property is misleading, the truth being already
stated in Paragraph 12 of this Answer;

28.6 That given the relevant factual circumstances (and not the PLAINTIFFS
purported facts but which are actually malicious conjectures), wherein
DECEDENTs sister and her family bore the entire burden of caring for the
DECEDENT without any help from the PLAINTIFFS, it is apparent that
DECEDENTs motive for donating the property to DEFENDANT was not only
liberality but also gratitude for his four (4) years of unwavering service even
at the cost of DEFENDANTs career progression. DECEDENT, having been a
businessman in his lifetime, would have known that a five (5) million
property was paltry compensation for the income that DEFENDANT has had
to forego in the four (4) years he had thus far spent on caring for DECEDENT,
and in the next few years to come wherein DEFENDANT would have
continued to do so;

29. That TCT No. 225984 dated 16 February 2009 is valid by virtue of a duly
executed Deed of Donation inter vivos, notarized in line with Rule IV, Section
3, of the Notarial Practice of Law (AM No. 02-8-13 SC);

29.1 That Judge Bienvenido V. Reyes was neither donor nor donee, or a
witness, and thus cannot be considered party to the Deed of Donation. It is
apparent in the said document (Annex 2) that the donor was Marino M.
Magcase and the donee was Ambrose Bu M. Azucena, and none of the
witnesses
signatures on the left side of the documents was that of Judge Reyess;
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29.2 That, contrary to the allegation, Judge Reyes did not receive any fee in
notarizing the Deed of Donation, and no piece of evidence was brought forth
to prove such;

30. That TCT No. 225984 dated 16 February 2009 is valid by virtue of a duly
executed Deed of Donation inter vivos, in accordance with the form and
solemnities of law;

30.1 That Quilala vs. Reyes, G.R. No. 132681 (2001) provides that, the
requirement that the contracting parties and their witnesses should sign on
the left- hand margin of the instrument is not absolute. The intendment of
the law merely is to ensure that each and every page of the instrument is
authenticated by the parties.xxx Also, the specification of the location of the
signature is merely directory. In this case, the purpose of authenticating the
page is served, and the requirement of a valid donation and the signing of all
the parties to the said deed is deemed substantially complied with.

30.2 That, by virtue of the abovementioned jurisprudence, the absence of


DECEDENTs thumb mark on the second page of the Deed of Donation is of
no matter, the Deed having been validated by substantial compliance of
being duly acknowledged before a notary public and presence of sufficient
number of witnesses who duly signed the said Deed;

30.3 That Carandang-Collantes vs. Capuno, G.R. No. L-55373 (1983) provides
that, a public instrument duly acknowledged before a notary public, bears
a thumb mark which is not that of the donor, and therefore forged, fictitious
or fraudulent, it is their duty to present strong, complete and conclusive
evidence in support thereof, and not merely by preponderance of evidence,
and the testimony of the notary public who is also a lawyer is satisfactory
and must be given mere credence than the testimonies of the Capuno
witnesses which merely implied that the thumb mark on the deed of
donation was not affixed by Josefa Capuno since no deed was notarized
during her confinement at the hospital.

30.4 That, by virtue of the abovementioned jurisprudence, the PLAINTIFFS


having utterly failed to present strong, complete and conclusive evidence,
the Deed of Donation sustains the presumption of validity vested upon it; 31.
That TCT No. 225984 dated 16 February 2009 is valid by virtue of a duly
executed Deed of Donation inter vivos, the consent not being vitiated by
fraud, duress, undue influence, and other circumstances;

31.1 That Sevilla vs. Sevilla, G.R. No. 150179 (2003) provides that, [t]here is
undue influence when a person takes improper advantage of his power over
the will of another, depriving the latter of a reasonable freedom of choice.
The following circumstances shall be considered: the confidential, family,
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spiritual and other relations between the parties, or the fact that the person
alleged to have been unduly influenced was suffering from mental weakness,
or was ignorant or in financial distress,
and that the Supreme Court consistently applied the ancient rule that if the
plaintiff, upon whom rests the burden of proving his cause of action, fails to
show in a satisfactory manner facts on which he bases his claim, the
defendant is under no obligation to prove his exception or defense.

