Professional Documents
Culture Documents
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LEGAL FORMS
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LEGAL FORMS
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A Compilation
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Atty Isagani Calderon
School Year 2012-2013
1|LLB III-A
Second Semester
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LEGAL FORMS
I. AFFIDAVITS
AFFIDAVIT is a written, ex parte statement made or taken under oath before an officer of the court or a notary public
or other person who has been duly authorized so to act.
1. That I am the only surviving daughter of one, named Wilson G. Fortalejo who died
intestate in Bakakeng, Baguio City, on December 15, 2011 as evidenced by Death
Certificate issued by the Civil Registrar of Baguio City hereto attached as ANNEX “A”
and made an integral part of this Affidavit.
2. That the said deceased left deposit in the Philippine National Bank, in the amount of
Five Hundred Thousand Pesos (P500,000.00);
3. That said deceased also left a 2-bedroom condominium unit, located at #288, Twin
Towers Condominium, Leonard Wood Road, Baguio City, with an area of SEVENTY
EIGHT (78) SQUARE METERS more or less, covered by Condominium Certificate Title
No. 188521 of the Register of Deeds of Baguio City;
4. That the said deceased left no debts nor any LAST WILL AND TESTAMENT;
5. That pursuant to Rule 74, Sec. 1 of the Rules of Court, I hereby adjudicate unto myself
the above described real and personal property by means of this Affidavit and hereby
files the same with the Register of Deed of Baguio City with the request that the said
adjudication be made effective without judicial proceeding as prescribed by the
aforementioned Rules of Court.
IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of November,
2012, at Baguio City, Philippines.
_____________________
DIANNE C. FORTALEJO
Affiant
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines, this 22nd
day of November 2012, by Ms. Dianne C. Fortalejo who exhibited to me herPassport No.
CC957742, valid until February 14, 2017 as competent proof of her identity, andwho is the
same person who personally signed before me the foregoing affidavit and acknowledged that
she executed the same.
AFFIDAVIT OF SELF-ADJUDICATION
I, Jefferson U. Simeon, of legal age, Filipino, single and a resident of No. 115 Maria
Basa, Pacdal, Baguio City, Philippines, after having been duly sworn in accordance with law,
do hereby depose and say:
1. That I am the only son of Peter B. Simeon who died intestate in the City of Baguio, on
September 3, 2011 as evidenced by Death Certificate issued by the Civil Registrar of
Baguio, hereto attached as ANNEX “A” and made an integral part of this Affidavit;
2. That said deceased left an estate consisting of a parcel of land measuring ONE
THOUSAND (1,000) SQUARE METERS, located at Mary Hills Road, Loakan Proper,
Baguio City covered by Transfer Certificate Title No. CC-19876 of the Registry of Deeds
of Baguio City;
3. That the said parcel of land is more particularly described as follows to wit;
4. That the said deceased left no debts nor any LAST WILL AND TESTAMENT;
5. That pursuant to Rule 74, Section 1 of the Rules of Court, I hereby adjudicate unto
myself the above described Real Estate by means of this Affidavit and hereby files the
same with the Register of Deeds of Baguio City with the request that said adjudication
be made effective without the judicial proceeding as prescribed by the aforementioned
Rules of Court.
IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of November 2012
at Baguio City, Philippines.
____________________
JEFFERSON U. SIMEON
Affiant
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines, this 22 nd
day of November 2012, by Jefferson U. Simeon, personally known to me, who is the same
person who personally signed before me the foregoing affidavit and acknowledged that he
executed the same.
2. That she is a PAG-IBIG Fund member with an application for Provident Benefits with
the Fund;
4. That we certify that she was born at Baguio General Hospital, Baguio City Philippines,
on the 14th day of February in the year 1977 ;
5. That she has been using the said birth date in all her documents and transactions,
including her education and employment records;
6. That we are not related by affinity or consanguinity to the above mentioned person; and
7. That we are executing this affidavit to attest to the truth of the foregoing facts for record
and references purposes.
IN WITNESS WHEREOF, we have hereunto set our hands this 22nd day of November
2012, at Baguio City, Philippines.
___________________ ____________________
JONATHAN B. ABREU FLORIDA T. SOLOMON
Affiant Affiant
CTC No. 28738278 CTC No. 39824983
Issued on January 17, 2012 Issued on March 15, 2012
Issued at Baguio City Issued at Baguio City
JONATHAN B. ABREU, with Passport No. BB5593189, valid until February 14, 2016.
FLORIDA T. SOLOMON, with Passport No. SS8533100, valid until April 18, 2013.
who personally know the principal, to be the same persons who executed and personally
signed the foregoing affidavit before me and acknowledged that they executed the same.
1. That we are the parents of RENESSMEE S. NAVARRO, who is 10 years old and a
citizen of the Republic of the Philippines and a holder of valid Philippine Passport with
No. NN3311221 and who is going for a trip abroad specifically to Washington DC, USA
this December 15, 2012;
2. That we are giving our full consent to our said daughter to travel abroad or specifically
to Washington DC, USA;
3. That for this purpose, we have sufficient and adequate financial capacity to support and
defray the said travel and do hereby undertake to finance her trip abroad from the
application fees, airline tickets, board and lodging, pocket money and such other
expenses that she may incur so that she would neither be a burden to the state nor at
their place of destination at any time during his trip abroad;
4. That there is no criminal case pending in court against her nor has she been charged of
subversion, rebellion, insurrection or any crime or offense involving moral turpitude in
any court of the Philippines;
7. That we are executing this affidavit to declare the truth of the foregoing facts and for
whatever legal purpose it may serve.
IN WITNESS WHEREOF, we have hereunto set our hands this 22nd day of November
2012 in the City of Baguio, Philippines.
______________________________ ________________________
EDWARD JACOB C. NAVARRO ISABELLA MARIE S. NAVARRO
Affiant Affiant
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines, this 22nd
day of November 2012, by affiants, who have satisfactorily proven their identity through Kate
Mercedes Estanillo, who is personally known to me and who personally knows the principal,
that they are the same persons who executed and personally signed the foregoing affidavit
before me and acknowledged that they executed the same.
AFFIDAVIT OF DESISTANCE
I, GIOVANNI D. CONSTANTE, single, of legal age, Filipino citizen, with residence and
postal address at #35 Cabinet Hill, Baguio City, after having been duly sworn in accordance
with law, do hereby depose and state:
1. That I am the Private Complainant in Criminal Case No. 35667-R for violation of B.P.
Blg. 22 otherwise known as the Bouncing Checks Law now pending before the Regional
Trial Court, Baguio City, Branch 3;
2. That the accused Heribert Z. Fernandez has settled his obligations with me to my full
satisfaction;
3. That due to the aforementioned reason, I freely and voluntarily pray for the FINAL
DISMISSAL of the case against Heribert Z. Fernandez;
5. That I am now requesting the Office of the City Prosecutor of Baguio City and the
Honorable Court, Regional Trial Court, Branch 3 of Baguio City to have the case
withdrawn againstHeribert Z. Fernandez;
6. That I am executing this Affidavit of Desistance to attest to the truth of all the foregoing
facts, as well as, to withdraw my complaint againstHeribert Z. Fernandez, and
ultimately have the case against him be dismissed.
IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of November
2012, in the City of Baguio, Philippines.
_______________________
GIOVANNI D. CONSTANTE
Affiant / Private Complainant
Passport No. GG8553422
CERTIFICATION
This is to certify that I have personally examined the affiant and I am convinced that he
voluntarily executed his statement and understood the contents thereto.
___________
William Vargas
Public Prosecutor
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines, this 22nd
day of November 2012, by Giovanni D. Constante, personally known to me, who is the same
person who personally signed before me the foregoing affidavit and acknowledged that he
executed the same.
FLOR-ANN A. CAJAYON
Notary Public
Until December 31, 2014
3F Piao Yan Bldg., Bonifacio St., Baguio City
Tel. No: (074) 434-9870
PTR No. 98765; 1/03/2013; Baguio City
IBP OR No.: 98567; 1/03/13; Baguio City
1. That in my Certificate of Live Birth as recorded in the Office of the Civil Registrar of
Baguio City, Philippines and Secondary Student Permanent Record at Baguio City
National High School, it is stated that I was born on 10 November 1990 at Notre Dame
Hospital, Baguio City, Philippines;
2. That my relatives, acting on the honest belief that I was born on 10 November 1991,
had used 10 November 1991 as my birth date in all pertinent school records when they
processed my enrollment at University of the Cordilleras in Baguio City;
4. That I am executing this Affidavit of Discrepancy to attest to the truth of the foregoing
facts and to explain the discrepancy in my Certificates of Live Birth, Secondary Student
Permanent Record Transcript of Records and Voter Registration Form as regards to my
date of birth;
5. Further, I am declaring that from this date hereon I would be using my true and correct
date of birth of 10 November 1990 in all my papers, records and other documents; and
6. That I am executing this affidavit to attest to the truth of the foregoing facts for record
and references purposes.
SUBSCRIBED AND SWORNto before me, in the City of Baguio, Philippines, this 23rd
day of November 2012, affiant exhibiting to me her Community Tax Certificate with number
28624717 issued on May 7, 2012 at Baguio City and whom I have identified through her Postal
ID with number 519346, valid until August 10, 2015 to be the same person who executed the
foregoing affidavit and who certified that she executed the same based on her voluntary act
and deed.
FLOR-ANN A. CAJAYON
Notary Public
Until December 31, 2014
3F Piao Yan Bldg., Bonifacio St.,
Baguio City
Doc. No. 6; Tel. No: (074) 434-9870
Page No. 1; PTR No. 98765; 1/03/2013; Baguio City
Book No. I; IBP OR No.: 98567; 1/03/13; Baguio City
Series of 2012 Roll of Attorney’s No. 317120; 3/18/2004
Commission Serial No.: 56-NC-12 ®
MCLE Compliance No.: IV-36286; 4/28/12
TIN No: 226-753-759
2. That however, in the said Certificate of Live Birth, the date of marriage of my parents
was erroneously written as "May 8,1960” instead of the true and correct date May 28,
1960" as evidenced by the Certificate of Marriage of my parents issued by the Civil
Registrar of Baguio City, hereto attached as Annex "A";
3. That said discrepancy in my Certificate of Live Birth was an error done inadvertently;
4. That I execute this Affidavit of Discrepancy to attest to the truth of the foregoing facts.
IN WITNESS WHEREOF, I have hereunto set my hand this 23rd day of November 2012,
in the City of Baguio, Philippines.
_________________________
EOWYN ROSE D. MADRINGAL
Affiant
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines, this 23rd
day of November 2012, by Eowyn Rose D. Madringal who presented to me her Social Security
System Card No. 179-444-885 as competent proof of her identity, and who is the same person
who personally signed before me the foregoing affidavit and acknowledged that she executed
the same.
FLOR-ANN A. CAJAYON
Notary Public
Until December 31, 2014
3F Piao Yan Bldg., Bonifacio St.,
Baguio City
Tel. No: (074) 434-9870
PTR No. 98765; 1/03/2013; Baguio City
Doc. No. 7; IBP OR No.: 98567; 1/03/13; Baguio City
Page No. 1; Roll of Attorney’s No. 317120; 3/18/2004
Book No. I; Commission Serial No.: 56-NC-12 ®
Series of 2012 MCLE Compliance No.: IV-36286; 4/28/12
TIN No: 226-753-759
1. That in my Certificate of Live Birth as recorded in the Office of the Civil Registrar of
Baguio City, Philippines, my middle name was erroneously written as “TILEDO” instead
of my true and correct middle name of “TOLEDO”;
2. That my true middle name is “TOLEDO”; as appearing in the same Certificate of Live
Birth as the maiden name of my mother;
3. That in all pertinent documents which I had used, to include that of my scholastic
records (transcript of records), I used my true and correct middle name of “TOLEDO”
4. That I am executing this Affidavit of Discrepancy to attest to the truth of the foregoing
facts and to explain the discrepancy in my Certificates of Live Birth, as regards my true
middle name.
IN WITNESS WHEREOF, I have hereunto set my hand this 23rd day of November 2012,
in the City of Baguio, Philippines.
_________________________
PEREGRIN TOLEDO MARCOS
Affiant
CTC No. 35791225
Issued on March 15, 2012
Issued at Baguio City
FLOR-ANN A. CAJAYON
Notary Public
Until December 31, 2014
3F Piao Yan Bldg., Bonifacio St.,
Baguio City
Tel. No: (074) 434-9870
PTR No. 98765; 1/03/2013; Baguio City
Doc. No. 8;
IBP OR No.: 98567; 1/03/13; Baguio City
Page No. 1;
Roll of Attorney’s No. 317120; 3/18/2004
Book No. I;
Commission Serial No.: 56-NC-12 ®
Series of 2012
MCLE Compliance No.: IV-36286; 4/28/12
TIN No: 226-753-759
1. That on October 25, 2007 I was issued a Philippine Passport with passport number
MM8874321 in which my true surname MONTERRAS was stated;
2. That before the expiration of the aforementioned passport on October 25, 2012, I had
applied with Philippine Embassy in Manila for the issuance of a new passport and on
November 5 2012, I was issued a new Philippine passport with passport no.
MM4332211;
3. However, in the said new passport my surname had been erroneously misspelled as
“MONTERRASAS” instead of “MONTERRAS”;
4. That I execute this Affidavit of Discrepancy to attest to the truth of the foregoing facts
and to explain the discrepancy in my Philippine Passport with regards my surname.
IN WITNESS WHEREOF, I have hereunto set my hand this 23rd day of November,
2012, at Baguio City, Philippines.
___________________________
DANIEL MCABEE MONTERRAS
Affiant
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines, this 23rd
day of November 2012, by Mr. Daniel McAbee Monterras who exhibited to me his Postal ID
No. 4082351, valid until September 11, 2015 as competent proof of his identity, and who is the
same person who personally signed before me the foregoing affidavit and acknowledged that
he executed the same.
AFFIDAVIT OF GUARDIANSHIP
I, MARJORIE M. BALITNANG, of legal age, Filipino citizen, widow and presently
residing at #100-B City Camp Alley Extension, Baguio City, Philippines, having been duly
sworn to in accordance with law, do hereby depose and say:
1. That I am the mother of the minor named below who have an interest in the PAG-IBIG
provident benefits of my late husband SHERWIN K. BALITNANG payable by the PAG-
IBIG Fund;
4. That I am competent to receive in behalf of the said minor any amounts due her; and
IN WITNESS WHEREOF, I have hereunto set my hand this 23rd day of November, 2012,
at Baguio City, Philippines.
_______________________
MARJORIE M. BALITNANG
Affiant
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines, this 23rd
day of November 2012, by MARJORIE M. BALITNANG, who has satisfactorily proven her
identity to me through her Tax Identification Number (TIN) 112-333-478 that she is the same
person who personally signed the foregoing affidavit before me and acknowledged that she
executed the same.
AFFIDAVIT OF ILLEGITIMACY
I, RUTHCELLE M. BALUNGGAY, single, of legal age, Filipino citizen, with residence
and postal address at #18 Everlasting St., Upper Q.M., Baguio City, Philippines, having been
duly sworn in accordance with law, do hereby depose and state that:
1. I am the biological mother of Cherry Kaye B. Pamittan, who was born on March 23
2002, at St. Paul Hospital, and who is a resident of Enrile, Cagayan. Attached hereto
and made as integral part hereof is an NSO copy of the birth certificate of my child.
2. That as appearing in the records of Office of the Civil Registrar of the Municipality of
Enrile, Province of Cagayan, Philippines, the father of the said child is Edwin G.
Pamittan, who is a Filipino citizen. The same is certified by the attached Certificate of
Live Birth of the said child.
3. That I hereby affirm and attest to the truth of the fact that the father of the above-
mentioned child is indeed Edwin G. Pamittan.
4. That at the time my child was born, I was not legally married to her biological father, nor
am I legally married to the said father now. Attached is a copy of a Certificate of No
Marriage and made an integral part hereof.
5. This Affidavit is being executed in order to attest to the truth of the foregoing facts and
for whatever purpose it may serve.
IN WITNESS WHEREOF, I have hereunto set my hand this 27th day November 2012, in
the City of Baguio, Philippines.
______________________________
RUTCHELLE M. BALUNGGAY
Affiant
SUBSCRIBED AND SWORN to before me in the City of Baguio, Philippines, this 27th
day of November 2012, by Rutchelle M. Balunggay, who has satisfactorily proven her identity
to me through her Non-Professional Driver’s License No. 19412195 valid until August 30,
2013, and that she is the same person who personally signed the foregoing affidavit before me
and acknowledged that she executed the same.
AFFIDAVIT OF LEGITIMATION
We, the spouses JONATHAN D. QUIZZAGAN and JHAYNE B. USON-QUIZZAGAN,
both of legal age, Filipinos, with residence and postal address at #47 Quisumbing St.,
Trancoville, Baguio City, Philippines, having been duly sworn in accordance with law, do
hereby depose and state that:
2. Out of our relationship was born a son on March 3, 2011 whom we named
NATHANAEL AEOMER;
3. As our son was born out of wedlock, he is considered illegitimate and he bears the
family name of his mother which is USON;
4. We subsequently got married on August 22, 2012 at St. Joseph Parish Church in
Pacdal, Baguio City as evidenced by our Certificate of Marriage;
5. At the time of the birth of our child, NATHANAEL AEOMER, we possessed all the
qualifications and none of the disqualifications to marry each other;
6. As a result of our marriage, the status of our child is legitimized and as such, he shall
now bear the family name of his father which is QUIZZAGAN;
7. We execute this affidavit to attest to the truth of the foregoing statements and for the
purpose of causing the legitimation of the status of our child, NATHANAEL AEOMER
and for all legal intents and purposes this may well serve;
IN WITNESS WHEREOF, we hereunto set our hands this 27th day of November, 2012 in
the City of Baguio, Philippines.
________________________ __________________________
JONATHAN D. QUIZZAGAN JHAYNE B. USON-QUIZZAGAN
Affiant Affiant
Passport No. JJ8822089 Passport No. QQ7644120
Valid until December 21, 2015 Valid until March 3, 2017
SUBSCRIBED AND SWORN to before me this 27th day of November, 2012 at Baguio
City, Philippines, the affiants personally appearing and exhibiting to me their Passport
numbers indicated below their names as proof of their identities, and that they are the same
person who personally signed the foregoing affidavit before me and acknowledged that they
executed the same.
MAE ABEGAIL I. TABUZO
Notary Public
Until December 31, 2014
RM1 Jose de Leon Bldg. Session Rd., Baguio City
(074)3041162/+639433600748
Doc. No. 9; Roll of Atty. No. 33214/05-21-10
Page No. 1; PTR No. 0655218/ Baguio City/01-04-2013
Book No. I; IBP Lifetime Membership No. 805954/ 01-6-10 Baguio-Benguet
Series of 2012 Commission Serial No.79-NC-07(R)
MCLE COMPLIANCE NO.II-00003456/01-04-2013
TIN: 264-602-447`
Atty Isagani Calderon 17 | L L B I I I - A
School Year 2012-2013 Second Semester
LEGAL FORMS
REPUBLIC OF THE PHILIPPINES}
DONE: IN THE CITY OF BAGUIO } S.S.
x ------------------------------------------- x
1. That I was issued by the Department of Foreign Affairs a passport sometime on 2009
which shall expire on 2014;
2. That I have always kept the same inside the topmost part of my bedside table drawer;
3. However, when I looked for it on October 25, 2012 as I intend to spend the upcoming
Christmas holiday in Brussels, I could not find it ;
4. That diligent efforts were exerted to recover the said passport but the same proved
futile and fruitless;
5. That the said passport was lost in the manner stated above and was not confiscated
nor cancelled by the issuing agency or other agencies for violation of any of its terms
and conditions, laws, rules and regulations;
6. That I am now executing this affidavit to attest to the veracity of the foregoing
narration for securing a replacement of the said lost passport and for all legal intents
and purposes it may serve.
IN WITNESS WHEREOF, I have hereunto set my hand this 27th day November 2012, in
the City of Baguio, Philippines.
_______________________
FRANCO N. DE MARCO
Affiant
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines, this 27th
day of November 2012, by Franco N. De Marco, who has satisfactorily proven his identity to
me through his Professional Driver’s License No. 80521731 valid until July 19, 2013, and that
he is the same person who personally signed the foregoing affidavit before me and
acknowledged that he executed the same.
I, NATY B. SICCO, of legal age, Filipino Citizen, married and currently residing at # 12-
D Balacbac Rd., Sto. Tomas Proper, Baguio City, Philippines, having been duly sworn in
accordance with law, do hereby depose and state:
1. That I availed of an Automated Teller Machine (ATM) card from the Land Bank of the
Philippines last September 26, 2011 as a requisite for the delivery and receipt of my
retirement pension from the Social Security System (SSS);
2. That I have always kept said ATM card in my purse and that I bring my purse wherever I
go;
3. That last October when I travelled from Baguio to Manila, my purse was misplaced, and
consequently, I lost my Land Bank ATM card along with my senior citizen ID and other
things ;
4. That diligent efforts were exerted to recover the said ATM card but the same proved
futile and fruitless;
5. That the said ATM card was lost in the manner stated above and was not confiscated
nor cancelled by the issuing bank for violation of any of its terms and conditions, laws,
rules and regulations;
6. That I am now executing this affidavit to attest to the veracity of the foregoing narration
for securing a replacement of the said lost ATM card and for all legal intents and
purposes it may serve.
IN WITNESS WHEREOF, I have hereunto set my hand this 27th day of November 2012,
in the City of Baguio, Philippines.
____________________
NATY B. SICCO
Affiant
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines, this 27th
day of November 2012. Affiant personally appeared and exhibited to me her Community Tax
Certificate bearing the No. 22256675 issued on May 28, 2012 at Baguio City, Philippines, and
who has satisfactorily proven her identity through JESSA MAE B. HORTELANO, who is
personally known to me and who personally knows the principal, that she is the same person
who executed and personally signed the foregoing affidavit before me and acknowledged that
she executed the same.
1. That I am the President and Chief Executive Officer of Field Crest Real Estate Planning
and Development, Inc., a corporation duly organized and existing under the laws of the
Philippines, with principal office at Unit 4F,4th Floor Yorkshire Building, Legarda Rd.,
Baguio City, Philippines;
2. That said corporation was incorporated on June 14, 2009 and acquired by the
undersigned with the purchase of its corporate property in the above address sometime
in July 2010 but has not yet commenced its operations in view of the slump in the real
estate industry in the country;
3. That the stockholders and directors of the corporation are contemplating on reviving its
operations in the near future when the opportune time comes;
4. That this affidavit is being executed in order to attest to the truth of the foregoing
circumstances and for the purpose of complying with the reportorial requirements of the
Securities and Exchange Commission.
IN WITNESS WHEREOF, I have hereunto set my hand this 27th day of November 2012, in
the City of Baguio, Philippines.
______________________
JENNY LISA M. BALAWAN
Affiant
TIN: 443-511-214
SUBSCRIBED AND SWORN to before me, in the City of Baguio this 27thday of
November 2012, by Jenny Lisa M. Balawan, who has satisfactorily proven her identity through
JEANETTE B. UBA, who is personally known to me and who personally knows the principal,
that she is the same person who executed and personally signed the foregoing affidavit before
me and acknowledged that she executed the same.
AFFIDAVIT OF NON-TENANCY
I, CHARLOTTE M. LAPPAO,married to ROBERT B. LAPPAO,of legal age, Filipino
citizen, and with residence and postal address at 135-A KM. 5, Balili, La Trinidad, Benguet,
under oath hereby depose and state that:
Beginning at the point marked “1” of lot no. 7189, Cad 743-
D, La Trinidad Cadastre being S. 60-02 E., 7,466.42 m. from
BLLM NO. 1, Cad 743-D, La Trinidad Cadastre, La Trinidad,
Benguet thence:
2. I have been planting vegetables in this land area since the 1980’s and have devoted all
portions of it for Agricultural purposes;
4. I am executing this affidavit to attest to the truth of the foregoing, to satisfy the
requirements of the proper government agencies and private institutions, and for all
legal intents and purposes that it may serve.
IN WITNESS WHEREOF, I have hereunto set my hand this 28th day of November 2012, at
La Trinidad, Benguet, Philippines.
__________________________
CHARLOTTE M. LAPPAO
Affiant
CTC No. 11289947
Issued on January 28, 2012
Issued at La Trinidad, Benguet
AFFIDAVIT OF TRANSFEREE
I, EUNICE B. MATUTE, single, of legal age, Filipino citizen and a resident of # 21
Green Valley Village, Baguio City, Philippines, after having been sworn to in accordance with
law, do hereby depose and state that:
1. My total aggregate landholdings, including the parcel of land containing a land area of
ONE HUNDRED TWENTY (120) SQUARE METERS, located at Buhaw, Puguis, La
Trinidad, Benguet, that I acquired from CHERRY G. DICANG, thru a Deed of Absolute
Sale of a Registered Land covered by Doc. No. 27; Page No. 6; Book No. I; Series of
2012 of the Notarial Registry of Atty. BRYAN M. CHOA of Baguio City, Philippines,
dated May 25, 2012, does not exceed FIVE (5) hectares;
IN WITNESS WHEREOF, I have hereunto set my hand this 28th day of November 2011, in
the City of Baguio, Philippines.
__________________
EUNICE B. MATUTE
Affiant
SUBSCRIBED AND SWORN to before me, in the City of Baguio this 28thday of
November 2012, by affiant, who has satisfactorily proven her identity to me through her
Professional Driver’s License No. B21-082105 valid until July 23, 2013, that she is the same
person who personally signed the foregoing affidavit before me and acknowledged that she
executed the same.
AFFIDAVIT OF TRANSFEROR
I, KRISTINA CASSANDRA C. MONTEJO, single, of legal age, Filipino citizen and a
resident of #78-D Guisad, Surong Ext., Baguio City, Philippines, after having been sworn to in
accordance with law, do hereby depose and state that:
1. My total aggregate landholdings, including that parcel of land containing a land area of
ONE HUNDRED (100) SQUARE METERS, located at Tuding, Itogon Benguet, that I
sold to JASMINE ANNE ROSALES, thru a Deed of Absolute Sale of a Registered Land
covered by Doc. No. 12; Page No. 2; Book No. I; Series of 2012 of the Notarial Registry
of Atty. GERALD A. GERONIMO of Baguio City, Philippines, dated April 21, 2012, does
not exceed FIVE (5) hectares;
IN WITNESS WHEREOF, I have hereunto set my hands this 28th day of November 2012, in
the City of Baguio, Philippines.
________________________________
KRISTINA CASSANDRA C. MONTEJO
Affiant
TIN: 888-327-911
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines, this 28th
day of November 2012, by Kristina Cassandra C. Montejo, who has satisfactorily proven her
identity through:
Judy Ann Pecson, with Passport No. DD5353221, valid until February 14, 2017.
Kathryn Maghirang, with Passport No. KK8889878, valid until April 18, 2014.
who personally know the principal, to be the same person who executed and personally signed
the foregoing affidavit before me and acknowledged that she executed the same.
2. On October 25, 2012, I executed an Affidavit of Ownership and Loss with Undertaking
and filed the same with the National Telecommunication Commission to authorize said
commission and all CMTS to block the said GSM handset for the reason that said
cellphone was stolen from me by unidentified person/s during a trip to Boracay;
3. However, on November 25, 2012, I was able to retrieve said GSM handset through a
common friend;
5. I hereby undertake to hold free from any responsibility or shall not hold NTC and the
above-mentioned carriers liable for whatever claims, loss or damages or any party may
institute by reason of NTC’s action to unblock the afore-mentioned unit;
7. I am executing this affidavit to attest to the truth of the foregoing facts and for whatever
legal intents and purposes it may serve.
IN WITNESS WHEREOF, I have hereunto set my hand this 28th day of November 2012 in
the City of Baguio, Philippines.
__________________________
NIKKI MAY A. MAGTALAS
Affiant
Passport No. NN1245899
1. That I am the true and absolute owner of the following personal properties, to wit:
Motor Vehicle
MAKE/TYPE ………………… Toyota Hi-lux Pick-up
MOTOR NO…………………. 5L52-BHND5337
CHASSIS NO…………………. NNCKSLC919E112997
PLATE NO…………………….. CDY-114
Personal Computer
MAKE/TYPE ………………… Acer emachines Netbook
SPECIFICATIONS:
LED LCD ……………………. 10.1”
CPU ………………………….. Intel Atom N455
DDR3 Memory ……………… 2 GB
HDD ………………………….. 500 GB
Li-ion Battery ………………… 8-cell
2. That I intend to deliver the said personal properties as a collateral to secure the loan
that I am applying for from Maryhill Credit and Loans Cooperative;
3. That I hereby warrant title and ownership over the above-mentioned personal properties
and I will defend the possession of the Pledge from eviction;
IN WITNESS WHEREOF, I have hereunto set my hand this 28th day of November, 2012, at
Baguio City, Philippines.
___________________________
CHRISTOPHER L. KWAN
Affiant
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines, this 28th
day of November 2012, by Mr. Christopher L. Kwan who exhibited to me his Professional
Driver’s License No. NC-9875442, valid until June 2, 2013 as competent proof of his identity,
and who is the same person who personally signed before me the foregoing affidavit and
acknowledged that he executed the same.
NOEL A. SISON
Notary Public
Until December 31, 2013
2nd Floor, Salcedo Building
Legarda Road, Baguio City
Tel. No.: (074) 442-1212
PTR No. 7221425, 02-01-08
IBP O. R. No. 649932, 01-03-97
Roll of Attorney No. 111, 04-22-92
Doc. No. 20;
Commission Serial No. 87-LV-12
Page No. 1;
MCLE Compliance No. 7222, 01-03-12
Book No. I;
TIN 288-456-789
Series of 2012
AFFIDAVIT OF PUBLICATION
I, BERNADETH GIANNE T. CENZON, single, of legal age, Filipino citizen, with
residence and postal address at No. 75 Lower Liwanag, Loakan, Baguio City, Philippines, after
having been duly sworn in accordance with law, do hereby depose and say:
2. That the notice in the exact form annexed was published in the regular issues of the
Midland Courier which was regularly distributed to its subscribers during the period
stated in the annexed Notice of Judicial Settlement of the Estate of Jenson V. Segoma;
3. That the notice was published on September 30, October 7 and 14, 2012;
4. That the amount of the fee charged in the foregoing publishing in the amount of
Php3,000.00 has been paid in full.
IN WITNESS WHEREOF, I have hereunto set my hand this 29th day of November 2012, in
the City of Baguio, Philippines.
_______________________________
BERNADETH GIANNE T. CENZON
Affiant
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines, this 29th
day of November 2012, by Ms. Bernadeth Gianne T. Cenzon who exhibited to me herSSS ID
No. 77453219, as competent proof of her identity, andwho is the same person who personally
signed before me the foregoing affidavit and acknowledged that she executed the same.
NOEL A. SISON
Notary Public
Until December 31, 2013
2nd Floor, Salcedo Building
Legarda Road, Baguio City
Tel. No.: (074) 442-1212
PTR No. 7221425, 02-01-08
IBP O. R. No. 649932, 01-03-97
Doc. No. 21;
Roll of Attorney No. 111, 04-22-92
Page No. 1;
Commission Serial No. 87-LV-12
Book No. I;
MCLE Compliance No. 7222, 01-03-12
Series of 2012
TIN 288-456-789
AFFIDAVIT OF SUPPORT
I, DOMINIC T. FUENTEBELLA, married to LETTY CASSIE R. FUENTEBELLA, of legal
age, former Filipino citizen, now a U.S. citizen, with permanent address at 335 Lexington
Avenue, New York, USA and temporary Philippine address at # 28 Quezon Hill, Baguio City,
Philippines, after having been sworn to in accordance with law, do hereby depose and state
that:
1. I am the brother of MIA LORIE T. FUENTEBELLA, with pending application for Student
Visa with the Department of Immigration and Citizenship of Canada;
2. I am willing to extend my whole hearted support for her studies in Canada, I being her
brother and have the financial capability to provide all her needs during the period of her
studies;
6. I shall provide any other support that she may need other than money should it be
necessary or as maybe further required by the Canadian Government during the period
of her studies in said country;
7. I am executing this affidavit to attest the truth of the foregoing facts and to support the
application of MIA LORIE T. FUENTEBELLA, my sister, for the issuance of her student
visa and for all legal intents this affidavit may lawfully serve.
IN WITNESS WHEREOF, I have hereunto set my hand this 29th day of November 2012, in
Baguio City, Philippines.
___________________________
DOMINIC T. FUENTEBELLA
Affiant
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines, this 29th
day of November 2012, by Mr. Dominic T. Fuentebella who exhibited to me hisPassport No.
DD1478998, valid until February 14, 2017 as competent proof of his identity, andwho is the
same person who personally signed before me the foregoing affidavit and acknowledged that
he executed the same.
NOEL A. SISON
Notary Public
Until December 31, 2013
2nd Floor, Salcedo Building
Legarda Road, Baguio City
Tel. No.: (074) 442-1212
PTR No. 7221425, 02-01-08
IBP O. R. No. 649932, 01-03-97
Roll of Attorney No. 111, 04-22-92
Doc. No. 22; Commission Serial No. 87-LV-12
Page No. 1; MCLE Compliance No. 7222, 01-03-12
Book No. I; TIN 288-456-789
Series of 2012
AFFIDAVIT OF TRANSFER
We, GINNY W. MARTIN, single, of legal age, Filipino citizen, and with residence and
postal address at #21 Monterrazas Village, Itogon, Benguet and HARRY JAMES P. GUZMAN,
single, of legal age, Filipino citizen, and with residence and postal address at #95 PNB Village,
Marcos Highway, Baguio City, after having been duly sworn in accordance with law, do hereby
depose and state that:
1. The land I,GINNY W. MARTIN, sold in favor of HARRY JAMES P. GUZMAN, with an
area of ONE HUNDRED FORTY (140) SQUARE METERS more or less, located at
West Buyagan, La Trinidad, Benguet by virtue of that Absolute Deed of Sale of
Registered Land entered as Doc. No. 10; Page No. 2; Book No. I; Series of 2012, of the
Notarial Registry of Atty. HERMIONE G. QUINTIN of Baguio City, Philippines, dated
April 21, 2012 is my retention area of not more than five (5) hectares;
2. I, HARRY JAMES P. GUZMAN, own an aggregate landholding, including the land area
of ONE HUNDRED FORTY (140) SQUARE METERS that I am acquiring from GINNY
W. MARTIN, which is not more than five (5) hectares;
3. That this affidavit is executed in compliance with the DAR Administrative Order No. 01,
Series of 1989 as well as to show proof that the land subject of the above-mentioned
transaction is a retention area or portion of a retention area not exceeding five (5)
hectares.
IN WITNESS WHEREOF, we have hereunto set our hands this 29th day of November
2012, in the City of Baguio, Philippines.
__________________ _________________________
GINNY W. MARTIN HARRY JAMES P. GUZMAN
Affiant Affiant
SUBSCRIBED AND SWORN to before me, in the City of Baguio this 29th day of
November 2012, by Ginny W. Martin and Harry James P. Guzman, who has satisfactorily
proven their identities through:
Ginny W. Martin, with Passport No. WW441245, valid until June 2, 2015.
Harry James P. Guzman, with Professional Driver’s License No. GH-778942, valid until April
18, 2013.
andwho are the same persons who personally signed before me the foregoing affidavit and
acknowledged that they executed the same.
AFFIDAVIT OF WARRANTY
I, SHANE STEVEN F. GARCIA, Filipino citizen, of legal age, single, and a resident of
#43 St. Patrick Subd., San Carlos Heights Baguio City, Philippines, after having been duly
sworn in accordance with law, do hereby depose and say:
1. That I am the actual buyer of that motor vehicle which is specifically described as
follows:
Motor Vehicle
MAKE/TYPE ………………… Honda Civic
MOTOR NO…………………. 27M89-MMND7213
CHASSIS NO…………………. KLMDBCW721D121253
PLATE NO…………………….. CDY-114
2. That the fact of purchase is evidenced by that Deed of Sale of Motor Vehicle dated
August 21, 2012 whereby HOWIE D. MANZANO is the vendor and I am the vendee as
entered in the notarial register of Atty. LEE RYAN MERCEDES as Doc. No. 14, Page
Atty Isagani Calderon 31 | L L B I I I - A
School Year 2012-2013 Second Semester
LEGAL FORMS
No. 3, Book No. 1 , and Series of 2012, a copy of said Deed of Sale is hereto attached
for reference;
3. That I hereby attest to the authenticity of said Deed of Sale and the genuineness of the
transaction and in furtherance thereof, I hereby release the officers and staff of the Land
Transportation Office from any liability which may occur in the event that there is any
flaw or legal infirmities in said transaction;
4. That I am executing this affidavit in order to attest to the veracity of the foregoing
circumstances and as a warranty on the authenticity and genuineness of the above
mentioned transaction.
IN WITNESS WHEREOF, I have hereunto affixed my signature this day of 29th day of
November 2012 at Baguio City, Philippines.
_________________________
SHANE STEVEN F. GARCIA
Affiant
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines, this 29th
day of November 2012, by SHANE STEVEN F. GARCIA, who has satisfactorily proven his
identity to me through his Professional Driver’s License No. 9877442 that he is the same
person who personally signed the foregoing affidavit before me and acknowledged that he
executed the same.
AFFIDAVIT OF WITHDRAWAL
I, MARIO H. NALITO, of legal age, Filipino, single and a resident of No. 36 City
Camp, Baguio City, Philippines, having been duly sworn in accordance with law, hereby
depose and state:
1. That I filed my candidacy for Kagawad in our barangay for this coming Barangay
Election to be held on September 2, 2010;
3. That since I had changed my plan and not to run as Barangay Kagawad, I am now
withdrawing my candidacy for Barangay Kagawad;
IN WITNESS WHEREOF, I hereunto affix my signature this 18th day of October 2010 at
Baguio City, Philippines.
MARIO H. NALITO
Affiant
SUBSCRIBED AND SWORN to before me in the City of Baguio this 18th day of October
2010, MARIO H. NALITO, who has satisfactorily proven his identity to me through competent
evidence of identity, provided below his name, that he is the same person who personally
signed the foregoing affidavit before me and acknowledged that he executed the same.
UNILATERAL DEED/CONTRACT
-vendee assumes no obligation
- no need for the vendee or the other party to sign the deed/contract nor the acknowledgment therefore
BILATERAL DEED/CONTRACT
- vendee obliged to do something
- vendee or the other party must sign both the deed and the acknowledgment
CARLO K. KITAWA, single, of legal age, Filipino Citizen, with residence address at #859
Honeymoon, Baguio City, Philippines, hereinafter called the VENDEE;
WITNESSETH THAT:
The VENDORS are the owners of a certain unregistered parcel of land situated at Sabkil,
Loacan, Itogon, Benguet, Philippines and more specifically described as follows, to wit:
BOUNDARIES:
NORTH: Lot 2 SOUTH: Lot 2052
EAST : Lot 1 WEST : Lot 4
KIND: Camotal Land
AREA: 4.6961 ha.
MARKET VALUE: Php 72,500.00
ASSESSED VALUE: Php 18,900.00
The VENDORS decide to sell a portion of the above-described unregistered land including all
the improvements therein to herein VENDEE;
For and in consideration of the total sum of ONE HUNDRED SIXTY THOUSAND PESOS
(Php160,000.00) ONLY, PHILIPPINE CURRENCY, paid by the VENDEE to the VENDORS, the
1. That upon signing of this Conditional Deed of Sale, the VENDEE shall pay SIXTY
THOUSAND PESOS (Php60,000.00), as downpayment;
3. That upon receipt of the Bank Guarantee in favor of the VENDOR, the latter shall
execute an Absolute Deed of Sale in favor of the VENDEE;
4. That failure to pay the balance shall cause the automatic rescission of this Contract with
damages in the amount of FIFTY THOUSAND PESOS (Php50,000.00);
5. That the realty taxes and special assessments on the subject property on or before the
date of sale, cost of operation of the documents of sale, and notarial fees shall be for
the account of the VENDOR; while those realty taxes that shall accrue after the date of
this Conditional Deed of Sale, capital gains tax, documentary stamps, costs of
registration, transfer tax, and all incidental expenses for the issuance of the new title
shall be for the account of the VENDEE;
IN WITNESS WHEREOF, the parties have hereunto set their hands this 28th day of November
2012, in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 28 th day of November
20121, personally appeared ANDREW M. MARQUEZ, REIGNA L. MARQUEZ and CARLO K.
KITAWA, who have satisfactorily proven to me their identity through their Taxpayer
Identification Number 835-869-976-135, SSS No. 967497296, and Professional Driver’s
License No. AO946148, respectively, that they are the same persons who executed and
voluntarily signed the foregoing Deed of Absolute Sale of an Unregistered Land which they
acknowledged before me as their free and voluntary acts and deeds.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
-and-
RICA J. MONA, single, of legal age, Filipino citizen, with residence and postal address
at #15 West Bayan Park, Aurora Hill, Baguio City, hereinafter referred to as the VENDEE;
W ITNESSETH:
WHEREAS, the VENDOR is the absolute owner, in fee simple of that certain parcel of
land located in Bakakeng, Baguio City, covered by Transfer Certificate of Title No. T-
734175, more particularly described as follows:
WHEREAS, the VENDOR has agreed to sell unto and in favor of the VENDEE, and the
VENDEE is willing and/or agreeable to buy from the VENDOR, its ownership, rights and
interest of the above-described land with an area of FIVE HUNDRED NINETY FOUR (594)
SQUARE METERS with a total consideration of TWO MILLION FOUR HUNDRED EIGHTY
THOUSAND PESOS (Php2,480,000.00), Philippine Currency, under the terms and conditions
provided hereunder;
Now, therefore, for and in consideration of the foregoing, they do hereby agree as
follows:
6. That upon signing of this Conditional Deed of Sale, the VENDEE shall pay ONE
MILLION THREE HUNDRED THOUSAND PESOS (Php1,300,000.00), as
downpayment;
7. That the balance of ONE MILLION ONE HUNDRED EIGHTY THOUSAND PESOS
(Php1,180,000.00) shall be paid through Metrobank and Trust Company, Session Road
Branch on or before sixty (60) days, or until January 29, 2012, from the execution of this
Conditional Deed of Sale;
8. That upon receipt of the Bank Guarantee in favor of the VENDOR, the latter shall
execute an Absolute Deed of Sale in favor of the VENDEE;
9. That failure to pay the balance shall cause the automatic rescission of this Contract with
damages in the amount of ONE HUNDRED THOUSAND PESOS (Php100,000.00);
10. That the realty taxes and special assessments on the subject property on or before the
date of sale, cost of operation of the documents of sale, and notarial fees shall be for
the account of the VENDOR; while those realty taxes that shall accrue after the date of
this Conditional Deed of Sale, capital gains tax, documentary stamps, costs of
registration, transfer tax, and all incidental expenses for the issuance of the new title
shall be for the account of the VENDEE;
IN WITNESS WHEREOF, the parties have hereunto set their hands, and affix their
signatures, this 28th day of November 2012 in the City of Baguio, Philippines.
RICA J. MONA
Vendee
CTC No. 74532164
Issued on 01/25/2012
Issued at Baguio City
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 28 th day of November
2012, personally appeared WENDELL D. CESARIO,MICA L. CESARIO, and RICA J. MONA
who have satisfactorily proven to me their identity through their Professional Driver’s License
No. AO94631857,Passport No.SS 7528573 valid until December 18, 2014 and Postal ID No.
402544respectively, that they are the same persons who executed and voluntarily signed the
foregoing Deed of Conditional Sale which they acknowledged before me as their free and
voluntary acts and deeds.
This instrument consisting of THREE (3) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof
by the parties and their witnesses.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
This DEED OF SALE OF A MOTOR VEHICLE made and executed by and between:
MARQUEE C. SIMON, single, of legal age, Filipino Citizen, with residence and postal
address at 75A Gibraltar, Baguio City, Philippines hereinafter referred to as the VENDOR;
-and-
CESAR Q. PURISIMA, single, of legal age, Filipino Citizen, with residenceand postal address at
No. 327 Victoria Village, Quezon Hill, Baguio City, Philippines, hereinafter referred to as the VENDEE;
WITNESSETH THAT:
Make: Isuzu
Plate Number: UV AYT 736
MV File Number: 1749-8462547
Motor Number: 735185639839
Serial/ Chassis Number: VCD 9361437
Official Receipt Number: 83543638463
Certificate of Registration Number: 83524963849
The VENDOR agreed to sell and the VENDEE is willing to buy the above-described
personalty;
For and in consideration of the total sum of ONE HUNDRED THOUSAND TWO
HUNDRED FIFTY PESOS (Php100,250.00), PHILIPPINE CURRENCY, receipt of said total purchase
price is hereto acknowledged by the VENDOR, paid by the VENDEE to the VENDOR, the VENDOR by
these present hereby does SELL, TRANSFER and CONVEY, unto the said VENDEE, her heirs and
assigns the above-described motor vehicle;
The VENDOR hereby warrants that the above-described personalty is free from liens and
encumbrances.
IN WITNESS WHEREOF, the parties have hereunto set their hands this 28th day of November
2012, in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 28th day
of November 2012, personally appeared MARQUEE C. SIMON and CESAR Q. PURISIMA who
exhibited to me their respective identification documents as indicted below their respective
names and signatures, known to me as the same persons who executed and voluntarily
signed the foregoing Deed of Absolute Sale of a Motor Vehicle which they acknowledged
before me as their free and voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof
by the parties and their witnesses.