31.2; That the DECEDENTs mental weakness has already been specifically
denied and disproved in Paragraph 19 of this Answer

31.3 That given the relevant factual circumstances, DECEDENT could not be
reduced to being ignorant, being a successful businessman, and during his
lifetime, amassed numerous properties, pieces of jewelry, and shares of
stocks in various businesses, as averred in Paragraph 9 of the Complaint;

31.4 That the DECEDENTs financial distress has already been specifically
denied and disproved in Paragraph 22 of this Answer;

31.5 That, by virtue of the abovementioned jurisprudence, the DEFENDANT


could not have effected fraud or undue influence over the DECEDENT and
the allegations stating otherwise are self-serving testimonies without an iota
of evidence to prove the contrary;

31.6 That the inadvertent loss of the videotape, which was affirmatively
claimed to have recorded the said donation, is insufficient to prove fraud nor
make it a voidable donation;

31.7 That, assuming arguendo that the Deed of Donation dated 14 February
2008 was indeed vitiated by fraud, as alleged in the Complaint, it is still
susceptible of ratification as provided for by Article 1390 of the Civil Code of
the Philippines.

By the acts manifested in the handwritten note dated 23 February 2012


(Annex 7) and post- dated checks dated November 2012 and December
2012 (Annexes 8 and 9), the PLAINTIFFS have executed acts which
necessarily imply an intention to waive their right and have, therefore,
ratified the contract, and consequently extinguished the action to annul a
voidable contract as provided for by Articles 1393 and 1392 of the Civil Code
of the Philippines;

31.8 That Metropolitan Waterworks and Sewerage System vs. Court of


Appeals, 297 SCRA 287 (1998) provides that, [i]mplied ratification may take
various formslike silence or acquiescence; by acts showing approval or
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adoption of the contract; or by acceptance and retention of benefits flowing
therefrom.

31.9 That, by virtue of the abovementioned provisions of law and


jurisprudence, PLAINTIFFS have, assuming arguendo that said deed was
vitiated by fraud, ratified the contract and consequently extinguished any
action to annul a voidable contract;

31.10 That the acts manifested in the handwritten note dated 23 February
2012 and post-dated checks dated 3 November 2012 and 1 December 2012
constitute an estoppel on the part of the PLAINTIFFS as provided for by
Section 2, Rule 131, of the Rules of Court, to wit:

xxx Whenever a party has, by his own declaration, act, or omission,


intentionally and deliberately led another to believe a particular thing is true,
and to act upon such belief, he cannot, in any litigation arising out of such
declaration, act or omission, be permitted to falsify it. The tenant is not
permitted to deny the title of his landlord at the time of the commencement
of the relation of landlord and tenant between them.

31.11 That Article 1436 of the Civil Code of the Philippines also provides that,
[a] lessee or a bailee is estopped from asserting title to the thing leased or
received, as against the lessor or bailor;

31.12 That, by virtue of the abovementioned provisions of law, PLAINTIFFS


are estopped from denying the title of DEFENDANT; 29. That, moreover,
donation inter vivos may be revoked only for the reasons provided in Articles
760, 764, and 765 of the Civil Code of the Philippines; the instant Complaint,
having not alleged, much less show, any of the grounds for revocation of a
donation inter vivos, must, therefore, be dismissed for lack of cause of
action;

COMPULSORY COUNTERCLAIM

30. That due to the unwarranted and malicious filing of the instant
Complaint, the DEFENDANT suffered mental anguish, serious anxiety,
sleepless nights, and such action has besmirched his reputation for which the
PLAINTIFFS should be adjudged to pay the DEFENDANT moral damages in the
amount of Five Hundred Thousand Pesos (P500,000.00);

31. That due to the precipitate and baseless initiation by the PLAINTIFFS of
the instant Complaint, the sole ploy of which to enrich themselves at the
expense and inconvenience of the defendant, the PLAINTIFFS should be
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adjudged to pay the defendant exemplary damages in the amount of Five
Hundred Thousand Pesos (P500,000.00); and

32. That due to the PLAINTIFFS instant unwarranted and malicious


Complaint, the DEFENDANT incurred in costs of litigation and was
constrained to engage the services of legal counsel in the amount of Five
Hundred Thousand Pesos (P500,000.00).