WITNESS MY HAND AND SEAL on the date and at the place first above-written.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
This DEED OF SALE OF A REGISTERED LAND made and executed by and between:
CECEILLE B. BARONA, single, of legal age, Filipino Citizen, with residence and postal
address at 35 Cabinet Hill, Baguio City, Philippines hereinafter referred to as the VENDOR;
-and-
MARIA E. AMIGOS, single, of legal age, Filipino Citizen, with residence and postal address at
149Pias St., Barangay Camp 7, Baguio City, Philippines, hereinafter referred to as the VENDEE;
WITNESSETH THAT:
1. The VENDOR is the exclusive/absolute owner and possessor of that certain registered
parcel of land situated in Pico, La Trinidad, Benguet, Philippines covered by TRANSFER
CERTIFICATE OF TITLE No. T-73163 issued by the Register of Deeds of Benguet and
more specifically described as follows, to wit:
2. The VENDOR agreed to sell and the VENDEE is willing to buy the above-described parcel
of registered land including all its improvements;
3. For and in consideration of the total sum of NINETY THOUSAND EIGHT HUNDRED
PESOS (Php90,800.00), PHILIPPINE CURRENCY, receipt of said total purchase price is
hereto acknowledged by the VENDOR, paid by the VENDEE to the VENDOR, the VENDOR
by these present hereby SELL, TRANSFER and CONVEY, unto the said VENDEE, their
heirs and assigns the above-described parcel of REGISTERED LAND including all
improvements;
4. It is hereby declared that the boundaries of the foregoing land are visible by means of
natural and man-made boundaries as shown in the survey plan of the above-described
parcel of land;
5. The VENDOR hereby warrants that the above-described parcel of land is free from liens and
encumbrances and further warrants the peaceful possession by the VENDEE of the hereto
sold property;
6. FURTHER, that the requirements under the provisions of ARTICLE 1623 OF THE NEW
CIVIL CODE have been complied with.
IN WITNESS WHEREOF, the parties have hereunto set their hands this 28th day of November
2012, in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 28th day of November
2012, CECEILLE B. BARONA and MARIA E. AMIGOSpersonallyappeared, who have
satisfactorily proven to me their identity through their Passport No. SS8264518 valid until
December 25, 2014 and Professional Driver’s License No.AO836278, respectively, that they
are the same persons who executed and voluntarily signed the foregoing Deed of Absolute
Sale of Registered Land which they acknowledged before me as their free and voluntary acts
and deeds.
This instrument consisting of TWO (2) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof
by the parties and their witnesses.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
This DEED OF SALE OF AN UNREGISTERED LAND, made and executed by and between:
SPS.ROY B. UY and ANNIE H. UY, of legal ages, Filipino citizens, and with residence
address at #47 New Lucban, Baguio City, Philippines hereinafter called as the VENDORS;
-and-
ROD BRYAN P. SABIO, single, of legal age, Filipino Citizen, with residence address at #732
Tacay Road, Baguio City, Philippines, hereinafter called the VENDEE;
WITNESSETH THAT:
The VENDORS are the owners of a certain unregistered parcel of land situated at Sabkil,
Loacan, Itogon, Benguet, Philippines and more specifically described as follows, to wit:
BOUNDARIES:
NORTH: Lot 2 SOUTH: Lot 2052
EAST : Lot 1 WEST : Lot 4
KIND : Camotal land
AREA : 4.6351 ha.
MARKET VALUE : Php 48,500.00
ASSESSED VALUE: Php 15,300.00
The VENDORS decide to sell the entire area of the above-described unregistered land including
all the improvements therein to herein VENDEE;
For and in consideration of the total sum of ONE HUNDRED FORTY THOUSAND PESOS
(Php140,000.00) ONLY, PHILIPPINE CURRENCY, paid by the VENDEE to the VENDORS, the
VENDORS by these present hereby SELL, TRANSFER and CONVEY, unto the said VENDEE, his
heirs and assigns the above described portion of property;
It is hereby declared that the boundaries of the foregoing land are visible by means of natural
and man-made boundaries;
The Vendors hereby warrant that the above-described portion of unregistered land is free from
all liens and encumbrances;
The above-described real estate property, not having been registered under Act No. 496 nor
under the Spanish Mortgage Law, the parties hereto have agreed to register this instrument under the
provisions of Sec. 194 of the Revised Administrative Code, as amended by Act No. 3344.
IN WITNESS WHEREOF, the parties have hereunto set their hands this 28th day of November
2012, in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 28 th day of November
2012, personally appeared ROY B. UY, ANNIE H. UY and ROD BRYAN P. SABIOwho have
satisfactorily proven to me their identity through their Taxpayer Identification Number
362953714, SSS No. 5385626482, and Professional Driver’s License No. AO734184,
respectively, that they are the same persons who executed and voluntarily signed the
foregoing Deed of Absolute Sale of an Unregistered Land which they acknowledged before me
as their free and voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof
by the parties and their witnesses.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
HELEN K. TETANCO, single, of legal age, Filipino citizen, with residence and postal
address at Unit 12 Genesis Point Village, Irisan, Baguio City, Philippines, hereinafter referred
to as the ASSIGNOR;
-and-
WILMA F. ASAN, single, of legal age, Filipino citizen, with residence and postal
address at 124-J Banig, Tawang, La Trinidad, Benguet, Philippines, hereinafter referred to as
the ASSIGNEE.
WITNESSETH:
That the ASSIGNOR is indebted to the ASSIGNEE in the sum of ONE HUNDRED
FIFTY THOUSAND PESOS (Php150,000.00), Philippine Currency, and in full payment and
complete satisfaction thereof, the ASSIGNOR hereby ASSIGN, TRANSFER and CONVEY
unto the ASSIGNEE that certain real estate situated in Pico, La Trinidad, Benguet, and more
particularly described as follows:
of which real estate the ASSIGNOR is the registered owner, her title being evidenced by
Transfer Certificate of Title No. 46295 issued by the Register of Deeds of La Trinidad,
Benguet, Philippines.
That the ASSIGNEE does hereby accept this assignment in full payment of the above-
mentioned debt of ONE HUNDRED FIFTY THOUSAND PESOS (Php150,000.00), Philippine
Currency.
IN WITNESS WHEREOF, the parties hereto have hereunto set their hands this 29 th day
of November 2012 in the City of Baguio, Philippines.
BEFORE ME, a Notary Public in and for the City of Baguio, this 29th day of November 2012,
personally appeared HELEN K. TETANCO andWILMA F. ASAN, who have satisfactorily proven to me
their identity through their Passport No. SS 3721836 valid until December 20, 2016 and Professional
Driver’s License No.AO946284, respectively, that they are the same persons who executed and
voluntarily signed the foregoing Deed of Assignment which they acknowledged before me as their free
and voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof
by the parties and their witnesses.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
MONICA KAYE K. ABAGO, single, of legal age, Filipino Citizen, with residence and
postal address at #16 West Bayan Park, Aurora Hill, Baguio City, Philippines, hereinafter
referred to as the MORTGAGOR;
-and –
IVAN CARLO M. MARTIN, of legal age, Filipino citizen, with residence and postal
address at #62 Bonifacio St., Baguio City, Philippines, hereinafter referred to as the
MORTGAGEE;
W I T N E S S E T H:
That the MORTGAGOR is the owner a motor vehicle, which is particularly described
hereunder, to wit:
That for and inconsideration of a LOAN obtained by the MORTGAGOR from the
MORTGAGEE in the sum of SIX HUNDRED THOUSANDPESOS(Php600,000.00), Philippine
Currency, with an interest of TEN PERCENT (8%) MONTHLY, and to secure the payment of
the same, the MORTGAGOR hereby freely and voluntarily CEDE, TRANSFER, AND
CONVEY by way of mortgage unto the MORTGAGEE, his successors and assigns, that motor
vehicle above – described;
The MORTGAGOR hereby warrants that the above-described motor vehicle is free from
any claim whatsoever, except that which appears in the Certificate of Registration, if any.
The MORTGAGEE with notice to the MORTGAGOR, reserves the right to sell, cede,
transfer, assign or convey to any person or entity its right and interest in and to this chattel
mortgage so long as the same is subsisting.
For the purpose of extra-judicial foreclosure, the MORTGAGOR hereby constitute and
appoint the MORTGAGEE or his successors to sell the property mortgaged, to sign all
documents, receive, receipt for and accept all monies or checks, and to perform any act
requisite and necessary to accomplish said purpose.
This Chattel Mortgage shall be for a period of SIX (6) MONTHS to be reckoned from the
date of its execution and shall be renewable upon the mutual consent of both parties.
IN WITNESS WHEREOF, the partieshave hereunto affixed their signatures this 29thday
of November 2012 in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th day of November
2012, personally appeared MONICA KAYE K. ABAGO and IVAN CARLO M. MARTIN,
personally known to me to be the same persons who voluntary executed the foregoing Deed of
Chattel Mortgage which they acknowledged before me as their free and voluntary acts and
deeds.
This instrument consisting of TWO (2) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof
by the parties and their witnesses.
This DEED OF CONDITIONAL SALE, made and entered into by and between:
-and-
GUILBERT H. BADUA, single, of legal age, Filipino citizen, with residence and postal
address at #98 East Bayan Park, Aurora Hill, Baguio City, hereinafter referred to as the
VENDEE;
W ITNESSETH:
WHEREAS, the VENDOR is the absolute owner, in fee simple of that certain parcel of
land located in Bakakeng, Baguio City, covered by Transfer Certificate of Title No. T-
862967, more particularly described as follows:
WHEREAS, the VENDOR has agreed to sell unto and in favor of the VENDEE, and the
VENDEE is willing and/or agreeable to buy from the VENDOR, its ownership, rights and
interest of the above-described land with an area of FOUR HUNDRED SIXTY FIVE (465)
SQUARE METERS with a total consideration of ONE MILLION SEVEN HUNDRED
THOUSAND PESOS (Php1,700,000.00), Philippine Currency, under the terms and conditions
provided hereunder;
Now, therefore, for and in consideration of the foregoing, they do hereby agree as
follows:
11. That upon signing of this Conditional Deed of Sale, the VENDEE shall pay SEVEN
HUNDRED THOUSAND PESOS (Php700,000.00), as downpayment;
12. That the balance of ONE MILLION ONE PESOS (Php1,000,000.00) shall be paid
through Metrobank and Trust Company, Session Road Branch on or before sixty (60)
days, or until January 30, 2012, from the execution of this Conditional Deed of Sale;
13. That upon receipt of the Bank Guarantee in favor of the VENDOR, the latter shall
execute an Absolute Deed of Sale in favor of the VENDEE;
14. That failure to pay the balance shall cause the automatic rescission of this Contract with
damages in the amount of FIFTY THOUSAND PESOS (Php50,000.00);
15. That the realty taxes and special assessments on the subject property on or before the
date of sale, cost of operation of the documents of sale, and notarial fees shall be for
the account of the VENDOR; while those realty taxes that shall accrue after the date of
this Conditional Deed of Sale, capital gains tax, documentary stamps, costs of
registration, transfer tax, and all incidental expenses for the issuance of the new title
shall be for the account of the VENDEE;
IN WITNESS WHEREOF, the parties have hereunto set their hands, and affix their
signatures, this 29th day of November 2012 in the City of Baguio, Philippines.
GUILBERT H. BADUA
Vendee
CTC No. 07432187
Issued on 01/25/2012
Issued at Baguio City
BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th day of November
2012, personally appeared BRYAN A. LOBATONand GUILBERT H. BADUA, who have
satisfactorily proven to me their identity through their Passport No. SS 9672584 valid until
December 18, 2015 and Professional Driver’s License No.AO86749787, respectively, that they
are the same persons who executed and voluntarily signed the foregoing Deed of Conditional
Sale which they acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of THREE (3) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof
by the parties and their witnesses.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
MARION Y. YUNGSO, married to ELIZA H. YUNGSO, of legal age, Filipino citizen and
with residence and postal address at #67 Liteng, Baguio City, hereinafter referred to as the
DONOR;
LENSTER H. YUNGSO, single, of legal age, Filipino citizen and with residence and
postal address at #89 Everlasting St., Q.M. Subdivision, Baguio City, hereinafter referred to as
the DONEE;
WITNESSETH:
1. That the DONOR is the owner in fee simple of that certain real property situated
at Manila City described as follows:
BOUNDARIES:
NORTH : Lot 5 SOUTH: Lot 7815
EAST : Lot 3 WEST : Lot 4
KIND : Camotal land
AREA : 6.8295 ha.
MARKET VALUE : Php 150,300.00
ASSESSED VALUE: Php 90,000.00
2. That the DONEE is the child of the DONOR, who has lovingly dedicated his life
as the latter's personal caregiver and companion;
4. That the DONOR affirms that this donation is not made with intent to deceive her
creditors, and that he has reserved for himself sufficient funds and property;
5. That the DONEE hereby accepts and receives this donation made in his favor by
the DONOR, and hereby manifests his gratefulness for the latter's generosity.
IN WITNESS WHEREOF, both the DONOR & DONEE have hereunder subscribed their
names this 29th day of November 2012, in the City of Baguio, Philippines.
ELIZA H. YUNGSO
CTC No. 75194629
Issued on 01/15/2012
Issued at Baguio City
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th day of November
2012, personally appeared MARION Y. YUNGSO and LENSTER H. YUNGSO, who have
satisfactorily proven to me their identities through HONEY G. TIANGCO, who is personally
known to me and who personally knows the parties, that they are the same persons who
executed and voluntarily signed the foregoing Deed of Donation of Real Property which they
acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof
by the parties and their witnesses.
RITZCHALLE T. GARCIA
WITNESS MY HAND AND SEAL. NOTARY PUBLIC
Until December 2013
MARIAM F. CATACUTAN, single, of legal age, Filipino citizen, with residence and
postal address at No. 89 Trancoville, Baguio City, hereinafter referred to as the DONOR;
ELENA J. CUMAG, single, of legal age, Filipino citizen, with residence and postal
address at 76 Ma. Basa, Pacdal, Baguio City, hereinafter called the DONEE;
WITNESSETH:
That the DONOR is the owner of a laptop computer and precious jewelries, more
particularly described as follows:
SONY VAIO notebook Laptop
Pair of Garnet Earrings
Gold Necklace with Garnet Pendant
Gold Ring with set with Garnet stone
That the DONEE is a cousin of the DONOR, who has lovingly dedicated eight (8) years
of her life as the latter's personal caregiver and companion;
That FOR AND IN CONSIDERATION of the DONEE'S trust, devotion and affection
shown to the DONOR, and as an act of gratitude and liberality on her part, the DONOR hereby
voluntarily GIVES, TRANSFERS, and CONVEYS by way of donation, unto the said DONEE,
her heirs and assigns, the above described personal properties, free from all liens and
encumbrances;
That the DONOR affirms that this donation is not made with intent to deceive her
creditors, and that she has reserved for herself sufficient funds and property;
That the DONEE hereby accepts and receives this donation made in her favor by the
DONOR, and hereby manifests her gratefulness for the latter's generosity.
IN WITNESS WHEREOF, both the DONOR and DONEE have hereunder subscribed
their names this 29thday of November 2012, in the City of Baguio, Philippines.
BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th day of November
2012, personally appeared MARIAM F. CATACUTAN and ELENA J. CUMAG, who have
satisfactorily proven to me their identities through their Passport No. SS 2458413 valid until
August 28, 2015 and Professional Driver’s License No.AO41579360, respectively, that they
are the same persons who executed and voluntarily signed the foregoing Deed of Donation
which they acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof
by the parties and their witnesses.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
CARMEN K. LIAM, single, of legal age, Filipino Citizen, with residence and postal
address at #836 Mines View, Baguio City, Philippines, hereinafter referred to as the FIRST
PARTY;
-and-
JERLYN H. BIEN, single, of legal age, Filipino Citizen, with residence and postal address at
Pico, La Trinidad, Benguet, hereinafter referred to as the SECOND PARTY.
WITNESSETH:
WHEREAS, the FIRST PARTY is the owner and present possessor of a parcel of land located
at Pico, La Trinidad, Benguet with an area of FIVE HUNDRED SIXTY (560) SQUARE METERS, more
or less, covered by Tax Declaration No. 05-421-75869, particularly described as follows:
“Bounded on the North by Section 09; on the south by GLENDA L. LUNA; on the
East by JERRY L. DAYAG; and on the West by KLAIR L. ASKI; containing an area of
Five Hundred Sixty square meters located at Pico, La Trinidad, Benguet.”
WHEREAS, the SECOND PARTY is the owner and present possessor of a certain parcel of
land covered and embraced by Transfer Certificate of Title No. T-84217 and more particularly
described as follows:
“A parcel of land (lot 1, Psd-1-981298), situated in the Bo.Ambiong, Mun. of La Trinidad,
Province of Benguet, Island of Luzon. Bounded on the NW. along line 1-2 by property of
Rhea Cachero; on the N. along line 2-3 by public land; on the E. along line 3-4 by
property of Shana Laurie Locano; on the S., & SW., along lines 4-5-6-7-1 by Lot 2, Psd-
1-981298. Beginning at a point marked “1” on Lot 1, x xx
x xx containing an area of FIVE HUNDRED SIXTY (560) SQUARE METERS. x xx”
WHEREAS, both PARTIES hereto have agreed to exchange their respective properties
covering an area of FIVE HUNDRED SIXTY (560) SQUARE METERS from the above-described
properties of both parties, which are free from all liens and encumbrances of whatever kind and nature;
WHEREAS, the FIRST PARTY thus hereby CEDE, TRANSFER, DELIVER and CONVEY unto
the SECOND PARTY its property located in Pico, La Trinidad, Benguet as afore-described (A copy of
the sketch plan of the aforementioned property is hereto attached as ANNEX “A”). LIKEWISE, the
SECOND PARTY, hereby simultaneously CEDE, TRANSFER, DELIVER and CONVEY unto the
FIRST PARTY the aforementioned property;
WHEREAS, the PARTIES herein do hereby warrant that their respective properties subject of
this Deed of Exchange are free against any claim from third person of whatever kind and nature;
WHEREAS, the provisions of Art. 1623 of the New Civil Code of the Philippines has been
complied with.
IN WITNESS WHEREOF, the PARTIES have hereunto affixed their signatures this 30thday of
November 2012, in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 30 thday of November
2012, personally appeared CARMEN K. LIAMand JERLYN H. BIEN, personally known to me
to be the same persons who voluntary executed the foregoing Deed of Exchange which they
acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof
by the parties and their witnesses.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
WILMA G. JACOBA, of legal age, single, Filipino, and with residence and postal
address at 25 Leonard Wood Road, Baguio City hereinafter known as the MORTGAGOR.
-and-
GERALD D. SIMON, also of legal age, married to Drizelle F. Simon, Filipino, with
residence and postal address at #71Engineers Hill, Baguio City hereinafter known as the
MORTGAGEE.
WITNESSETH:
That the MORTGAGOR is the lawful, absolute and exclusive owner and actual
possessor of a property free from all liens and encumbrances particularly described as follows:
“An orchard located at Caba, San Fernando La Union declared under Tax Declaration
No. 52540 with an area of 300 square meters, more or less, bounded by monuments
and no permanent structure. Bounded on the North by Lot No. 1448-B; on the East by
Lot No. 4556; on the South by Gomez St; and on the West by Lot No. 1337-A and B”.
That the MORTGAGOR, for and in consideration of the sum of SIX HUNDRED
THOUSAND PHILIPPINE PESOS (Php. 600,000.00), received from the MORTGAGEE, does
hereby mortgage unto the said MORTGAGEE, his heirs and assigns, the above-described real
property including its improvements;
The herein parties have agreed that the above-mentioned loan shall earn interest of
EIGHT (8%) percent monthly for a period of TEN (10) months from execution of this contract.
Advance payment of TEN (10%) percent for one (1) month shall be paid upon execution
of this contract with the subsequent interest to be paid on every 30 th day of every month
thereafter up to the duration of this contract;
That this Real Estate Mortgage of House and Lot may be renewed upon option of the
parties under such terms and conditions acceptable to them;
During the enforcement / term of this contract, the MORTGAGOR shall not enter into
any contract that may encumber the above-described property unless with the express and
written consent of the MORTGAGEE;
That in case of non-payment by the MORTGAGOR of the herein amount and the
MORTGAGEE is compelled to pursue foreclosure proceedings, the MORTGAGOR does
hereby agree that the said MORTGAGEE may enforce his rights herein without judicial
proceedings by causing the above-described property is located, after giving notice of sale for
20 days posted in at least three public places of the said city; said sale to take place at the
Baguio City Hall, by the judge of the Regional Trial Court or the Sheriff; as the case may be, in
accordance with Act No. 3135 as amended by Act No. 4118;
That the cost of publication, sale, collection, attorney’s fees, taxes and charges in
relation to the foreclosure sale shall be borne by the MORTGAGOR.; and
That the parties do hereby agree to register the Real Estate Mortgage pursuant to the
provisions of Act 3135 as amended by Act No. 4118.
IN WITNESS WHEREOF, we have hereunto signed this deed of sale, this 30 th day of
November 2012, in Baguio City, Philippines.
ACKNOWLEDGMENT
BEFORE ME, this30th day of November 2012 in the City of Baguio personally appeared
WILMA G. JACOBA and GERALD D. SIMON, who have satisfactorily proven to me their
identities through FRED J. CUDOS, who is personally known to me and who personally knows
the parties, that they are the same persons who executed and voluntarily signed the foregoing
instrument and acknowledged to me that the same is their free act and deed.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
KRISTOFF G. HEHERSON, single, of legal age, Filipino citizen, with residence and
postal address at CD-725 Wangal, La Trinidad, Benguet, Philippines, hereinafter referred to as
the VENDOR;
- and-
DREXELL M. PACIS, single, of legal age, Filipino citizen, with residence and postal
address at Lower Burgos, Baguio City, Philippines, hereinafter referred to as the VENDEE;
W I T N E S S E T H:
WHEREAS, the VENDOR hereby warrants good and clean ownership over that
Franchise and that his rights, interests and participation over it has not been previously
alienated, sold nor transferred to any third party, whomsoever;
FINALLY, that the VENDOR shall defend the possession and ownership of the above-
mentioned Franchise of the VENDEE, against any possible claim of ownership by any third
party and adverse claimants.
That the VENDOR is executing this deed of sale freely and voluntary and for all legal
intents and purposes that it may serve.
IN WITNESS WHEREOF, the PARTIES have hereunto set their hands this 30 th day of
November 2012, in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 30 th day of November 2012,
personally appeared KRISTOFF G. HEHERSON and DREXELL M. PACIS, personally known
to me to be the same persons who voluntary executed the foregoing Deed of Absolute Sale of
Franchise which they acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof
by the parties and their witnesses.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
SALLY C. FUENTES, of legal age, single, Filipino, and with residence and postal
address at 46 Pacdal, Baguio City hereinafter known as the VENDOR.
-and-
WITNESSETH:
That the VENDOR is the absolute owner of a certain parcel of land situated in
Trancoville, Baguio City, covered by Transfer Certificate of Title No. T-465836 issued by the
Registry of Deeds of Baguio City, and more particularly described as follows:
A parcel of Land (Lot 5, Blk. 11, Psd-1-014521, being a portion of Lot 19,
II-11894, L.R.C. Rec. No. ___), situated in the Bo.Trancoville, City of
Baguio, Island of Luzon. Bounded on the SE., along line 6-1-2 by Lot 4, Blk.
11, on the SW., along line 2-3 by Alley Lot 5, on the NW., along line 3-4 by
Lot 5, Blk. 11, on the NE., along line 4-5-6 by Drainage I Lot 6, all of the
Psd-1-014521. Beginning at a point marked “1” of Lot 5 Blk. 11, on plan
being S. 4 deg. 13’W., 797.98 m. from B.L. No. 7, Baguio Townsite, thence:
That the VENDEE has offered to buy and the VENDOR has agreed to sell a portion of
the above described property, pending its subdivision in accordance with law, for a price and
under the terms and conditions herein set forth;
That the VENDOR does hereby warrant valid title to and peaceful possession of, the
portion of land herein sold and conveyed, and will defend the same unto the said VENDEE
his/her heirs and assigns against the claims of third persons whomsoever.
That the parties hereto hereby agree that within a period of SIXTY (60) days from and
after the execution of this instrument, the VENDOR shall engage the services of a licensed
geodetic engineer to undertake the preparation of the necessary survey plan of subdivision,
segregating the definite portion object of this sale, and submit the same to the proper
government authorities for verification and approval in accordance with law.
That pending approval of the subdivision plan, the parties hereto have agreed to
register this Deed of Sale in the Office of the Register of Deeds concerned by way of
memorandum: annotation on the corresponding certificate of title as permitted under the
provision of Section 58 of Act 496, as amended with the understanding that upon the final
approval of said subdivision plan and the corresponding technical description of the resulting
lots, certified copy thereof shall forthwith be filed with the Register of Deeds to enable him to
effect the segregation process by the issuance of a new certificate of title in the name of the
herein VENDEE for the portion of land sold and another certificate in the name of the herein
VENDOR for the portion remaining.
That the parties further agree that the expenses incident to the survey of the land shall
be deemed to be included in the consideration of this sale, and that the attorney’s fee for the
preparation of the necessary deed and other legal papers as well as the requisite documentary
stamps shall be for the account of the VENDOR, while the registration fees to be payable to
the Register of Deeds and transfer tax shall be for the account of the VENDEE.
IN WITNESS WHEREOF, we have hereunto signed this deed of sale, this 30 th day of
November 2012, in Baguio City, Philippines.
BEFORE ME, this 30th day of November 2012 in the City of Baguio personally appeared
SALLY C. FUENTES and SAMSON G. KORONEL, who have satisfactorily proven to me their
identities through GINO H. GUEVARRA, who is personally known to me and who personally
knows the parties, that they are the same persons who executed and voluntarily signed the
foregoing instrument and acknowledged to me that the same is their free act and deed.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
This DEED OF SALE OF HEAVY EQUIPMENT made and executed by and between:
LUIGI M. MENDOZA, single, of legal age, Filipino Citizen, with residence and postal
address at 87A Gibraltar, Baguio City, Philippines hereinafter referred to as the VENDOR;
-and-
DEXTER P. CALIXTO, single, of legal age, Filipino Citizen, with residenceand postal address at
No. 138 Victoria Village, Quezon Hill, Baguio City, Philippines, hereinafter referred to as the VENDEE;
WITNESSETH THAT:
The VENDOR agreed to sell and the VENDEE is willing to buy the above-described heavy
equipment;
For and in consideration of the total sum of THREE HUNDRED THOUSAND TWO
HUNDRED FIFTY PESOS (Php300, 250.00), PHILIPPINE CURRENCY, receipt of said total purchase
price is hereto acknowledged by the VENDOR, paid by the VENDEE to the VENDOR, the VENDOR by
these present hereby does SELL, TRANSFER and CONVEY, unto the said VENDEE, her heirs and
assigns the above-described heavy equipment;
The VENDOR hereby warrants that the above-described heavy equipment is free from
liens and encumbrances.
IN WITNESS WHEREOF, the parties have hereunto set their hands this 1st day of December
2012, in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 1st day of December
2012, personally appeared LUIGI M. MENDOZAand DEXTER P. CALIXTOwho exhibited to me
their respective identification documents as indicted below their respective names and
signatures, known to me as the same persons who executed and voluntarily signed the
foregoing Deed of Sale of Heavy Equipment which they acknowledged before me as their free
and voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof
by the parties and their witnesses.
WITNESS MY HAND AND SEAL on the date and at the place first above-written.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
KRISTINE M. LOPEZ, single, of legal age, Filipino Citizen, with residence and postal
address at 328 Aurora Hill, Baguio City, Philippines hereinafter referred to as the
TRANSFEROR;
-and-
GLACIA S. TUAZON, single, of legal age, Filipino Citizen, with residence and postal address at
172Pias St., Barangay Camp 7, Baguio City, Philippines, hereinafter referred to as the TRANSFEREE;
WITNESSETH THAT:
7. The TRANSFEROR is the exclusive/absolute owner and possessor of that certain registered
parcel of land situated in Pico, La Trinidad, Benguet, Philippines covered by TRANSFER
CERTIFICATE OF TITLE No. T-73163 issued by the Register of Deeds of Benguet and
more specifically described as follows, to wit:
8. The TRANSFEROR agreed to sell and the TRANSFEREE is willing to buy the above-
described parcel of registered land including all its improvements;
9. For and in consideration of the total sum of NINETY THOUSAND EIGHT HUNDRED
PESOS (Php90,800.00), PHILIPPINE CURRENCY, receipt of said total purchase price is
hereto acknowledged by the TRANSFEROR, paid by the TRANSFEREE to the
TRANSFEROR, the TRANSFEROR by these present hereby SELL, TRANSFER and
CONVEY, unto the said TRANSFEREE, their heirs and assigns the above-described parcel
of REGISTERED LAND including all improvements;
10. It is hereby declared that the boundaries of the foregoing land are visible by means of
natural and man-made boundaries as shown in the survey plan of the above-described
parcel of land;
11. The TRANSFEROR hereby warrants that the above-described parcel of land is free from
liens and encumbrances and further warrants the peaceful possession by the
TRANSFEREE of the hereto sold property;
12. FURTHER, that the requirements under the provisions of ARTICLE 1623 OF THE NEW
CIVIL CODE have been complied with.
IN WITNESS WHEREOF, the parties have hereunto set their hands this 1st day of December
2012, in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 1st day of December
2012, KRISTINE M. LOPEZ and GLACIA S. TUAZON personallyappeared, who have
satisfactorily proven to me their identity through their Passport No. SS7489146 valid until
December 25, 2014 and Professional Driver’s License No. AO58357136, respectively, that
they are the same persons who executed and voluntarily signed the foregoing Deed of
Absolute Sale of Registered Land which they acknowledged before me as their free and
voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof
by the parties and their witnesses.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
This DEED OF SALE OF A MOTOR VEHICLE made and executed by and between:
MAURICIO G. DE LEON, single, of legal age, Filipino Citizen, with residence and postal
address at 48B Gibraltar, Baguio City, Philippines hereinafter referred to as the VENDOR;
-and-
PHILIP B. CASTRO, single, of legal age, Filipino Citizen, with residenceand postal address at
No. 318 Victoria Village, Quezon Hill, Baguio City, Philippines, hereinafter referred to as the VENDEE;
WITNESSETH THAT:
The VENDOR is the owner a motor vehicle engine, which is particularly described
hereunder, to wit:
The VENDOR agreed to sell and the VENDEE is willing to buy the above-described vehicle
engine;
For and in consideration of the total sum of FIFTY THOUSAND PESOS (Php50,000.00),
PHILIPPINE CURRENCY, receipt of said total purchase price is hereto acknowledged by the
VENDOR, paid by the VENDEE to the VENDOR, the VENDOR by these present hereby does SELL,
TRANSFER and CONVEY, unto the said VENDEE, her heirs and assigns the above-described motor
engine;
The VENDOR hereby warrants that the above-described engine is free from liens and
encumbrances.
IN WITNESS WHEREOF, the parties have hereunto set their hands this 1st day of December
2012, in the City of Baguio, Philippines.
BEFORE ME, a Notary Public in and for the City of Baguio, this 1st day of December
2012, personally appeared MAURICIO G. DE LEONand PHILIP B. CASTROwho exhibited to
me their respective identification documents as indicated below their respective names and
signatures, known to me as the same persons who executed and voluntarily signed the
foregoing Deed of Absolute Sale of a Motor VehicleEnginewhich they acknowledged before
me as their free and voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof
by the parties and their witnesses.
WITNESS MY HAND AND SEAL on the date and at the place first above-written.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
This DEED OF SALE OF MOTOR VEHICLE WITH FRANCHISE, made and executed
by and between:
JIMMY V. MORALES, single, of legal age, Filipino citizen, with residence and postal
address at CD-725 Wangal, La Trinidad, Benguet, Philippines, hereinafter referred to as the
VENDOR;
- and-
ADRIAN L. PEDRO, single, of legal age, Filipino citizen, with residence and postal
address at Lower Burgos, Baguio City, Philippines, hereinafter referred to as the VENDEE;
W I T N E S S E T H:
Make: Isuzu
Plate Number: UV AYT 736
MV File Number: 1749-8462547
Motor Number: 735185639839
Serial/ Chassis Number: VCD 9361437
Official Receipt Number: 83543638463
Certificate of Registration Number: 83524963849
WHEREAS, the VENDOR is also the lawful owner of a Certificate of Public convenience
to Operate a Taxi Service issued by the Land Transportation Franchising and Regulatory
Board, Cordillera Administrative Region, Baguio City under case No. 2006-CAR-165;
WHEREAS, the VENDOR hereby warrants good and clean ownership over that motor
vehicle with franchise and that his rights, interests and participation over it has not been
previously alienated, sold nor transferred to any third party, whomsoever;
FINALLY, that the VENDOR shall defend the possession and ownership of the above-
mentioned motor vehicle with franchise of the VENDEE, against any possible claim of
ownership by any third party and adverse claimants.
That the VENDOR is executing this deed of sale freely and voluntary and for all legal
intents and purposes that it may serve.
IN WITNESS WHEREOF, the PARTIES have hereunto set their hands this 1 st day of
December 2012, in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 1st day of December 2012,
personally appeared JIMMY V. MORALES and ADRIAN L. PEDRO, personally known to me to be the
same persons who voluntary executed the foregoing Deed of Absolute Sale of Franchise which they
acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof
by the parties and their witnesses.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
I, GERARDO K. AFAN, of legal age, Filipino, married and the incumbent City Mayor of
Dagupan City, Pangasinan, after having duly sworn on oath in accordance with the law hereby
voluntarily depose and say:
1. That the City Government of Tuguegarao is the consignee of a shipment of two (2) units
Schindler Elevator 5385MRL, 1450KG., 1.2MPS, 4stops/opening which comes with
miscellaneous spare parts and accessories covered by Bill of Lading No. 4758-8462-
857.847.
2. That under the provision of Section of Section 382 of Title Six, Book II of Republic Act
No. 7160 otherwise known as “THE NEW LOCAL GOVERNMENT CODE”, we, as a
local government unit, shall be exempt of duties and taxes for the importation of
machines, equipments, tools, supplies and spare parts;
3. That upon release and possession of the said shipment, and in consideration of said
privilege, the words “ENTERED DUTY-TAX-FREE UNDER THE NEW LOCAL
GOVERNMENT CODE”, shall be printed in a conspicuous space on the machinery and
equipment which was accorded duty and tax release;
4. That I am executing this Undertaking to attest to the truth of the foregoing facts.
IN WITNESS WHEREOF, I have hereunto set my hand this 1st day of December 2012,
in Baguio City, Philippines.
GERARDO K. AFAN
Affiant
SUBSCRIBED AND SWORN to before me in the City of Baguio this 1st day of December
2012, by GERARDO K. AFAN, who has satisfactorily proven his identity to me through his
Professional Driver’s License No. A03-72047 valid until August 26, 2013, that he is the same
person who personally signed the foregoing undertaking before me and acknowledged that he
executed the same.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
ROBERTO S. YARCIA, married to FRANCISCA H. YARCIA, Filipino citizen, of legal age, with
residence and postal address at #63 Quezon Hill, Baguio City, Philippines, hereinafter referred to
as the WAIVOR;
- in favor of –
RANDY L. DELA CRUZ, married to RIHANNA K. DELA CRUZ, Filipino citizen, of legal age,
with residence and postal address at #89 New Lucban, Baguio City, Philippines, hereinafter
referred to as the WAIVEE;
WITNESSETH:
WHEREAS, in a certain public document executed on March 1, 2011, the WAIVOR sold
under Pacto de Retro unto the WAIVEE certain real estates situated in No. 28A, Sanitary Camp and
No.56, Trancoville, Baguio City and more particularly describes as follows, to wit:
I.
A PARCEL OF LAND situated in Sanitary Camp, Baguio City containing an area
of SIX HUNDRED (600) square meters more or less.
xxx xxx
Bounded on the E-along lines1-2-3, Lot 32; on the N-along lines 3-4 Lot 33: on the W-
along lines 4-5-6-7, Lot 43; and on the S- along lines 7-8-1, Lot 54, all Cad 405-D,
Baguio cadastre.
II.
A PARCEL OF LAND (Lot 20 Blk 54 of consolidation subdivision plan (LRC) Pcs-
13265, being a portion of the consolidation of Lots 4751-A and 4751-B (LRC) Psd-
50533, Lot 3, Psd-100703, Lot 1, Psd-150980, LRC Rec. Nos. Nos. N-27024, 51768,
89632, N-11782, N-13466, and 21071 situated in Trancoville, City of Baguio, Prov. of
Benguet, Is. of Luzon. Bounded on NE., point 4 to 1 by Road Lot 22, on...to the point of
beginning; containing an area of (280)square meters more or less..."
Xxx xxx
said property being covered by Original Certificate of Title Nos. 957427 and 967276, respectively,
issued by the Register of Deeds of Baguio City;
WHEREAS, in accordance with the stipulation contained in said public instrument, the
WAIVOR has reserved the right to redeem the subject properties within a period of one (1) year
from and after the date of execution thereof;
WHEREAS, the WAIVOR is willing to renounce and waive his right to redeem said
properties for valuable consideration, which the WAIVEE has agreed to pay more specifically
mentioned herein below;
NOW THEREFORE, for and in consideration of the sum of THREE MILLION PESOS
(PHP3,000,000.00), Philippine Currency, in addition to the original purchase price, which
additional sum the WAIVOR hereby acknowledges to have received from the WAIVEE to his
entire satisfaction, the said WAIVOR does by these presents renounce and waive all his rights and
interests in and to the real properties above-described, more specifically the right to redeem
which he has reserved unto himself by virtue of the above described public instrument executed
on March 1, 2011 duly inscribed in the corresponding Certificate of Title as per entry Nos. 2859
IN WITNESS WHEREOF, the parties hereunto set their hands this 1st day of December
2012, in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary public in and for the City of Baguio, this 1st day of December 2012,
personally appeared ROBERTO S. YARCIA and RANDY L. DELA CRUZ, who have satisfactorily
proven their identities through:
both of whom personally know the parties, that they are the same persons who executed and voluntarily
signed the foregoing Waiver of Rights (over registered land) which they acknowledged before me as their
free and voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof by
the parties and their witnesses.
RITZCHALLE T. GARCIA
NOTARY PUBLIC
Until December 2013
This REAL ESTATE MORTGAGE OF A REGISTERED LAND, made and entered into
by and between:
RIZALINDA T. AFAGA, single, of legal age, Filipino citizen, with residence and postal
address in #93 Brookside, Baguio City, hereinafter referred to as the MORTGAGOR;
-and-
HAROLD Y. SANTOS, married to KIARA J. SANTOS, of legal age, Filipino citizen and
with residence and postal address at #10 Quezon Hill, Baguio City, hereinafter referred to as
the MORTGAGEE;
W I T N E S S E T H:
That for and in consideration of the aforementioned debt of the herein MORTGAGOR
in the sum of SIX HUNDRED THOUSAND PESOS(Php600,000.00), Philippine currency,
obtained from the MORTGAGEE, and to secure the payment of the same and those others
that the MORTGAGEE may extend to the MORTGAGOR, including interest and expenses,
and other obligations owing by the MORTGAGOR to the MORTGAGEE, whether direct or
indirect, principal or secondary, the MORTGAGOR do hereby transfer and convey by way of
REAL ESTATE MORTGAGE unto the MORTGAGEE, her successors and assigns, that
PARCEL OF REGISTERED LAND located along 28-A Trancoville, Baguio City which is more
particularly described as follows, to wit:
A parcel of Land (Lot 5, Blk. 11, Psd-1-014521, being a portion of Lot 19,
II-11894, L.R.C. Rec. No. ___), situated in the Bo.Trancoville, City of
Baguio, Island of Luzon. Bounded on the SE., along line 6-1-2 by Lot 4, Blk.
11, on the SW., along line 2-3 by Alley Lot 5, on the NW., along line 3-4 by
Lot 5, Blk. 11, on the NE., along line 4-5-6 by Drainage I Lot 6, all of the
Psd-1-014521. Beginning at a point marked “1” of Lot 5 Blk. 11, on plan
being S. 4 deg. 13’W., 797.98 m. from B.L. No. 7, Baguio Townsite, thence:
Including the residential house erected therein covered by ARP No. 2009-89-051-85139 of
the records of the Assessor’s Office of Baguio City.
Of which parcel of land, the MORTGAGOR is the absolute owner and present possessor
as evidenced by TCT NO.T-73169 of the records of Register of Deeds of Baguio City, under
Assessment of Real Property ARP No. 2009-89-051-85139 (land) and (ARP) No. 2009-829-
085--84164 (building) of the records of the City Assessor’s Office and Register of Deeds of
Baguio City, free from all liens and encumbrances.
This mortgage shall also stand as security for said obligations and all other obligations of
the MORTGAGOR to the MORTGAGEE of whatever kind and nature whether such obligations
have been contracted before, during or after the constitution of this mortgage.
However, if the MORTGAGOR shall pay the MORTGAGEE, his successors or assigns, the
obligations secured by this mortgage, together with the interest, cost and other expenses, on
or before the date they are due, and shall keep and perform, then this mortgage shall be null
and void, otherwise, it shall remain in full force and effect;
a. Should the MORTGAGEE becomes involved in any litigation which may have relation
with any or all of the properties mortgaged by virtue of this instrument, all expenses of the
MORTGAGEE in such litigation, including a reasonable amount of attorney’s fee to be
determined by the MORTGAGEE, shall be paid by the MORTGAGOR and this mortgage shall
stand as security thereof, and in the event of such litigation, any and all obligations of the
MORTGAGOR shall likewise become immediately due, payable and defaulted;
b. The MORTGAGOR shall not make any alteration upon or demolish any building or
buildings herein mortgaged or encumber the same, without the prior written consent of the
MORTGAGEE;
c. The MORTGAGEE may be a bidder at the sale of the mortgaged properties under
foreclosure proceedings;
d. The MORTGAGOR shall execute such other documents as may be required by the
MORTGAGEE in connection with the loans secured by this mortgage contract subject to the
mutual agreement of both parties;
e. That should the MORTGAGOR duly pay or cause to be paid unto the MORTGAGEE
and the latter’s heirs and assigns, his total indebtedness of SIX HUNDRED THOUSAND
PESOS(Php600,000.00), Philippine currency including its THREE PERCENT (3%) monthly
interest on or before February 1, 2013, then this mortgage shall thereby be discharged and
rendered of no force and effect. Otherwise, the MORTGAGOR does hereby agree that said
JAMES D. CASTRO, may enforce his rights herein without judicial proceedings by causing the
above-described real property to be sold at public auction in Baguio City where the property is
situated in accordance with Act No. 3135, as amended by Act No. 4118;
g. That should the MORTGAGOR fails to pay his debt of SIX HUNDRED THOUSAND
PESOS(Php600,000.00), Philippine currency including its THREE PERCENT (3%) monthly
interest, on the 1st day of February 2012, said MORTGAGOR does hereby agree to pay a
penalty of 1% thereof per month of delay effective on February 1, 2012;
h. That should the MORTGAGOR pay his debt before the 1st day of February 2012, he
will only pay the principal amount of SIX HUNDRED THOUSAND PESOS(Php600,000.00),
Philippine Currency plus accrued interests as of the date of payment; and
i. That the parties hereto agreed to record this instrument under Act No. 496, as
amended and likewise under Act No. 3344.
IN WITNESS WHEREOF, the parties have hereunto set their hands in Baguio City, Philippines,
on this 30th day of November 2012.
BEFORE ME, a Notary Public in and for the City of Baguio, this 30th day of November 2012,
personally appeared RIZALINDA T. AFAGA and HAROLD Y. SANTOS, who have satisfactorily proven
to me their identities through:
both of whom personally know the parties, that they are the same persons who executed and
voluntarily signed the foregoing Real Estate Mortgage which they acknowledged before me as their free
and voluntary acts and deeds.
This instrument consisting of THREE (3) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof
by the parties and their witnesses.
JOSE M. LADIA, LAURO P. LADIA, ABELARDO P. LADIA, all of legal ages, married,
with postal address at LADIA AND SONS LAW OFFICES, 7F Citylight Tower, Bonifacio Rd., Baguio
City, herein represented by ABELARDO P. LADIA by virtue of a Special Power of Attorney executed
on 25 April 1994, and hereinafter referred to as the FIRST PARTIES;
-and-
BAGUIO METROPOLITAN DOCTORS, INC., doing business under the name and style as
PINES METROPOLITAN MEDICAL CENTER, a corporation duly organized and existing under
Philippine laws, with business address at No. 3 Camdas, Baguio City, herein represented by its Medical
Director, MANOLITO D. MORAN, M.D., hereinafter referred to as the SECOND PARTY;
-and-
WITNESSETH:
WHEREAS, the FIRST PARTIES are the plaintiffs in Civil Case No. 95-9233, entitled
“ABELARDO REY P. SUNTAY, et al., versus BAGUIO METROPOLITAN DOCTORS, INC, et
al.," pending in the Regional Trial Court of Baguio City, Branch 6, hereinafter referred to as the
"Pending Case";
WHEREAS the SECOND PARTY and THIRD PARTIES are the defendants in said Pending
Case;
WHEREAS, all the parties are desirous of settling amicably the Pending Case, which has been
pending for almost eight (8) years, and thereby put to rest a long and costly litigation;
NOW, THEREFORE, in consideration of the foregoing premises, the parties hereby undertake
as follows:
1.1. To make available to JOSE M. LADIA a private room at the Makati Medical
Center which is appropriate and adequate, considering his present medical condition,
including the continued use of the hospital bed he is now using and a sofa bed, all
free of charge and for as long as he remains clinically alive and in need of medical
attention; and,
1.2. To provide JOSE M. LADIA, likewise free of charge, medicine, drugs, life-support
systems, medical equipment and other facilities, medical assistance, neurological
treatment and other appropriate medical services from competent nurses, doctors or
specialists – which may be advisable or necessary to maintain him in his present
condition, including treatment of complications or illnesses of whatever kind or
nature which may arise from said treatment or condition.