PRAYER

WHEREFORE, it is respectfully prayed that after due hearing, judgment be


rendered as follows:

a. Ordering the dismissal of the Complaint for lack of cause of action on the
part of the PLAINTIFFS against the DEFENDANT;

b. Ordering the PLAINTIFFS to pay the DEFENDANT the sum of Five Hundred
Thousand Pesos (P500,000.00) for and as moral damages;

c. Ordering the PLAINTIFFS to pay the DEFENDANT the sum of Five Hundred
Thousand Pesos (P500,000.00) for and as exemplary damages;

d. Ordering the PLAINTIFFS to pay the defendant the sum of Five Hundred
Thousand Pesos (P500,000.00) for and as attorneys fees; and

e. Ordering the PLAINTIFFS to pay the costs of suit.

The DEFENDANT likewise prays for such other measures of relief, which this
Honorable Court may deem just and equitable in the premises.

Makati City, Philippines, 17 October 2012.


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Atty. Mark Angelo Abletis


Counsel for Defendant
ABLETIS BAYANI & BENITEZ LAW OFFICE
Unit 201, 109 L.P. Leviste St., Salcedo Village, Makati City
Tel. No.: 8882233 loc 01
Fax No.: 3335544
email address: mab.abb@law.com.ph
Roll of Attorneys No.: 0016252
IBP No.: 018921636
PTR No.: 012979361
MCLE No.: 04-29625

Atty. Camille Bayani


Counsel for Defendant
ABLETIS BAYANI & BENITEZ LAW OFFICE
Unit 201, 109 L.P. Leviste St., Salcedo Village, Makati City
Tel. No.: 8882233 loc 02
Fax No.: 3335544
email address: cb.abb@law.com.ph
Roll of Attorneys No.: 0016254
IBP No.: 018921632
PTR No.: 012979389
MCLE No.: 04-29623

Atty. Angelico Benitez


Counsel for Defendant
ABLETIS BAYANI & BENITEZ LAW OFFICE
Unit 201, 109 L.P. Leviste St., Salcedo Village, Makati City
Tel. No.: 8882233 loc 02
Fax No.: 3335544
email address: cb.abb@law.com.ph
Roll of Attorneys No.: 0016234
IBP No.: 018921678
PTR No.: 012979378
MCLE No.: 04-29656
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VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING

I, AMBROSE BU M. AZUCENA, of legal age, Filipino, with address at c/o


ABLETIS BAYANI & BENITEZ LAW OFFICE, Unit 201, 109 L.P. Leviste St.,
Salcedo Village, Makati City, after having been duly sworn in accordance
with law, do hereby depose and state that:

1. I am the defendant in the instant case;

2. I have cause the preparation of the foregoing, which I have read and
understood, the contents of which are all true and correct of my personal
knowledge and/or based on authentic records; and

3. I further certify that I have not heretofore commenced any action


involving the same issues in the Supreme Court, the Court of Appeals, or
different divisions thereof, or any other tribunal or agency; to the best of
my knowledge, no such other action or proceeding is pending in the
Supreme Court, the Court of Appeals, or different divisions thereof, or any
other tribunal or agency; and, if I should hereafter learn that a similar
action or proceeding has been filed or is pending before the Supreme
Court, the Court of Appeals, or different divisions thereof, or any other
tribunal or agency, I undertake to promptly inform this Honorable Court
within five (5) days therefrom.

AFFIANT FURTHER SAYETH NAUGHT.

AMBROSE BU M. AZUCENA
Affiant

SUBSCRIBED AND SWORN to before me this 7th day of November


2016, personally known to me as such, affiant exhibiting to me his
Passport No. EB3090290, issued in Lucena City, and valid until 18
July 2016.

Doc. No. __
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