2. The THIRD PARTIES, individually, undertake to make available their expertise or services
when and as needed by JOSE M. LADIA, upon request by the FIRST PARTIES or the
3. The parties agree to, and shall cause, the dismissal, with prejudice, of the Pending Case,
including all claims and counterclaims therein, and agree not to file any similar case, whether
civil, administrative or criminal, of any kind or nature whatsoever, arising from the same
facts, incident, claim, cause or causes of action.
4. Except as provided in paragraphs 1 and 2 hereof, the parties hereby mutually, irrevocably,
freely and voluntarily release and forever discharge one another, including the officers,
directors, employees, stockholders, successors-in-interest of the SECOND PARTY and the
heirs and assigns of the THIRD PARTIES, from any and all manner of action, causes of
action, sum of money, damages, liability, responsibility, obligation, claims and demands
whatsoever in law or equity, which they had, now have, or may have against each other,
including, but not limited to, actual, moral, exemplary and all other damages or causes of
action provided for under the law, if any, arising, directly or indirectly, from the facts and
circumstances giving rise to, surrounding or arising from the complaint and/or counterclaims
in the Pending Case , all of which claims or causes of action by these presents the parties
hereby abandon and waive.
5. This agreement shall not in any way be construed as an admission on the part of any party of
any fault, negligence or liability, of whatever kind and nature, in connection with the Pending
Case.
6. In case of material breach of the terms and conditions of this agreement, the innocent party is
hereby authorized to apply for a writ of execution in the Pending Case for the purpose of
compelling compliance with the terms and conditions of this agreement.
IN WITNESS WHEREOF, the parties have hereunto set their hands this 3rd day of December
2012 in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 3rd day of December 2012,
personally appeared ABELARDO P. LADIA, MANOLITO D. MORAN, M.D., DRA. MUTYA B.
YUSON, DR. ANGELITO P. BATANG-AMA, and DRA. ANNA C. MANALASTAS who exhibited
to me their respective identification documents as appearing below their respective names and
signatures, known to me as the same persons who executed and voluntarily signed the foregoing
COMPROMISE AGREEMENT which they acknowledged before me as their free and voluntary acts
and deeds.
This instrument consisting of THREE (3) pages, including the page on which this
Acknowledgment is written has been signed on the left margin of each and every page thereof by the
parties and their witnesses.
WITNESS MY HAND AND SEAL on the date and at the place first above-written.
CONTRACT OF EMPLOYMENT
KNOW ALL MEN BY THESE PRESENTS:
KNL PREMIERE FINANCING, a sole proprietorship duly existing under Philippine Laws,
with office address at 3/F Laperal Building, Session Road, Baguio City, herein represented by its sole
proprietor MARITA H. GO, single, of legal age, Filipino Citizen, with residence and postal address at
No. 34 Palma Road, Baguio City, Philippines hereinafter referred to as the EMPLOYER;
-and-
JANE K. MENDOZA, single, of legal age, Filipino Citizen, with residence and postal address
No. 10 Brookspoint, aurora Hill, Baguio City, and hereinafter referred to as the EMPLOYEE.
WITNESSETH:
A. DESIGNATION:
B. SALARY:
The Employee shall be paid a monthly salary of TWENTY THOUSAND PESOS (Php
20,000.00);
C. CONTRACT DURATION:
It is hereby agreed that the EMPLOYEE shall be hired as such for a period of ONE (1)
YEAR which shall be renewable upon the mutual consent and agreement of the parties.
Provided, however, that upon the expiration of this contract any extension of employment
granted to the EMPLOYEE shall not be deemed as automatic renewal and instead should be
covered by a separate contract; Provided, further, that any work extended by the
EMPLOYEE after the expiration of this contract and with the consent of the EMPLOYER
shall be paid PRO RATA;
D. TERMINATION OF CONTRACT:
Either party may pre-terminate this contract, PROVIDED, that the party concerned shall
serve written notice to the other of her intention to terminate the same at least ONE (1)
MONTH prior to the intended termination. PROVIDED, further, that should the
EMPLOYEE desire to terminate this contract she shall surrender any document or
accountability entrusted to her in relation to her employment.
IN WITNESS WHEREOF, the parties have hereunto affixed their signatures this 3rd day of
December 2012 in the City of Baguio, Philippines.
MARITA H. GO
Sole proprietor
Professional Driver’s License No.
A0-01-140577
Valid util May 14, 2014
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 3rd day of December 2012,
personally appeared MARITA H. GO and JANE K. MENDOZA, who exhibited to me their respective
identification documents appearing below their names and signatures, both known to me to be the same
persons who executed and voluntarily signed the foregoing CONTRACT OF EMPLOYMENT and
which they acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this acknowledgment
is written has been signed on the left margin of each and every page thereof by the parties and their
witnesses.
CONTRACT OF EMPLOYMENT
KNOW ALL MEN BY THESE PRESENTS:
KNL PREMIERE FINANCING, a sole proprietorship duly existing under Philippine Laws,
with office address at 3/F Laperal Building, Session Road, Baguio City, herein represented by its sole
proprietor MARITA H. GO, single, of legal age, Filipino Citizen, with residence and postal address at
No. 34 Palma Road, Baguio City, Philippines, and hereinafter referred to as the EMPLOYER;
-and-
WILMAR L. IPAC, single, of legal age, Filipino Citizen, with residence and postal address No.
10 Ambiong Road, Aurora Hill, Baguio City, and hereinafter referred to as the EMPLOYEE.
WITNESSETH:
WHEREAS, the EMPLOYER desires to engage the services of the EMPLOYEE as PERMANENT EMPLOYEE at
KNL PREMIERE FINANCING and the EMPLOYEE is willing to accept, work and extend her services to the EMPLOYER as
desired under the following terms and conditions, to wit:
A. DESIGNATION:
B. SALARY:
The Employee shall be paid a monthly salary of THIRTY THOUSAND PESOS (Php
30,000.00);
C. CONTRACT DURATION:
It is hereby agreed that the EMPLOYEE shall be hired as such for a PERMANENT
PERIOD;
D. TERMINATION OF CONTRACT:
Either party may pre-terminate this contract, PROVIDED, that the party concerned shall
serve written notice to the other of his/her intention to terminate the same at least ONE (1)
MONTH prior to the intended termination. PROVIDED, further, that should the
EMPLOYEE desire to terminate this contract he shall surrender any document or
accountability entrusted to him in relation to his employment.
IN WITNESS WHEREOF, the parties have hereunto set their hands this 4th day of December
2012 in the City of Baguio, Philippines.
MARITA H. GO
Sole proprietor
Professional Driver’s License No.
A0-01-140577
Valid util May 14, 2014
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 4th day of December 2012,
personally appeared MARITA H. GO and WILMAR L IPAC, who exhibited to me their respective
identification documents appearing below their names and signatures, both known to me to be the same
persons who executed and voluntarily signed the foregoing CONTRACT OF EMPLOYMENT and
which they acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this acknowledgment
is written has been signed on the left margin of each and every page thereof by the parties and their
witnesses.
CONTRACT OF LEASE
KNOW ALL MEN BY THESE PRESENTS:
CONCHITA J. HERNANDEZ, single, of legal age, Filipino Citizen, with residence and postal
address at No. 64 Palma Road, Baguio City, Philippines, and hereinafter referred to as the LESSOR;
-and-
JEFFREY I. OLIVAR, single, of legal age, Filipino Citizen, with residence and postal address
No. 123 Ambiong Road, Aurora Hill, Baguio City, and hereinafter referred to as the LESSEE.
WITNESSETH:
WHEREAS, the LESSOR is the lawful, absolute and registered owner of a residential house
located ate No. 5/6 Genesis Point Village, Tuba, Benguet, Philippines, hereinafter referred to as the
LEASED PREMISES;
WHEREAS, LESSEE desires to lease the Leased premises and LESSOR is willing to lease the
same unto the LESSEE, subject to the terms and conditions hereinafter specified:
NOW, THEREFORE, for and in consideration of the forgoing and mutual covenant herein
contained, LESSOR does hereby lease, rent, let and deliver by way of lease unto the LESSEE the
leased premises, and the LESSEE hereby accepts the same, subject to the following terms and
conditions:
1. TERMS. This lease shall be for a fixed period of ONE (1) YEAR commencing on February 1,
2012 and shall expire on February 1, 2013, renewable thereafter upon the mutual agreement of
the parties.
2. RENTAL. The monthly rent for the leased premises shall be SEVENTEEN THOUSAND
PESOS (P17, 000.00) to be paid by the lessee to the lessor within the first ten days of each and
every month without the need of demand.
3. 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 one (1) month and may forfeit whatever rental deposit or advances have been
given by the LESSEE.
4. 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, firm or corporation. 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.
5. APPLIANCES. The leased premises is furnished and provided with appliances. The Lessee
shall be responsible for any and all repairs of appliances damaged through the lease period.
7. 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.
8. 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 property, or to exhibit the leased premises to prospective
LESSEE, or for any other lawful purposes which she may deem necessary.
9. 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 the leased premises with
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 Percent (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.
10. 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 Percent (100%) of the
amount claimed in the complaint as attorney's fees which shall in no case be less than P50,
000.00, in addition to other costs and damages which said party may be entitled to under the law.
11. This CONTRACT OF LEASE shall be valid and binding between the parties, their successors-
in-interest and assigns.
IN WITNESS WHEREOF, parties herein affixed their signatures this 4th day of December 2012
in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 4th day of December 2012,
personally appeared CONCHITA J. HERNANDEZ and JEFFREY I. OLIVAR, who exhibited to me
their respective identification documents appearing below their names and signatures, both known to me
to be the same persons who executed and voluntarily signed the foregoing CONTRACT OF LEASE and
which they acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of THREE (3) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof by the
parties and their witnesses.
CONTRACT OF SERVICES
KNOW ALL MEN BY THESE PRESENTS:
ENGR. SANTIAGO A. TIONGCO, SR., a licensed Geodetic Engineer in the Philippines, with
office address at A-16 Poblacion, La Trinidad, Benguet, Philippines, and hereinafter referred to as the
SURVEYOR,
-and-
MOKI R. MOMOL, of legal age, Filipino Citizen, with residence and postal address at #322
Magsaysay Avenue, Baguio City, Philippines, and hereinafter referred to as the CLIENT.
WITNESSETH:
WHEREAS, the CLIENT is the surviving heir of the late ANDRES B. MOMOL who is the
owner of that parcel of land situated at Pico, La Trinidad, Benguet with an area of 29, 256 sq.m., more
or less and more particularly described in PSU-252483;
WHEREAS, the client desires to engage the services of the SURVEYOR and the latter is willing to accordingly
extend his technical services to the CLIENT;
NOW THEREFORE, the PARTIES have hereunto agreed, as they hereby agree, on the
following stipulations for the foregoing purposes, to wit:
Acting in the interest of the CLIENT, the SURVEYOR shall perform and conduct the
following:
c) Conduct site investigation and issue certifications, if needed, necessary for ongoing and
future cases that arises from PSU-252483 concerning matters within the duration of this
contract, if any;;
d) Testify in court, if necessary and subject to minimal appearance fee, on the correctness and
authenticity of the metes and bounds of the area covered by PSU-252843 and other cases
incidental thereto, such as but not limited to the subdivision and amendment of the approved
plan;;
e) To coordinate with the lead counsel on matters requiring legal action or opinion;
g) Perform any other tasks, included, incidental or inherent to the foregoing as maybe mutually
agreed upon by both Parties.
a. Furnish all pertinent documents for the proper accomplishment of the services of the
SURVEYOR; and
b. Ensure that all surveys are referred to the SURVEYOR, and all fees thereon fully paid and
settled.
The CLIENT bind himself to pay the SURVEYOR a professional’s fee in the amount of
THIRTY THOUSAND (Php.30, 000.00) PESOS upon the execution of this contract.
All services extended by the SURVEYOR during the subsistence of this contract shall
be subject to fees to be agreed upon by the parties based on the current GEP Tariff and to be
paid 50 % before the surveyor executes the said service and 50 % upon conveyance of the final
output; and
The CLIENT likewise agree and bind himself to segregate, by a proper Deed or
Document, a 200 square meter portion of the parcel of land subject of this contract in favor of
the SURVEYOR upon the signing of this contract on the further condition that the CLIENT
has the option to choose the location from which the said portion shall be segregated;
In connection with the 200 square meters portion mentioned above, the SURVEYOR
has requested and the CLIENT has agreed that the proper Deed or Document to be executed
upon the signing of this contract shall be in the name of one of the children of the SURVEYOR,
who as the transferee of such portion is hereby authorized, including his heirs and assigns and
the SURVEYOR himself to take possession and make or introduce any and all improvements
on the portion mentioned above.
GUARANTEE CLAUSE
The CLIENT hereby guarantees that he is duly authorized to represent the heirs of
Andres Pengosro and/or enter into this contract.
The SURVEYOR hereby guarantees that all services subject of this contract shall be
duly executed and performed. Provided, however, that the SURVEYOR will not guarantee, as
he cannot guarantee, the EXPIDITIOUS, IMMEDIATE and/or FAVORABLE APPROVAL
by the proper authorities of said surveys, due to circumstances beyond the control of the
SURVEYOR, such as but not limited to, protest by third person/s or third party/ies as the case
may be;
This contract shall remain in force and effect unless and until both Parties mutually agree
in writing to terminate the terms abovementioned; provided however, that either party is
furnished one (1) month notice prior to termination.
IN WITNESS WHEREOF, parties herein affixed their signatures this 5th day of December 2012
in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 5th day of December 2012,
personally appeared MOKI R. MOMOL and ENGR. SANTIAGO A. TIONGCO, SR., who exhibited
to me their respective identification documents appearing below their names and signatures, both known
to me to be the same persons who executed and voluntarily signed the foregoing CONTRACT OF
SERVICES and which they acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of THREE (3) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof by the
parties and their witnesses.
JOSEFA A. CAROLINA, of legal age, Filipino Citizen, with residence and postal address at
Maria Pucay Road, Guisad, Baguio City, Philippines, and hereinafter referred to as the FIRST PARTY,
-and-
DEMITRI T. SERRANO, of legal age, Filipino Citizen, with residence and postal address at A-
18 Poblacion, La Trinidad, Benguet, Philippines, and herein referred to as the SECOND PARTY;
WITNESSETH:
WHEREAS, the FIRST PARTY desires to engage the services of the SECOND PARTY to drill a DEEP WELL at
MARIA PUCAY ROAD, GUISAD, BAGUIO CITY and the SECOND PARTY is willing to extend his services to the FIRST
PARTY as desired under certain terms and conditions;
NOW THEREFORE, the PARTIES have hereunto agreed, as they hereby agree, on the
following stipulations for the foregoing purposes, to wit:
a) Faithfully and completely furnish to the satisfaction of the FIRST PARTY all
necessary labor, tools, supervision and management of the drilling project;
b) Drill a borehole with a depth of at least TWO HUNDRED (200) feet and a
diameter of not less than SIX (6) inches;
c) Install FOUR (4) inches (diameter) G.I./B.I. pipe casings and perforated/slotted
casings;
d) Install a gravel pack on the annular space between the borehole wall and the
casing;
e) Develop the well by surging and bailing, cement grout the annular space between
the borehole and the lining from the ground surface to FORTY (40) FEET
below/downwards;
g) Clean the drilling site upon its completion and demobilize all equipment, tools
and/or his personnel.
The FIRST PARTY shall pay the total consideration in the amount of EIGHTY
THOUSAND (Php.80, 000.00) PESOS which will cover for the following, to wit:
B. MODE OF PAYMENT
The FIRST PARTY agreed, as she hereby agrees, to pay to the SECOND PARTY
FIFTY (50%) PERCENT of the EIGHTY THOUSAND (Php.80, 000.00) PESOS contract
price upon execution of this contract which represents the partial payment and the other FIFTY
(50%) PERCENT shall be paid upon the purchase of the above-mentioned pipes. But in no case
shall the FIRST PARTY pay an amount in excess of EIGHTY THOUSAND (Php.80, 000.00)
PESOS.
Should the contract price of EIGHTY THOUSAND (Php.80, 000.00) PESOS would
not suffice for the job contract; the SECOND PARTY hereby obliged himself to shoulder the
amount in excess thereof.
C. WORK DURATION
It is hereby agreed upon that the SECOND PARTY shall accomplish the drilling job
within THIRTY (30) to SIXTY (60) DAYS.
IN WITNESS WHEREOF, parties herein affixed their signatures this 5th day of December 2012
in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 5th day of December 2012,
personally appeared JOSEFA A. CAROLINA and DEMITRI T. SERRANO, who exhibited to me
their respective identification documents appearing below their names and signatures, both known to me
to be the same persons who executed and voluntarily signed the foregoing CONTRACT FOR PIECE
OF WORK and which they acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of THREE (3) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof by the
parties and their witnesses.
CONTRACT TO SELL
KNOW ALL MEN BY THESE PRESENTS:
WILSON R. MINOLA, married to MAURIZE O. MINOLA, both of legal age, Filipino Citizens,
with office address at Narda’s Commercial Building, Session Road, Baguio City, Philippines, and herein
referred to as the FIRST PARTY;
-and-
CARMINA G. HARI, married, Filipino Citizen, of legal age, with postal address at No. 68
Maligaya Park Subd.,Quezon City, Philippines, and herein referred to as the SECOND PARTY;
WITNESSETH:
WHEREAS, by virtue of an authority, the FIRST PARTY hereby enters into a contract to sell
with the SECOND PARTY over that parcel of land situated at Alalpang, La Trinidad, Benguet, covered
by Transfer Certificate of Title No. T-52919 and particularly described as follows:
WHEREAS, for and in consideration of the sum of FOUR HUNDRED SEVENTY FIVE
THOUSAND (Php. 475,000.00) PESOS, Philippine currency, paid in hand by the SECOND PARTY,
the PARTIES herein hereby voluntarily enter into this Contract to Sell under the following terms and
conditions:
RELEASE OF TITLE
a. The title to the lot shall be released six (6) to nine (9) months after full payment of the
purchase price thereof and that of the agreed consideration in the contract to build a
residential house thereon;
b. Capital and documentary stamps shall be at the account of the FIRST PARTY while the
Transfer taxes and other related expenses shall be at the account of the SECOND
PARTY;
DEFAULT PROVISIONS
a. If, at any time, the SECOND PARTY fails to pay the balance or scheduled payments
within the required period he/she shall be considered in default, and a penalty as
provided for in item No. 2 hereof shall be charged, and with the option given to the
FIRST PARTY to rescind this contract after the expiration of the grace period and all
advance payments made shall be forfeited in favor of the latter;
b. The provisions herein above-contained shall be without prejudice to the right of the
SECOND PARTY to SELL, TRANSFER or CONVEY his/her rightsand interests
under this contract to qualified party within the grace period allowed and before actual
cancellation of this contract, subject, however, to the written consent of the FIRST
PARTY;
c. Should this contract be cancelled by the SECOND PARTY, the FIRST PARTY shall
refund to the former the cash surrender value of the payments on the property
equivalent to FIFTY (50%) PERCENT of the total payments made, less all expenses
that the latter may have incurred by reason of the execution of the contract, and
expenses that may be incurred for repairs on the premises, if any. Refund is also
exclusive of payments for insurance premiums, agents commissions, electric and
water bills and related expenses, which may have been paid by the FIRST PARTY for
and in behalf of the SECOND PARTY, if any;
d. Except for the stipulations on the mode of payment and other conditions necessary for
the eventual execution of the Deed of Absolute Sale by the FIRST PARTY in favor of
the SECOND PARTY, all other stipulations herein are understood to be made part of
the DEED which shall be executed upon complete/full payment of the consideration of
this contract;
WHEREAS, the FIRST PARTY warrants that the above-described residential house and lot are
free from any lien and/or encumbrance 60 days or less from full payment of the balance;
WHEREAS, the provisions of ART. 1623 of the New Civil Code of the Philippines has been
complied with;
WHEREAS, this contract shall be binding and enforceable upon his/her heirs, assigns and
successors of the parties herein.
IN WITNESS WHEREOF, parties herein affixed their signatures this 5th day of December 2012
in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 5th day of December 2012,
personally appeared WILSON R. MINOLA and CARMINA G. HARI, who exhibited to me their
respective identification documents appearing below their names and signatures, both known to me to be
the same persons who executed and voluntarily signed the foregoing CONTRACT TO SELL and which
they acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of THREE (3) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof by the
parties and their witnesses.
AGREEMENT
KNOW ALL MEN BY THESE PRESENTS:
JASON G. JOANINO, of legal age, Filipino citizens, with residence at Buguias, Benguet,
herein referred to as the FIRST PARTY;
-and-
AMINA K. ORINGO, of legal age, Filipino Citizen with residence at New Lucban, Baguio City, Philippines, herein
referred to as the SECOND PARTY;
WITNESSETH:
WHEREAS, the FIRST PARTY is the registered owner of that TEN WHEELER TRUCK
bearing plate number AYI-223, while the SECOND PARTY is a businesswoman duly authorized to
haul scrap materials from the Benguet Corporation, Balatoc, Itogon, Benguet;
WHEREAS, the SECOND PARTY hereby leased from the FIRST PARTY the
aforementioned truck to haul scrap materials owned by Benguet Corporation from the Balatoc Mines
starting on December 13, 2012 up to June 20, 2014, and the latter on the other hand agreed to lease out
the same to the former;
WHEREAS, this agreement was entered into freely and voluntarily by and between the parties and they shall
faithfully and religiously comply with the terms hereof.
IN WITNESS WHEREOF, parties herein affixed their signatures this 6th day of December 2012
in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 6th day of December 2012,
personally appeared JASON G. JOANINO and AMINA K. ORINGO, who exhibited to me their
respective identification documents appearing below their names and signatures, both known to me to be
the same persons who executed and voluntarily signed the foregoing AGREEMENT and which they
acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of THREE (3) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof by the
parties and their witnesses.
CONTRACT OF SUB-LEASE
KNOW ALL MEN BY THESE PRESENTS:
KIMBERLY J. TAN, of legal age, married, Filipino, with residence and postal address 68
Pacdal, Baguio City, Philippines, and hereinafter referred to as the SUB-LESSOR;
-and-
MITCH C. VOUS, of legal age, married, Filipino and with residence and postal address at
Tuding, Itogon, Benguet, Philippines, and hereinafter referred to as the SUB-LESSEE;
WITNESSETH:
WHEREAS, the SUB-LESSOR is the LESSEE of that business establishment located at Abanao Extension, Baguio
City;
WHEREAS, the SUBLESSOR hereby SUBLEASES that aforementioned building owned by ANTON N. OTNA,
including the FIVE (5) BILLIARD OR POOL TABLE therein, unto the SUBLESSEE;
NOW THEREFORE, the parties have agreed on this contract under the following terms and conditions, to wit:
A. TERM OF SUB-LEASE- TWO (2) YEARS which shall commence and be effective upon the signing of this contract
and shall be renewable upon mutual consent of the parties;
B. RENTAL- The SUB-LESSEE shall pay to the SUB-LESSOR for the use and occupancy of the said stall the amount
of THIRTY THOUSAND (P30, 000.00) PESOS per month payable on or before the 1st day of each calendar month
during the entire duration of this contract. The SUB-LESSEE however shall deposit SIXTY THOUSAND (Php.
60,000.00) PESOS upon the singing of this document. The said deposit however, shall be applied to the last two
months of this contract should the term be completed;
C. SUB-LEASE- The SUB-LESSEE is not allowed under any circumstances to re-sublease the said portion;
D. ADVANCE NOTICE TO VACATE- The SUB-LESSEE shall give the SUB-LESSOR thirty days written notice in
advance of his intention to vacate the premises before the expiration of the term;
E. MAINTENANCE-The SUB-LESSEE shall have the obligation to maintain in good condition the aforementioned
billiard tables including the premises of the leased building. Provided, that any damages to the said billiard tables and
the leased premises during the subsistence of this contract until its termination shall be for the account of the SUB-
LESSEE and the latter shall be obliged to cause the repair of the damage, if any;
F. IMPROVEMENTS- the SUB-LESSEE is allowed to introduce improvements in the said leased premises with the
condition that it will not alter the purpose for which the said premises was leased and the SUB-LESSEE shall not
remove any improvement introduced thereon after the termination of this contract;
G. BREACH OR DEFAULT- Should the SUB-LESSEE violate any of the foregoing terms and conditions, the SUB-
LESSOR shall have the right to terminate and cancel this contract extra-judicially and the latter may then exclude the
former from the premises and shall not be liable to reimburse the SIXTY THOUSAND (Php.60,000.00) PESOS
DEPOSIT;
H. MUNICIPAL SERVICES- the SUB-LESSEE shall be responsible for the payment of all municipal services, such as
but not limited to, water and electrical bills, and that upon the termination of this contract she will surrender the leased
premises free from all unpaid bills, whatsoever;
IN WITNESS WHEREOF, parties herein affixed their signatures this 6th day of December 2012
in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 6th day of December 2012,
personally appeared KIMBERLY J. TAN and MITCH C. VOUS, who exhibited to me their respective
identification documents appearing below their names and signatures, both known to me to be the same
persons who executed and voluntarily signed the foregoing AGREEMENT and which they
acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this acknowledgment
is written has been signed on the left margin of each and every page thereof by the parties and their
witnesses.
MEMORANDUM OF AGREEMENT
KNOW ALL MEN BY THESE PRESENTS:
MERIAM S. SAINGAN, of legal age, Filipino, widow, with residence and postal address at 40
Suello Village, Marcos Highway, Baguio City, and hereinafter referred as the FIRST PARTY;
and
CAMILLE J. SANCHEZ, of legal age, married, Filipino, with postal address at Km. 6, La
Trinidad, Benguet, and hereinafter referred as the SECOND PARTY;
WITNESSETH:
WHEREAS, the SECOND PARTY is indebted to the FIRST PARTY in the principal amount
of ONE HUNDRED FIFTY THOUSAND PESOS (Php 150, 000.00) as of November 22, 1996
receipt of which is already acknowledge by the SECOND PARTY by virtue of that MEMORANDUM
OF AGREEMENT executed on seventeenth (17th) day of May 2012 which loan remains unpaid;
WHEREAS, the same amount had already accumulated into FIVE HUNDRED THOUSAND
SEVEN HUNDRED TWENTY ONE and THIRTY THREE CENTAVOS (Php 500, 721.33)
inclusive of interest and penalties at the rate of twenty six percent (26%) and five percent (5%) per
annum respectively as of 28 November 2012 and the amount of interest is also increasing at the time of
execution of this agreement;
WHEAREAS, the SECOND PARTY hereby agrees to pay the said loan inclusive of interests
and penalties in favor of the FIRST PARTY herein and the latter likewise agrees to accept the same,
under the following terms and conditions, to wit:
1. The SECOND PARTY hereby acknowledge the loan obligation in the aforementioned
MEMORANDUM OF AGREEMENT is still subsisting in the principal amount of ONE
HUNDRED FIFTY THOUSAND (Php 150, 000.00) plus the accumulated interest and
penalties which now has the total amount of FIVE HUNDRED THOUSAND SEVEN
HUNDRED TWENTY ONE and THIRTY THREE CENTAVOS (Php 500, 721.33)
wherein said amount shall be paid on or before August 14, 2013;
2. The SECOND PARTY shall pay the total amount of the loan in nine (9) equal monthly
installments in the amount of FIFTY FIVE THOUSAND SIX HUNDRED TWENTY
FOUR and FIFTEEN CENTAVOS (Php 55, 624.15) commencing in the month of
December 2012 up to August 14, 2013 with the single payment in the last month in the
amount of ONE HUNDRED FOUR THOUSAND PESOS (Php 104, 000.00);
3. Finally, both parties hereby agree to mutually comply in good faith with all the terms and
conditions of this agreement.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 6th day of December 2012,
personally appeared MERIAM S. SAINGAN and CAMILLE J. SANCHEZ, who exhibited to me
their respective identification documents appearing below their names and signatures, both known to me
to be the same persons who executed and voluntarily signed the foregoing MEMORANDUM OF
AGREEMENT and which they acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this acknowledgment
is written has been signed on the left margin of each and every page thereof by the parties and their
witnesses.
INDEMNITY AGREEMENT
KNOW ALL MEN BY THESE PRESENTS:
THAT for the purpose of this contract the said deceased is being represented by one of their
surviving heirs DENISE R. BERNARDO-LAUREL, of legal age, married, Filipino Citizen and with
residence and postal address at North Sanitary Camp, Baguio City, Philippines; by virtue of that Special
Power of Attorney executed by her co-heirs CLARITO R. BERNARDO and HEDILY B. CIUBAL, a
copy of which is hereto attached for easy reference.
WHEREAS, at the time of the respective deaths of the said deceased, they maintained the
following BANK ACCOUNTS:
EPCIB FUND
00-0402-00016-ctf-k US$59,573.23
U.S. DOLLAR FUND
WHEREAS, the surviving heirs of the deceased desire to withdraw the proceeds from the
aforementioned accounts. As such, DENISE R. BERNARDO-LAUREL has presented/submitted,
among others, the original copies of the respective Death Certificates;
WHEREAS, pursuant thereto, the surviving heirs, through their representative and co-heir
herein, hereby release, discharge and free and further undertake to indemnify, Equitable PCI BANK
from any and all liabilities, claims, damages, or other causes of whatever nature that may now exist or
hereafter exist, in connection with the release in their favor the deposits left by their deceased parents.
IN WITNESS WHEREOF, parties herein affixed their signatures this 7th day of December 2012
in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 7th day of December 2012,
personally appeared DENISE R. BERNARDO-LAUREL and MANUEL Q. QUIZON, who exhibited
to me their respective identification documents appearing below their names and signatures, both known
to me to be the same persons who executed and voluntarily signed the foregoing MEMORANDUM OF
AGREEMENT and which they acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this acknowledgment
is written has been signed on the left margin of each and every page thereof by the parties and their
witnesses.
ALBINA SMITH-ABELLERA, of legal age, widow, Filipino Citizen, with residence and
postal address at Montecillo, Camp 7 Barangay, Baguio City, Philippines;
FILOMINA SMITH-BULAHAO, of legal age, widow, Filipino Citizen, with residence and
postal address at Montecillo, Camp 7 Barangay, Baguio City, Philippines;
CARMEN SMITH-PABLO, of legal age, widow, Filipino Citizen, with residence and postal
address at Montecillo, Camp 7 Barangay, Baguio City, Philippines;
AUREA SMITH-MONTE, of legal age, married to Fidel Monte, Filipino Citizen, with
residence and postal address at Montecillo, Camp 7 Barangay, Baguio City, Philippines; and,
AIDA BAWAS-SMITH, of legal age, widow, Filipino Citizen, with residence and postal
address at Montecillo, Camp 7 Barangay, Baguio City, Philippines.
WITNESSETH:
WHEREAS, the above-mentioned parties are the co-owners of that parcel of land situated at
Datakan, Kapangan, Benguet, Philippines, and covered by TCT No.T-1086 containing an area of FIVE
(5) HECTARES by virtue of that Deed of Extrajudicial Settlement of Estate, which was entered in the
Notarial Registry of Jose Velasco as Doc. No. 359; Page No. 23; Book No. I; Series of 1959, and more
particularly described as follows:
Lot 1
Transfer Certificate of Title No. T-1086, Lot 1. Beginning at a point marked 1 on plan F-49403, N. 86-09’
E. 2680.24 m. more or less from B.L.L.M. No.1, Mpl. Dist. of Kapangan, Mt. Province, thence N. 48-43’ E.
62.05 m. to point 2; N. 67-07’ E. 77.72 m. to point 3; N. 64-43’ E. 53.70 m. to point 4; S. 46-22’ W. 98.84
m. to point 5; N. 89-46’ W. 101.27 m. to point 1, point of beginning. With an area of 0.4629 hectare. Point
3 Old G.I.S. in a tree; point 4 Nail in tree; and the rest are B.L. Conc. Mons. Bounded on the North, by
property of Severino Malitas and Public Land; on the Southeast and South, by Creek; and on the
Northwest, by property of Sudimay.
Lot 2
Beginning at a point marked 1 on plan F-49403, N. 86-24’ E. 2493.38 m. more or less from B.L.L.M. No. 1,
Mpl. Dist. of Kapangan, Mt. Prov., thence N. 50-37’ E. 95.96 m. to point 2; S. 50-06’ E. 51.70 m. to point
3; S. 46-06’ E. 45.31 m. to point 4; S. 34-48’ W. 107.07 m. to point 5; S. 58-14’ W. 94.21 m. to point 6; N.
26-53’ W. 119.52 m. to point 7; S. 81-56’ W. 48.37 m. to point 8; N. 49-32’ W. 32.95 m. to point 9; N. 36-
15’ E. 21.68 m. to point 10; N. 85-37’ E. 105.98 m. to point 1, point of beginning. Containing an area of
2.3318 hectares. Point 2, B.L. on Boulder; points 3,5,6 and 7, Nails in trees; Points 4, 8 and 9, B.L. on
Rocks; and the rest are B. L. Conc. Mons. Bounded on the Northeast, by property of Tomas; on the
Southeast, by creek; on the Northwest, by properties of Insas and Mariano Casio; and on the Northwest, by
Creek.
Lot 3
Beginning at a point marked 1 on plan F-49403, N. 85-27’ E. 2473.33 m. more or less from B.L.L.M. No. 1,
Mpl. Of Kapangan, Mt. Province, thence N. 77-08’ E. 222.88 m. to point 2; S. 57-17’ W. 182.42 m. to point
3; S. 80-58’ W. 62.41 m. to point 4; N. 2-06’ W. 58.81 m. to point 1, point of beginning. Containing an area
of 0.8726 hectare. Points 1 and 2, Old B.L. Conc. Mons.; and the rest are B.L. Conc. Mons. Bounded on
Lot 4
Beginning at a point marked 1 on plan F-49403, N. 87-22’ E. 2173.10 m. more or less from B.L.L.M. No. 1
Mpl. Dist. of Kapangan, Mt. Province, thence N. 66-42’ W. 56.61 m. to point 2; N. 6-19’ E. 26.37 m. to
point 3; N. 30-15’ W. 10. 52 m. to point 4; N. 51-16’ E. 19.50 m. to point 5; S. 84-02’ E. 17.30 m. to point
6; N. 60-16’ E. 36.25 m. to point 7; S. 29-05’ m. to point 8; N. 75-58’ E. 54.50 m. to point 9; S. 39-03’ W.
110.75 m. to point 1, point of beginning. Containing an area of 0.5608 hectare. Point 9, Old X on Rock;
and the rest are B.L. Conc. Mons. Bounded on the North by Properties of Da-aya, Sabelo and Insas; on the
Southeast, by property of Locloc Serafino; on the Southwest, by property Locloc Serafino; and on the West,
by properties of Bagtang and Da-aya. Bearings True. Declination 1-30’ E. Points referred to are marked
on plan F-49403, Sheet No. 2 Surveyed under authority of Sections 41-43 Act No. 2874 and in accordance
with existing regulations of the Bureau of Lands, by Nemesio Albano, Jr. Surveyor, under the supervision
of Gregorio L. Arizabal, Public Land Surveyor, on July 22-25, 1931 and approved on May 20, 1933.
Lot 5
Beginning at a point marked 1 on plan F-49403, S. 87-13’ E. 1943.96 m. more or less from B.L.L.M. No. 1
Mpl. Dist. of Kapangan, thence S. 45-32’ m. 9.07 m. to point 2; N. 21-47’ E. 7.52 m. to point 3; N. 42-20’
W. 8.54 m. to point 4; N. 55-20’ W. 11.04 m. to point 5; S. 73-29’ W. 14.31 m. to point 6; N. 25-01’ W.
63.13 m. to point 7; N. 76-11’ E. 53.73 m. to point 8; S. 57-07’ E. 43.90 m. to point 9; S. 10-26’ W. 15.14
m. to point 10; S. 29-35’ W. 33.59 m. to point 11; N. 80-74’ W. 6.24 m. to point 12; S. 20-46’ W. 13.11 m.
to point 1, point of beginning. Containing an area of 0.4355 hectare. Pointsnd 9, B.L. Conc. Mons.; and the
rest are Old B.L. Conc. Mons. Bounded on the Northwest, by property of Tella; on the Southeast, by
properties of Tella and Laoyan Baporo; on the Southwest, by property of Geraldo Pilpilic; and on the
Northwest, by Public Land. Bearings True. Declination 0-21’ E. Points referred to are marked on Plan F-
49403, Sheet No. 3. Surveyed under authority of sections 41-43 Act No. 2874 and in accordance with
existing regulations of the Bureau of Lands, by Teodoro Salanga, Public Land Surveyor, on April 3,1935
and approved on May 4, 1937.
Lot 6
Beginning at a point marked 1 on plan 49403, S. 87-14’ E. 2624.71 m. more or less from B.L.L.M. No. 1
Mpl. Dist. of Kapangan, thence S. 27-59’ E. 95.19 m. to point 2; S. 34-42’ E. 9.49 m. to point 3; S. 39-32’
w. 36.26 m. to point 4; N. 59-38’ W. 26.85 m. to point 5; N. 15-59’ W. 77.88 m. to point 6; N. 29-22’ E.
36.01 m. to point 1, point of beginning. Containing an area of 0.3910 hectare. Point 4, B.L. on stone; point
5, Old X on Stone; Point 6, Old B.L. Conc. Mon.; and the rest are B.L. Conc. Mons. Bounded on the
Northwest, Public Land; on the Southeast, by Public Land; on the Southwest, by property of of Locloc
Serafino; and on the Northwest, by property of Vintiria. Bearing true. Declination 0-21’ E. Points referred
to are marked on plan F-49403, Sheet No. 4. Surveyed under the authority of Section 41-43 Act No. 2874
and in accordance with existing regulations of the Bureau of Lands, by Ricardo R. Quilop, Jr. Surveyor,
under the supervision of Gaudencio Fantony, Public Land Surveyor, on April 6, 1936 and approved on
May 4, 1937.
WHEREAS, the parties have caused the subdivision of the above-described real property into
SIX (6) lots as per Subdivision Plan 1230 and they have partitioned and adjudicated among themselves
the said property and as indicated in Transfer Certificate of Title No. 1086 as follows:
1. LOT 1 and 2 with an area of 0.4629 HECTARES shall be adjudicated in favor of ALBINA
SMITH-ABELLERA;
2. LOT 3 shall be adjudicated in favor of FILOMINA SMITH-BULAHAO;
3. LOT 4 shall be adjudicated in favor of CARMEN SMITH-PABLO;
4. LOT 5 shall be adjudicated in favor of AUREA SMITH-MONTE;
5. LOT 6 shall be adjudicated in favor of AIDA BAWAS-SMITH;
WHEREAS, the copy of Transfer Certificate of Title No. 1086 is hereto attached and made as
integral part hereof;
WHEREAS, the parties hereby request, the Register of Deeds of Benguet to issue individual
Titles in accordance with this partition agreement.
IN WITNESS WHEREOF, parties herein affixed their signatures this 7th day of December 2012
in the City of Baguio, Philippines.
AIDA BAWAS-SMITH
Professional Driver’s License No.
A03-01-1403327
Valid util May 14, 2014
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 7th day of December 2012,
personally appeared ALBINA SMITH-ABELLERA, FILOMINA SMITH-BULAHAO, CARMEN
SMITH-PABLO, AUREA SMITH-MONTE and MANUEL AIDA BAWAS-SMITH, who exhibited
to me their respective identification documents appearing below their names and signatures, both known
to me to be the same persons who executed and voluntarily signed the foregoing PARTITION
AGREEMENT OF A REGISTERED LAND WITH SIMULTANEOUS WAIVER and which they
acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of FOUR (4) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof by the
parties and their witnesses.
ARTHUR P. BANASEN, of legal age, single, Filipino Citizen with residence and postal address
at Montecillo, Camp 7 Barangay, Baguio City, Philippines and herein referred to as the FIRST
PARTY;
WILSON BANASEN, married to Sharon R. Banasen, both of legal age, Filipino Citizens and
residents of Montecillo, Camp 7 Barangay, Baguio City, Philippines and herein referred to as the
SECOND PARTY;
-and-
AMOR B. SEGUNDO married to Ferdinand B. Segundo, both of legal age, Filipino Citizens
and residents of Montecillo, Camp 7 Barangay, Baguio City, Philippines and herein referred to as the
THIRD PARTY;
WITNESSETH:
WHEREAS, by virtue of that DEED OF DONATION OF REGISTERED LOT entered in the
notarial registry of SHIRLEY JANE MALAYA-NACHOR as Doc. No. 85: Page No. 45: Book No. V:
Series of 2012 dated June 14, 2012; the above-named PARTIES are the co-owners of that parcel of land
situated at Montecillo, Camp 7 Barangay, Baguio City, Philippines containing an area of THREE
WHEREAS, the PARTIES herein caused the subdivision of the aforementioned parcel of land
into THREE (3) lots;
WHEREAS, by virtue of that Approved Consolidation Subdivision Plan of LOTS 1-F-C-1, 1-F-
C-2, 1-F-C-3 Psd-CAR-013970 bearing number Pcs-CAR-001126 as prepared for Arthur P. Banasen,
et.al., the parties herein hereby Subdivide, Partition and Adjudicate amongthemselves the
aforementioned parcel of land as follows, to wit:
1. Lot 1-F-C-1, Psd-CAR-013970 with an area of ONE HUNDRED SIXTEEN (116) SQUARE
METERS shall be adjudicated in favor of AMOR B. SEGUNDO, THIRD PARTY herein. A
copy of the Technical Description of Lot 1-F-C-1, Psd-CAR-013970 is hereto attached and
made part hereof;
2. Lot 1-F-C-2, Psd-CAR-013970 with an area of ONE HUNDRED THIRTY SIX (136)
SQUARE METERS, shall be adjudicated in favor of ARTHUR P. BANASEN the FIRST
PARTY, herein. Copy of the Technical Description of i Lot 1-F-C-2, Psd-CAR-013970 is
hereto attached and made part hereof; and
3. Lot 1-F-C-3, Psd-CAR-013970 with an area of ONE HUNDRED TWENTY SEVEN (127)
SQUARE METERS, shall be adjudicated in favor of WILSON P. BANASEN the FIRST
PARTY, herein. Copy of the Technical Description of i Lot 1-F-C-2, Psd-CAR-013970 is
hereto attached and made part hereof.
WHEREAS, the parties hereto hereby request, the Registrar of Deeds of Benguet to issue
individual Titles in accordance with this partition agreement and as per the Approved Consolidation
Subdivision Plan of LOTS 1-F-C-1, 1-F-C-2, 1-F-C-3 Psd-CAR-013970 bearing number Pcs-CAR-
001126 a copy of which is hereto attached for reference.
WHEREAS, the above-described parcel of land is in the possession of the PARTIES herein;
IN WITNESS WHEREOF, parties herein affixed their signatures this 10th day of December
2012 in the City of Baguio, Philippines.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 10th day of December 2012,
personally appeared ARTHUR P. BANASEN, WILSON BANASEN and AMOR B. SEGUNDO,
who exhibited to me their respective identification documents appearing below their names and
signatures, both known to me to be the same persons who executed and voluntarily signed the foregoing
PARTITION AGREEMENT and which they acknowledged before me as their free and voluntary acts
and deeds.
This instrument consisting of THREE (3) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof by the
parties and their witnesses.
CONTRACTORSHIP CONTRACT
KNOW ALL MEN BY THESE PRESENTS:
FATIMA CHEYEANNE D. PEREZ, of legal age, Filipino citizen, with residence and postal
address at No. 98 Purple Lane, Ridgewood Subdivision, Guisad Road Baguio City, Philippines,
hereinafter referred to as OWNER,
-and-
PINERS BUILDERS, INC., a company duly organized and existing under the laws of the
Philippines, with principal office and address at No. 39 Upper Bakakeng, Baguio City, Philippines,
represented herein by its ENGR. RON PAULO S. MADLAING, hereinafter referred to as
CONTRACTOR.
WITNESSETH:
WHEREAS, the OWNER is desirous that certain works, namely the Finishing Works of a
Three-Storey Residential Building, located at the property compound at Ridgewood Subdivision,
Guisad Road, Baguio City, Philippines, hereinafter referred to as the “PROJECT”, be provided and
executed by the CONTRACTOR on a Lump Sum Cost Contract basis for its Design & Construct,
Supply & Installation, and has accepted a tender by the CONTRACTOR for the execution and
completion of the PROJECT and the remedying of any defects therein;
WHEREAS, the CONTRACTOR represents and warrants that it has the sufficient experience,
capabilities and competence to undertake the WORKS with its full sincerity, cooperation, good faith and
equality;
WHEREAS, the CONTRACTOR has offered its services and the OWNER has accepted the
offer of the CONTRACTOR to undertake the aforesaid specified WORKS under the terms and
conditions hereinafter specified;
NOW, THEREFORE, for and in consideration of the foregoing premises and the mutual
covenants and undertakings hereinafter set forth, the parties hereto agree as follows:
I. Payment Schedule:
“PROGRESS PAYMENT”. The OWNER shall pay to the CONTRACTOR, for work
accomplished based on progress billings, not more than twice a month, submitted by the
CONTRACTOR to the OWNER and recommended for payment by the Construction Manager. Payment
of progress billings shall be made within FIVE (5) working days after submission of the billing duly
certified by the Representative. All payments shall be subject to recoupment of advance payment.
No payments made, by virtue of the provisions, shall be construed as a waiver of claims by the
CONTRACTOR for any defect in the PROJECT WORKS.
(ii) The CONTRACTOR fails to maintain work-quality standards as specified in the drawing &
specifications and as required by the OWNER.
(iii) The CONTRACTOR fails to assign full-time qualified, experienced & competent Project
Manager, Construction Foremen, and Engineer Supervisor and trades craftsmen.
(iv) The CONTRACTOR fails to comply with any of the other terms and conditions of this
Agreement.
The CONTRACTOR shall be entitled to payment under this contract ONLY. In the event of the
amount of the estimated cost remaining unpaid shall exceed the expenses incurred by the OWNER up to
such excess, but should the balance be less than the aforementioned expenses for the completion of the
Works, the CONTRACTOR shall pay the amount of such additional expenses to the OWNER, based
on the actual prevailing prices of materials, labor and equipment rentals PLUS an attendance fee
equivalent to five (5%) percent of the total expenses incurred to complete the Works.
The Parties have entered into this Agreement in accordance with the Laws of the Philippines on
the date hereof.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 10th day of December 2012,
personally appeared FATIMA CHEYEANNE D. PEREZ and ENGR. RON PAULO S.
MADLAING, who exhibited to me their respective identification documents appearing below their
names and signatures, both known to me to be the same persons who executed and voluntarily signed
the foregoing CONTRACTORSHIP AGREEMENT and which they acknowledged before me as their
free and voluntary acts and deeds.
This instrument consisting of FOUR (4) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof by the
parties and their witnesses.
III.MOTIONS
MOTION an application to the court requesting an order or rule in favor of the applicant
NOTICE OF HEARING
GREETINGS!
Please submit the foregoing motion to the Honorable Court immediately upon receipt thereof for
its consideration and approval without further arguments.
Copy Furnished:
PRAYER
WHEREFORE, premises considered and in view of the foregoing, it is respectfully prayed to
the Honorable Court that the recommended bond of Php50,000.00 will be reduced to Php30,000.00
CASH.
Other relief and remedies just and equitable under the premises are likewise prayed for.
Greetings!
Please submit the foregoing motion to the Honorable Court immediately upon receipt thereof for
its consideration and approval without further arguments.
Copy Furnished:
MIGUEL C. TIONGCO,
Plaintiff,
Civil Case No.: 6234-R
- versus –
FOR COLLECTION OF SUM OF
RONUEL J. SANTIAGO, MONEY
Defendant.
x---------------------------------x
PRAYER
WHEREFORE, it is respectfully prayed that Defendant RONUEL J. SANTIAGO be declared
in default pursuant to the Rules of Court and that the Honorable Court proceed to render judgment as the
complaint may warrant.
Other reliefs just and equitable are likewise prayed for.
GREETINGS!
Please take notice that on 18 December 2012 at 8:30 in the morning or soon thereafter as counsel
may be heard, the undersigned will request the Honorable Court to approve the foregoing Motion
Declare Defendant in Default without further argument and appearance from counsel.
JOSEPH E. VILLAVICENCIO,
Plaintiff,
Civil Case No.: 6633-R
- versus –
FOR COLLECTION OF SUM OF
BOHN R. SORIANO, MONEY
Defendant.
x---------------------------------x
PRAYER
WHEREFORE, it is respectfully prayed of this Honorable Court to render judgment on the
pleadings.
Greetings!
Please be informed that the foregoing motion is set for hearing on Friday, 21 December 2012 at
9:00 am or as soon as there after as counsel may be heard.
WHEREFORE, defendant most respectfully prays that an order be issued by this Honorable
Court requiring the plaintiff to make a more definite statement as to the particulars of the check
mentioned in paragraph 5 of its complaint, particularly stating its amount, check number, date, and the
name of the drawee bank.
NOTICE OF HEARING
The Clerk of Court
RTC, Branch 6
Baguio City
Greetings!
Please be informed that the undersigned will request the Honorable Court to approve the
foregoing Motion Declare Defendant in Default without further argument and appearance from
counsel on Friday, 21 December 2012 at 11:00 am.
2. That the basis of the Honorable Public Prosecutor in charging the Accused with Estafa is the
provision on other deceits under Article 318 of the Revised Penal Code stating among others
that, “the respondent or even his corporation do not actually own the lot sold to the Private
Complainant, the respondent must be held liable under Article 318 of the Revised Penal Code”.
3. That the Accused should have been charged for ESTAFA under ARTICLE 315 Paragraph 2a
of the Revised Penal Code, and not under Article 318, which provides that, ESTAFA could be
committed by means of false pretenses or fraudulent acts executed prior to or simultaneously
with commission of the fraud by using a fictitious name, or falsely pretending to possess power,
influence, qualifications, PROPERTY, credit, agency, business transactions; or by means of
other similar deceits;
4. That the Affidavit Complaint of the Private Complainant stated therein that the Accused obtained
money from the Private Complainant in the amount of FOUR HUNDRED THOUSAND
PESOS (PHP400,000.00) to be used to build a house over a property which the Accused offered
to the Private Complainant. It turned out however that the land was not the property of
LORENZO K. MARIANO or in the name of his corporation. With all the representations and
false pretenses made by the Accused that he owned a property and assuming the obligation to
build a house thereon but subsequently no property or building was erected, shows that indeed
the Accused only deceived the Private Complainant to obtain his money;
5. That the act of the Accused in misrepresenting that he is the owner of a lot being the subject of a
house and lot package to obtain money from the Private Complainant and misappropriating the
6. That the Private Complainant, BRENT N. SERQUIÑA, respectfully requests that a RE-
INVESTIGATION be conducted on the above-entitled case to resolve whether or not the case
falls within the ambit of ARTICLE 315 Paragraph 2a constituting the crime of ESTAFA by
falsely pretending to possess property and not ARTICLE 318 of the Revised Penal Code;
7. That this Motion is not in any manner intended to cause delay in the speedy disposition of this
instant case or to frustrate the ends of justice.
PRAYER
WHEREFORE, premises duly considered, it is most respectfully prayed of the Honorable Court
to GRANT this Motion for RE-INVESTIGATION and to issue an Order for the RE-INVESTIGATION
of the above-entitled case.
Such other relief as law and justice may warrant are likewise prayed for.
Respectfully submitted this 18th day of December 2012, in the City of Baguio, Philippines.
With my conformity:
FRANCO MONTALBAN
Public Prosecutor
PROSECUTOR’S OFFICE
Justice Hall, Baguio City
Please submit the foregoing Motion for the approval and consideration of the Honorable Court
immediately upon receipt hereof.
PROSECUTOR’S OFFICE
Justice Hall, Baguio City
PEDRO Y. SENIOR,
Plaintiff,
Civil Case No.: 8809
-versus-
FOR COLLECTION OF SUM OF
FACUNDO M. KITMA, MONEY WITH DAMAGES
Defendant.
x---------------------------------x
PRAYER
WHEREFORE, it is respectfully prayed that an order of execution of the decision be issued.
Respectfully submitted this 19th day of December 2012, in the City of Baguio, Philippines.
Glover Rais B. Sumail - Registered mail with return card due to the distance Defendant
of the office.
Please take notice that on 27 December 2012 at 10:30 o’clock in the morning undersigned
Counsel will submit the foregoing MOTION FOR EXECUTION OF JUDGMENT for the kind
consideration and approval of the Honorable Court and set the above-entitled case for hearing on the
said date and time.
PRAYER
WHEREFORE, premises considered, it is respectfully prayed to the Honorable Court to
reconsider and set aside the said order and that the Motion to Appeal as Pauper Litigant be heard
together with this motion for Reconsideration.
Other reliefs and remedies just and equitable under the premises are likewise prayed for.
Greetings!
Please note that on 26 December 2012, at 8:30 o’clock in the morning or as soon as the
undersigned counsel may be heard, he will submit the foregoing motion for the consideration and
approval of the Honorable Court.
Copy Furnished:
WHEREFORE, plaintiff respectfully prays that he be granted additional fifteen (15) days from
10 January 2013, or until 25 Jnauary 2013, within which to submit plaintiff’s Reply.
Greetings!
Please note that on 3 January 2013, at 8:30 o’clock in the morning or as soon as the undersigned
counsel may be heard, he will submit the foregoing motion for the consideration and approval of the
Honorable Court.
Copy Furnished:
MOTION TO QUASH
The Accused, by counsel and unto this Honorable Court, respectfully moves to quash the
Information filed against him for the crime of Theft on the following grounds:
GROUNDS
(1) IT CONTAINS AVERMENTS WHICH, IF TRUE, WOULD CONSTITUTE A LEGAL
JUSTIFICATION;
(2) THIS COURT IS WITHOUT JURISDICTION.
ARGUMENTS
The Information alleges that the Accused JANUARY P. ISAAC is eleven (11) years old and
without any known address. Under article 12, paragraph 3 of the Revised Penal Code, a person over nine
years of age and under fifteen, unless he acted with discernment, is exempt from criminal liability.
There is no allegation that the accused acted with discernment. Even granting that said
discernment was present, the Accused cannot be tried but instead should be proceeded against pursuant
to Article 80 of the Revised Penal Code, which provides that a minor, unless sixteen years of age at the
time of a grave or less grave felony, cannot be tries but instead shall have the benefit of a suspension of
all proceedings against him. The duty of the court would be to commit the minor to the custody or care
of a public or private benevolent or charitable institution for the care and education of the homeless and
delinquent children or to the custody of the Department of Social Welfare and Development.
Greetings!
Please note that on 2 January 2013, at 8:30 o’clock in the morning or as soon as the undersigned
counsel may be heard, he will submit the foregoing motion for the consideration and approval of the
Honorable Court.
Copy Furnished:
WHEREFORE, it is respectfully prayed that probable cause be judicially determined and for
this Honorable Court to issue warrant of arrest against the accused RAMON N. ITTO, MIGUEL C.
LAZARO and CONRADO L. MANOLO.
City of Baguio, Philippines; 28 December 2012.
Greetings!
Please note that on 2 January 2013, at 8:30 o’clock in the morning or as soon as the
undersigned counsel may be heard, he will submit the foregoing motion for the consideration and
approval of the Honorable Court.
IV. NOTICES
NOTICE "information concerning a fact, actually communicated to a person by an authorized person, or actually derived by
him from a proper source."
DEMAND LETTER
18 January 2013
I write in behalf of Mr. REY DELA PENA and Mrs. DELA PENA of #30, St. Patrick
Please be reminded that you have encroached upon a portion of their property
located in the above-stated address and from the time you started to so encroach,
your occupation of said portion is merely tolerated by the said owners. Demand was
made upon you orally to vacate the property but you refused.
Demand is being made upon you to vacate the portion you have encroached
within fifteen (15) days from receipt of this letter or else my clients will have no option
left but to file the appropriate case/s against you in the proper courts.
Thank you.
- versus -
ANTHONY CAPLAC,
Respondent.
x -------------------------------------------- x
ANNABEL SANTUCAY
Counsel for Defendant
MA 163 Puguis,
La Trinidad, Benguet
Ms. SANTUCAY:
This is to notify the parties that pursuant to Rule 23 of the Revised Rules of Civil
Procedure, the testimony, upon oral examination of ANITA UMALI, whose address is at #55
Poblacion, Marinduque, Philippines, as a last witness, will be taken on February 5, 2013 at
2:00 in the afternoon before the Honorable Court, or before the Clerk of Court of Branch 9. The
circumstances of this deposition as are provided in the motion are as follows:
1. The witness’s testimony will corroborate certain portions of the testimony of the
Petitioner, especially as to the fact that from the start of their marriage until their
separation, the petitioner and the respondent have not lived together as husband and
wife, that the petitioner and the respondent each manifest certain traits and behavior
patterns that are indicative of their respective inabilities to perform their marital
obligations towards each other;
2. In view of her announced change or residence, and because of the fact that she resides
at a City more than 100 kilometers away from La Trinidad, Benguet, the deposition will
be taken.
-versus-
AIDA MONTES,
Defendant.
x-----------------------------------x
Sir:
Please take notice that a parcel of land covered by TCT. No 3322 located in Upper
Tomay, La Trinidad, Benguet, registered in the name of defendant is the subject matter of an
action for Reconveyance of an undivided one-sixth portion thereof filed by ALI MAIN, above-
named plaintiff. Accordingly, please make the corresponding entries in the books of your
Registry in the manner provided by law.
Respectfully submitted.
ANNABEL SANTUCAY
Counsel for Defendant
MA 163 Puguis, La Trinidad, Benguet
Roll No. 75432, 05/05/10
PTR No. 334255, 2/10/13, La Trinidad, Benguet
IBP No. 98776, 1/04/13, Baguio-Benguet Chapter
MCLE COMPLAINCE No. 887649
Copy furnished:
Sir:
I, BRIAN DELOS SANTOS, after first being sworn according to law, do hereby state:
1. That I have an adverse claim in that certain registered real property, covered by TCT No. T-
04522 of the Registry of Deeds of the Province of Benguet, particularly described as follows:
2. That I bought said land from MR. SAM DONG, but since I was a minor at the time of the
purchase, I requested MR. AL SANTIAGO, my uncle, to register the same in the latter’s name
for my benefit and to be held in trust for me. My uncle agreed and so the land was registered in
his name.
3. That I am the real and actual owner of said property, and not the registered owner thereof, and to
protect my interest thereto as actual owner, this adverse claim is being registered on said TCT,
to warn any third person from buying the same.
WHEREFORE, I hereby request the Register of Deeds of Benguet Province to register this
adverse claim in the manner provided by law.
SUBSCRIBED AND SWORN to before me in La Trinidad, Benguet, this 10th day of January
2013, by Brian Delos Santos, personally known to me, who is the same person who personally signed
before me the foregoing affidavit and acknowledged that he executed the same.
- versus -
WALANG MALAY,
Respondent.
x -------------------------------------------- x
This is to notify for the death of EWAN MALAY, the Petitioner in this case. The fact of
death is evidenced by a Certificate of Death issued by the Local Civil Register of La Trinidad,
Benguet attached hereto as Annex “A”.
ANNABEL SANTUCAY
For the Petitioner
MA 163 Puguis, La Trinidad, Benguet
Roll No. 75432, 05/05/10
PTR No. 334255, 2/10/13, La Trinidad, Benguet
IBP No. 98776, 1/04/13, Baguio-Benguet Chapter
MCLE COMPLAINCE No. 887649
Copy furnished:
Explanation: Service of the foregoing was made by registered mail, due to the distance of their
office from that of the undersigned.
MARIA DUKUSEN
Respondent.
x----------------------------------------x
NOTICE OF HEARING
ANNABEL SANTUCAY
Counsel for Petitioner
MA 163 Puguis,
La Trinidad, Benguet
Ms. SANTUCAY:
This is to notify the parties that the above-captioned case is set for hearing on 25
January 2013 at 9:00 o'clock in the morning.
ROBERT DUKUSEN
Defendant.
x----------------------------------------x
NOTICE OF HEARING
ANNABEL SANTUCAY
Counsel for Defendant
MA 163 Puguis,
La Trinidad, Benguet
Ms. SANTUCAY:
This is to notify the parties that the above-captioned case is set for hearing on 28
January 2013 at 8:30 o'clock in the morning.
- versus -
LORENZO BADWAD,
Respondent.
x -------------------------------------------- x
ANNABEL SANTUCAY
Counsel for Petitioner
MA 163 Puguis,
La Trinidad, Benguet
Ms. SANTUCAY:
This is to notify the parties that pursuant to Rule 23 of the Revised Rules of Civil
Procedure, the testimony, upon written interrogatories of NOVER MAN, whose address is at
#55 Poblacion, Marinduque, Philippines, as a last witness, will be taken on March 5, 2013 at
9:00 in the morning before the Clerk of Court of Branch 4. The circumstances of this deposition
as are provided in the motion are as follows:
3. The witness’s testimony will corroborate certain portions of the testimony of the
Petitioner, especially as to the fact that from the start of their marriage until their
separation, the petitioner and the respondent have not lived together as husband and
wife, that the petitioner and the respondent each manifest certain traits and behavior
patterns that are indicative of their respective inabilities to perform their marital
obligations towards each other;
4. In view of her announced change or residence, and because of the fact that she resides
at a City more than 100 kilometers away from Baguio City, the deposition will be taken.
PETITION is a formal written request or prayer for a certain thing to be done. It connotes an application in
writing addressed to a court or judge, stating facts and circumstances relied upon as a cause for judicial action,
and containing a prayer for relief.
PLEADINGS statements, in logical and legal form, of the facts that constitute plaintiff's cause of action and
defendant's ground of defense. They are either allegations by the parties affirming or denying certain matters of
fact, or other statements by them in support of derogation of certain principles of law, which are intended to
have the effect of disclosing to the court the real matter in dispute.
MISCELLANEOUS PLEADINGS these are the documents attached to the main pleadings, or being issued as
another independent pleading other than the compliant or answer.
A. CIVIL CASES
JOEY D. SOTTO,
Plaintiff,
Civil Case No.: 000081
- versus -
FOR: DAMAGES
VIC S. DE LEON,
Defendant.
x-------------------------------------x
APPEARANCE AS COUNSEL
CLERK OF COURT
Regional Trial Court
Branch 7, Baguio City
SIR:
Please enter the appearance of the undersigned as counsel for the defendant in the above titled
case for all legal purposes.
RESPECTFULLY SUBMITTED.
8 January 2013.
ANNIE M. UY,
Plaintiff,
Civil Case No.: 000081
- versus -
FOR: COLLECTION OF SUM OF MONEY
JACK’S RESTAURANT, INC.,
Defendant.
x-------------------------------------x
Please make of record the WITHDRAWAL of the undersigned ATTY. GELIE ERIKA P.
ESTEBAN and the SUBSTITUTION of the undersigned ATTY. MARIA RUFFA MILLAN as counsel
for plaintiff ANNIE M. UY with her express conformity as indicated below. Henceforth kindly address
all pertinent notices to the undersigned new counsel ATTY. MARIA RUFFA MILLAN at the address
given below.
RESPECTFULLY SUBMITTED.
8 January 2013.
COPY FURNISHED:
MEMO R. ATTA,
Petitioner,
Civil Case No.: 000053
- versus -
FOR: RESCISSION OF CONTRACT
CAMILLE PANGANIBAN and CARS M. INATO, WITH DAMAGES
Respondent.
x-------------------------------------x
PETITION
COMES NOW, petitioner, by the undersigned counsel, most respectfully states:
(1) That petitioner is Filipino, of legal age, and a resident of 098 Gibraltar, Baguio City where he
may be served with summons and other court processes, while respondent is Filipino, of legal
age, a friend of petitioner, and a resident of Apartment No. 99 Quirino Hill, Baguio City where
she may be served with summons and other court processes;
(2) That on 20 March 2012, petitioner bought from respondent the former’s TOYOTA VIOS,
described in attached document ANNEX 1 and to be delivered on 20 July 2012, for SIX
HUNDRED THOUSAND PESOS (P600,000.00) payable on equal monthly installments upto 20
July 2012. Said sale was evidenced by a Contract of Sale herein attached as ANNEX 2;
(3) That petitioner had already paid two monthly installments totaling to THREE HUNDRED
THOUSAND PESOS (P300,000.00) as of 20 May 2012;
(4) That three (3) days after lastest payment, petitioner learned that respondent already transferred
said property to CARS M. INATO, their common acquaintance, through a Deed of Donation on
25 July 2012 without reserving any sufficient property to answer for her obligation and in fraud
of petitioner pursuant to ARTICLE 1387 of the CIVIL CODE OF THE PHILIPPINES;
(5) That due to said fraud, petitioner was deprived of Three Hundred Thousand Pesos (P300,000.00)
and suffered damages;
(6) That there are no other legal means to obtain reparation for such damages sustained, so petitioner
was constrained to file the instant petition engaging him to pay FIFTY THOUSAND PESOS
(P50,000.00) for legal services or attorney’s fees; and
(7) That this action for rescission with damages was commenced within the Four (4) year period
allowed under ARTICLE 1389 of the CIVIL CODE OF THE PHILIPPINES.
(2) I have read the foregoing Petition and the allegations therein are true and correct of my own
knowledge and/or based on the records on hand; and
(1) I have not commenced any other action or proceeding involving the same issues in the Supreme
Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency;
(2) No such action or proceeding is pending in the Supreme Court, the Court of Appeals, or different
Divisions thereof, or any other tribunal or agency; and
(3) If I should 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 hereby undertake to notify this Honorable Court within five (5) days from such notice.
IN WITNESS WHEREOF, I have hereunto affix my signature this 9th day of January 2013 in
the City of Baguio, Philippines.
MEMO R. ATTA
Affiant
Passport ID No. AW9334210
Atty Isagani Calderon 153 | L L B I I I - A
School Year 2012-2013 Second Semester
LEGAL FORMS
SUBSCRIBED AND SWORN to before me, in the City of Baguio, this 9th day of January 2013,
by the affiant who has satisfactorily proven his identity to me through his Passport Identification Detail
indicated below his name, that he is the same person who personally signed the foregoing document
before me and who acknowledged that he executed the same.
JULIO V. MARAVILLA,
Petitioner,
Civil Case No.: 00038-R
- versus -
FOR: JUDICIAL PARTITION
BEATRICE MARAVILLA-ESTANIO
and REGINA V. MARAVILLA,
Respondent.
x-------------------------------------x
PETITION
COMES NOW, petitioner, by the undersigned counsel and unto this Honorable Court,
respectfully states that:
(1) Petitioner is a Filipino citizen, of legal age, single, and resident of #23 Breeze Homes, Pias Road,
Camp 7 Barangay, Baguio City where he may be served with summons and other court
processes;
(3) Petitioner and respondents are the legitimate children and sole heirs of their deceased father
PATRICIO O. MARAVILLA who died intestate on 12 December 2011, as evidenced by his
death certificate herein attached as ANNEX 1;
(a) One (1) parcel of land located at Crystal Cave, Baguio City, covering 750 square meters,
more particularly described by Transfer Certificate of Title No. 9238 herein attached as
ANNEX 2, and
(b) Six (6) parcel of lands located at Woodsgate, Camp 7, Baguio City, covering a total of
1,500 sq. m. and more particularly described in Transfer Certificate of Title No. 3333-B
herein attached as ANNEX 3;
(5) Deceased left no indebtedness or obligations chargeable against his intestate estate;
(6) Petitioner and respondents, however, failed to agree on project partition of said parcel of land,
leading petitioner to institute this ordinary action for partition pursuant to SECTION 1, RULE 74
of the RULES OF COURT and thereby committing him to pay FIFTEEN THOUSAND PESOS
(P15,000.00) for legal services.
WHEREFORE, petitioner respectfully prays that judgment be rendered in his favor: (1)
ORDERING the partition and segregation of ONE-THIRD (1/3) portion belonging to petitioner of the
Atty Isagani Calderon 155 | L L B I I I - A
School Year 2012-2013 Second Semester
LEGAL FORMS
parcel of land described in paragraph 4[a] hereof; (2) ORDERING the partition and segregation of the
ONE-THIRD (1/3) portion belonging to petitioner of the six (6) parcels of land described in paragraph
4[b] hereof; (3) ORDERING respondents to pay petitioner FIFTEEN THOUSAND PESOS
(P15,000.00) as Attorney’s Fees; and (4) ORDERING such other reliefs as this court may deem just and
equitable under the circumstances.
(2) I have read the foregoing Petition and the allegations therein are true and correct of my own
knowledge and/or based on the records on hand; and
(1) I have not commenced any other action or proceeding involving the same issues in the Supreme
Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency;
(2) No such action or proceeding is pending in the Supreme Court, the Court of Appeals, or different
Divisions thereof, or any other tribunal or agency; and
(3) If I should 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 hereby undertake to notify this Honorable Court within five (5) days from such notice.
INA M. OTTO,
Plaintiff,
Civil Case No.: 000023
- versus -
FOR: COLLECTION OF SUM OF MONEY
KAREN L. SISON,
Defendant.
x-------------------------------------x
COMPLAINT
COMES NOW, plaintiff, by counsel and unto this Honorable Court, respectfully states that:
(1) Plaintiff is a Filipino, of legal age, and a resident of 67 Green Valley Subdivision, Baguio City
where she may be served with summons and other processes;
(2) Defendant is also a Filipino, of legal age, and a resident of 12 Brgy. Camp Allen, Baguio City
where she may be served with summons and other processes;
(3) On 10 January 2011 and over a period of six (6) months, defendant borrowed certain amounts
from plaintiff totaling to NINE HUNDRED THOUSAND PESOS (P900,000.00), and promised
to pay these amounts on or before 20 November 2012 as evidenced by three (3) promissory notes
herein attached as ANNEX A, ANNEX B and ANNEX C.
(4) When the due date arrived and despite repeated demands thereafter, both oral and written,
defendant failed or refused to pay said amount;
(5) Resort to Barangay Conciliation process proved futile as defendant failed to appear despite being
duly notified. Thus, a Certification to File Action, a copy of which is attached as ANNEX D, was
issued by the Barangay Chairperson;
(6) Defendant’s obligation is due and demandable, and plaintiff is entitled to the payment of the
entire amount of Nine Hundred Thousand Pesos (P900,000.00);
(7) By reason of defendant’s unreasonable failure or refusal to pay his due and demandable
obligation, plaintiff was forced to engage the services of a counsel to vindicate his rights
committing himself to pay legal services amounting to Fifty Thousand Pesos (P50,000.00).
(2) I have read the foregoing Petition and the allegations therein are true and correct of my own
knowledge and/or based on the records on hand; and
(1) I have not commenced any other action or proceeding involving the same issues in the Supreme
Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency;
(2) No such action or proceeding is pending in the Supreme Court, the Court of Appeals, or different
Divisions thereof, or any other tribunal or agency; and
(3) If I should 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 hereby undertake to notify this Honorable Court within five (5) days from such notice.
INA M. OTTO
Affiant
Driver’s License No. A01-12-032984
Issued: 10/12/2012; Baguio City
SUBSCRIBED AND SWORN to before me, in the City of Baguio, this 10th day of January
2013, by the affiant who has satisfactorily proven her identity to me through her Driver’s License
indicated below her name, that she is the same person who personally signed the foregoing document
before me and who acknowledged that she executed the same.
PROCOPRIO B. ANDRES,
Plaintiff,
Civil Case No.: 000044-R
- versus -
FOR: ANNULMENT OF DOCUMENT
ROMEO N. BONIFACIO,
Defendant.
x-------------------------------------x
COMPLAINT
COMES NOW, plaintiff, by counsel and unto this Honorable Court, respectfully states that:
(1) Plaintiff is a Filipino, of legal age, single, and a resident of 67 Green Valley Subdivision, Baguio
City where he may be served with summons and other processes, while defendant is also a
Filipino, of legal age, single, a friend of plaintiff, and a resident of 13 Brgy. Camp Allen, Baguio
City where he may be served with summons and other processes;
(2) Plaintiff owns a MOTOR VEHICLE, hereinafter referred to as personalty, which is described as
follows:
(3) Petitioner and defendant agreed to enter into a contract of sale wherein the former shall sell the
second personalty to the latter in exchange for money. However, as no amount was ever agreed
upon by them, the contract was never made;
(4) On 17 November 2012, defendant borrowed the personalty for business purposes and petitioner,
a good friend as he was, lent said personalty to the former on condition that the personalty be
returned ten (10) days thereafter;
(5) However, on the date of the supposed delivery, defendant refused to deliver said personalty and
claimed that he bought the same from petitioner. Defendant, through fraud, showed petitioner
their purported DEED OF ABSOLUTE SALE dated 17 November 2012, herein attached as
ANNEX 1, in which said personalty was allegedly sold for and in consideration of SEVEN
HUNDRED FIFTY THOUSAND PESOS (P750,000) and which contained the forged signature
of the latter;
(6) The events led petitioner to obtain legal services of a counsel and to institute the instant
complaint for annulment of the abovementioned document, thereby committing him FIFTY
THOUSAND PESOS (P50,000.00) as Attorney’s Fees; and
PRAYER
WHEREFORE, plaintiff most respectfully prays this Honorable Court to render judgment in his
favor:
(1) ANNULLING the Deed of Absolute Sale dated 17 November 2012;
(2) ORDERING restitution of the possession of the personalty described in paragraph 2 hereof to
plaintiff;
(3) ORDERING defendant to pay plaintiff FIFTY THOUSAND PESOS (P50,000.00) as Attorney’s
Fees;
(4) ORDERING other just and equitable reliefs as it may deem proper.
(1) I have read the foregoing Petition and the allegations therein are true and correct of my own
knowledge and/or based on the records on hand; and
(1) I have not commenced any other action or proceeding involving the same issues in the Supreme
Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency;
(2) No such action or proceeding is pending in the Supreme Court, the Court of Appeals, or different
Divisions thereof, or any other tribunal or agency; and
IN WITNESS WHEREOF, I have hereunto affix my signature this 11th day of January 2013 in
the City of Baguio, Philippines.
PROCOPRIO B. ANDRES
Affiant
Driver’s License No. A01-12-035555
Issued: 10/13/2012; Baguio City
SUBSCRIBED AND SWORN to before me, in the City of Baguio, this 11th day of January
2013, by the affiant who has satisfactorily proven his identity to me through his Driver’s License
indicated below his name, that he is the same person who personally signed the foregoing document
before me and who acknowledged that he executed the same.
KIM C. SALVADOR,
Plaintiff,
Civil Case No.: 000044-R
- versus -
FOR: RECONVEYANCE OF PROPERTY
MAJA S. CHIU,
Defendant.
x-------------------------------------x
COMPLAINT
COMES NOW, plaintiff, by the undersigned counsel and unto this Honorable Court,
respectfully states that:
(1) Plaintiff is a Filipino, of legal age, single, and a resident of 201 Upper Woodsgate, Barangay
Camp 7, Baguio City where she may be served with summons and other court processes, while
defendant is a Filipino, of legal age, married to Gerald A. Chiu, and a resident of 33 Montecillo,
Barangay Camp 7, Baguio City where she may be served with summons and other court
processes;
(2) Plaintiff and defendant are sisters and two of the children of JUAN T. SALVADOR, hereinafter
referred to as the deceased, who died on 1 June 2007 and left a parcel covering 450 square
meters of land at 33 Montecillo, Barangay Camp 7, Baguio City described in TCT No. 1029-B
herein attached as ANNEX A;
(3) Right after the burial of deceased, defendant requested from plaintiff and their other sibling
SANTA F. SALVADOR that she be allowed to take possession and receive income generated by
the subject property until after her eldest son could graduate from college, to which request the
sisters acceded;
(4) After her eldest son XIAN S. CHIU graduated college, defendant was asked by plaintiff and their
other sibling to return the subject property so they could partition the same among themselves.
Defendant, however, refused to relinquish possession of said property to the prejudice of her
other sisters;
(5) Due to defendant’s refusal to return possession of the subject property, plaintiff was forced to
institute the foregoing action, committing her to pay FIFTEEN THOUSAND PESOS
(P15,000.00) as consideration for legal services rendered by counsel.
(2) I have read the foregoing Petition and the allegations therein are true and correct of my own
knowledge and/or based on the records on hand; and
(1) I have not commenced any other action or proceeding involving the same issues in the Supreme
Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency;
(2) No such action or proceeding is pending in the Supreme Court, the Court of Appeals, or different
Divisions thereof, or any other tribunal or agency; and
(3) If I should 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 hereby undertake to notify this Honorable Court within five (5) days from such notice.
KIM C. SALVADOR
Affiant
TIN No. 999-111-333-000
Issued: 10/13/2012; Baguio City
SUBSCRIBED AND SWORN to before me, in the City of Baguio, this 11th day of January
2013, by the affiant who has satisfactorily proven her identity to me through her Tax Identification
Detail indicated below her name, that she is the same person who personally signed the foregoing
document before me and who acknowledged that she executed the same.
JENNELYN M. GUTIERREZ,
Petitioner,
Civil Case No.: 0009
- versus -
CARLO A. GUTIERREZ,
Respondent.
x-------------------------------------x
(2) Petitioner and respondent are married to each other since 19 May 2000, as evidenced by their
marriage contract herein attached as ANNEX 1, under the regime of conjugal partnership of
gains;
(3) For almost nine (9) years, they lived together, with their only child MANILYN M. GUTIERREZ
now six (6) years old, whose birth certificate is herein attached as ANNEX 2, in the
abovementioned address of petitioner as a happy family.
(4) However, on 16 March 2010, respondent left, without any notice and justifiable cause, petitioner
and their child. Petitioner exerted every effort to contact and find respondent until one and a half
(1 ½) later she saw the latter with another woman while walking along Session Road;
(5) On the same day, petitioner confronted respondent who, unfortunately, ignored her. Two (2)
days later, petitioner received a letter, herein attached as ANNEX 3, from respondent stating,
among others, “Hindi na kita mahal. Magkanya-kanya na tayo x x x”;
(6) Due to the abandonment by respondent for more than a year, without any justifiable cause,
petitioner commenced this instant action which committed her to engage legal services of
counsel amounting to FIFTY THOUSAND PESOS (P50,000.00);
(7) The children of petitioner and respondent are in petitioner’s custody and are being supported by
her financially and emotionally;
(8) Petitioner, however, cannot provide for all the financial needs of the children as she is only
earning a limited amount of money from her work whereas respondent is gainfully employed and
earns more than enough for his own personal needs. Petitioner earns only EIGHTEEN
THOUSAND PESOS (P18,000.00) a month from her work as shown by her payslip attached as
ANNEX 4, whereas respondent earns FORTY FIVE THOUSAND PESOS (P45,000.00) a month
PRAYER
WHEREFORE, plaintiff most respectfully prays this Honorable Court to render judgment in
her favor (1) GRANTING legal separation of petitioner and respondent; (2) AWARDING permanent
custody of the minor children to petitioner, with express acknowledgement of the respondent’s visitation
rights; (3) AWARDING monthly support in the amount of TWENTY THOUSAND PESOS
(P20,000.00) for the minor child, subject to adjustments to be made depending on changes in earning
capacity and needs of the children; (3) ORDERING respondent to pay plaintiff FIFTY
THOUSAND PESOS (P50,000.00) as Attorney’s Fees; and (4) ORDERING other just and equitable
reliefs as it may deem proper.
(2) I have read the foregoing Petition and the allegations therein are true and correct of my own
knowledge and/or based on the records on hand; and
(1) I have not commenced any other action or proceeding involving the same issues in the Supreme
Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency;
(2) No such action or proceeding is pending in the Supreme Court, the Court of Appeals, or different
Divisions thereof, or any other tribunal or agency; and
IN WITNESS WHEREOF, I have hereunto affix my signature this 14th day of January 2013 in
the City of Baguio, Philippines.
JENNELYN M. GUTIERREZ
Affiant
TIN No. 242-101-873-000
Issued: 10/13/2012; Baguio City
SUBSCRIBED AND SWORN to before me, in the City of Baguio, this 14th day of January
2013, by the affiant who has satisfactorily proven her identity to me through her Tax Identification
Detail indicated below her name, that she is the same person who personally signed the foregoing
document before me and who acknowledged that she executed the same.
(1) Petitioner is a Filipino citizen, of legal age, and married to respondent. For purposes of this
petition, she may be served with notices and other pertinent processes through counsel at 3F La
Azotea Bldg., Session Road, Baguio City;
(2) Respondent is a Filipino citizen, of legal age, currently employed at Summer Palace Hotel, and
married to the petitioner. He may be served with summons and other pertinent processes at #23
Lower East Camp 7, Baguio City;
(3) Petitioner and respondent were married on 25 March 1990 and out of this marriage, they have 2
children – ROBERT B. VILLAVICENCIO (15 years old) and JEDI MAE B. VILLAVICENCIO
(6 years old). A copy of the Marriage Contract executed by petitioner and respondent is attached
as ANNEX A; a copy of each of the birth certificates of the minor children is attached as
ANNEXES B and C, respectively;
(4) Petitioner and respondent are currently separated in fact and have been so since May 2012. The
reason for the continuing separation in fact is the breakdown of the marriage due to respondent’s
psychological incapacity, which existed at the time of the marriage in 1990 and manifested well
during the marriage, to fulfill and discharge his marital obligations to petitioner;
(5) Respondent’s psychological incapacity to remain married with petitioner appears to be incurable;
prior to this resort, the parties had attempted formal and informal counseling sessions, all of
which proved unproductive as respondent was resistant and even hostile at times to these efforts;
(6) Respondent’s psychological incapacity is classified in clinical terms as being consistent with
“301.20 Schizoid Personality Disorder with narcissistic features” which is further described as
“grave, incurable and has antecedents.” The psychological make-up of respondent is explained in
greater detail in his Clinical Assessment Report dated 20 February 2012, a copy of which is
attached as ANNEX D;
(7) The children of petitioner and respondent are in petitioner’s custody and are being supported by
her financially and emotionally;
(8) Petitioner, however, cannot provide for all the financial needs of the children as she is only
earning a limited amount of money from her work whereas respondent is gainfully employed and
Atty Isagani Calderon 170 | L L B I I I - A
School Year 2012-2013 Second Semester
LEGAL FORMS
earns more than enough for his own personal needs. Petitioner earns only EIGHTEEN
THOUSAND PESOS (P18,000.00) a month from her work as shown by her payslip attached as
ANNEX E, whereas respondent earns FORTY FIVE THOUSAND PESOS (P45,000.00) a
month from his work as shown by his payslip attached as ANNEX F. the common property of
the parties is likewise insufficient for the support of the children.
VERIFICATION
I, SARAH JADE B. VILLAVICENCIO, subscribing under oath, hereby deposes and states
that:
(2) I have read the foregoing Petition and the allegations therein are true and correct of my own
knowledge and/or based on the records on hand; and
(1) I have not commenced any other action or proceeding involving the same issues in the Supreme
Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency;
(3) If I should 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 hereby undertake to notify this Honorable Court within five (5) days from such notice.
IN WITNESS WHEREOF, I have hereunto affix my signature this 15th day of January 2013 in
the City of Baguio, Philippines.
SUBSCRIBED AND SWORN to before me, in the City of Baguio, this 15th day of January
2013, by the affiant who has satisfactorily proven her identity to me through her Social Security Service
Identification Card indicated below her name, that she is the same person who personally signed the
foregoing document before me and who acknowledged that she executed the same.
JAMES J. SMITH,
Petitioner,
Civil Case No.: 0001-F
- versus -
ANNE CURTIZ-SMITH,
Respondent.
x-------------------------------------x
COMES NOW, petitioner, by counsel and unto this Honorable Court, respectfully states that:
(1) Petitioner is a Canadian citizen, of legal age, and divorced to respondent under the Canadian law.
For purposes of this petition, he may be served with notices and other pertinent processes
through counsel at 3F La Azotea Bldg., Session Road, Baguio City;
(2) Respondent is a Filipino citizen, of legal age, currently employed at Summer Palace Hotel, and
divorced to petitioner. She may be served with summons and other pertinent processes at her
postal address #55 Ambiong, Barangay Aurora Hill, Baguio City;
(3) Petitioner and respondent met in Canada and fell in love with each other. They were married in
Canada on 20 March 2005, as evidenced by their marriage contract herein attached as ANNEX 1
and a photograph of the ceremony herein attached as ANNEX 2, which was held valid within the
jurisdiction of Philippines pursuant to ARTICLE 26 of the FAMILY CODE;
(4) Thereafter, respondent returned to the Philippines to watch over the construction of their family
home located in at Woodsgate, Barangay Camp 7, Baguio City. Five years after the marriage,
when petitioner went to the Philippines to check on his wife and their home, he discovered that
his wife was having an affair with another man;
(5) Hurt and disappointed, petitioner returned to Canada and filed a petition for divorce which was
granted by the Superior Court of Justice of Ontario, Canada on 8 December 2011. A decree of
divorce, herein attached as ANNEX 3, was issued and subsequently became effective on 8
January 2012;
(6) Three months after the divorce, petitioner moved on and met another Filipina LEA NINA C.
SALONGA, of legal age and a resident of 43 Upper Engineer’s Hill, Baguio City;
(7) Desiring now to remarry, petitioner instituted the instant proceedings for the acknowledgement
of the aforementioned foreign decree of divorce.
VERIFICATION
I, JAMES J. SMITH, subscribing under oath, hereby deposes and states that:
(2) I have read the foregoing Petition and the allegations therein are true and correct of my own
knowledge and/or based on the records on hand; and
(1) I have not commenced any other action or proceeding involving the same issues in the Supreme
Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency;
(2) No such action or proceeding is pending in the Supreme Court, the Court of Appeals, or different
Divisions thereof, or any other tribunal or agency; and
(3) If I should 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 hereby undertake to notify this Honorable Court within five (5) days from such notice.
JAMES J. SMITH
Affiant
Passport ID No. AB504966
Issued: 01/12/2012; Ontario, Canada
SUBSCRIBED AND SWORN to before me, in the City of Baguio, this 16th day of January
2013, by the affiant who has satisfactorily proven his identity to me through her Passport Identification
Card indicated below his name, that she is the same person who personally signed the foregoing
document before me and who acknowledged that he executed the same.
B. CRIMINAL CASES
Republic of the Philippines)
City of Baguio::::::::::::::::::::::)S.S.
x------------------------------------x
COMPLAINT-AFFIDAVIT
I, PSY GANGNAM, of legal age, single, Filipino Citizen, with residence and postal
address at #69 Irisan, Baguio City, Philippines (but may be notified at First ATM Loans and
Credit Corporation (FALCC), Room 305, 3rd Floor Samson Building, Lower Mabini Street,
Baguio City, after having duly sworn to an oath in accordance with law do hereby depose and
state the following, to wit:
1. That I am the manager of First ATM Loans and Credit Corporation (FALCC) with
office address at 3rd Floor, Room 305, Samson Building, Lower Mabini Street,
Baguio City and am authorized to file this complaint;
2. That on behalf of First ATM Loans and Credit Corporation, I am filing this
complaint for ESTAFA, or any appropriate charges as the evidence may warrant,
against KIM JONG IL for knowingly, unlawfully and feloniously defrauding First
ATM Loans and Credit Corporation (FALCC) in the manner stated below:
3. That KIM JONG IL, of legal age, Filipino and a resident of #123 Mabini St.
Baguio City worked for First ATM Loans and Credit Corporation (FALCC) as a
collector from January 1, 2012 up to his suspension on January 15, 2013;
4. That his duties, among others, are to collect payments of loans for and in behalf
of FALCC; to issue official receipts; and to remit the same to the company-
designated cashier;
6. That KIM JONG IL by machinations created two dummy accounts in the name of
“KIM IL SUNG” and “KIM CHIU IL”, and had the loans approved with the
purported names or accounts and thereafter received, took and misappropriated
the said loan amounts;
7. That on January 30, 2013 a formal demand (Annex “A”) has been made upon
Mr. KIM JONG IL demanding that he return the amount of Two Hundred
Thousand Five Hundred Sixty Three Pesos and 28/100 (P200,563.28) within
five (5) days from his receipt thereof. But despite such demand, he failed,
refused and still fails and refuses, to return the same;
8. That also marked as Annex “B” and in series are the Affidavits executed by
different clients of First ATM Loans and Credit Corporation (FALCC) stating that
indeed they paid to Mr. KIM JONG IL certain amounts as part of their loans to the
Corporation with the expectation that Mr. KIM JONG IL will remit the same;
9. That as per our continuous investigation, to date, Mr. KIM JONG IL has carried
away a total amount of Two Hundred Twenty Three Thousand, Two Hundred
PSY GANGNAM
Affiant
SUBSCRIBED AND SWORN to before me this 14th day of February, 2013 at Baguio
City.
KRISTOFER J. CORPUZ
Asst. City Prosecutor
CERTIFICATION
I HEREBY CERTIFY that I have personally examined the affiant and I am fully satisfied that he
has read and understood his statement and that he executed the same freely and voluntarily.
KRISTOFER J. CORPUZ
Asst. City Prosecutor
COMPLAINT-AFFIDAVIT
I, PSY GANGNAM, of legal age, single, Filipino Citizen, with residence and postal
address at #69 Irisan, Baguio City, Philippines, after having duly sworn to an oath in
accordance with law do hereby depose and state the following, to wit:
1. That I know the person KIM JONG IL, hereafter referred to as “Respondent”, who is
a resident #69 Grande Island Magsaysay Road, Baguio City, Philippines;
3. That the said check is drawn against the account of the said Respondent at
Metrobank with Account No.12345-1234;
5. However, when the above-mentioned check was deposited, the same was
dishonored and returned by the bank on the ground that the same was drawn
against a “CLOSED ACCOUNT.” A true and faithful machine reproduction of the
said check is hereto attached as Annex “A”;
6. As such I immediately notified said Respondent of the dishonor and return of the
said check and demanded from him that he make good the said check within
FIFTEEN (15) days from receipt thereof. A true and faithful machine reproduction of
my demand letter to him is hereto attached as Annex “B”;
7. That when said Respondent failed to heed my demands, I endorsed the said check
to my legal counsel who immediately sent a formal demand letter through registered
mail with return card on January 25, 2013, which was personally received by the
said Respondent on January 15, 2013. As of date however, the Respondent has
unjustifiably ignored all these demands to pay the said account and/or to redeem the
said returned check. A true and faithful machine reproduction of my demand letter to
him is hereto attached as Annex “C”;
PSY GANGNAM
Affiant
SUBSCRIBED AND SWORN to before me this 14th day of February, 2013 at Baguio
City.
KRISTOFER J. CORPUZ
Asst. City Prosecutor
I HEREBY CERTIFY that I have personally examined the affiant and I am fully satisfied that he
has read and understood his statement and that he executed the same freely and voluntarily.
KRISTOFER J. CORPUZ
Asst. City Prosecutor
COMPLAINT-AFFIDAVIT
I, PSY GANGNAM, of legal age, single, Filipino Citizen, with residence and postal
address at #69 Irisan, Baguio City, Philippines, after having duly sworn to an oath in
accordance with law do hereby depose and state the following, to wit:
1. That sometime in December 03, 2012, I was recruited to work as a Maintenance
Engineer in MOBIL ONE’s Oil Refinery located in the Kingdom of Saudi Arabia;
3. That after arriving at the Manpower’s office with all the necessary documents as stated
in their advertisement, located at #69 Magsaysay Road, Baguio City, I was scheduled
for an immediate interview by a certain KIM JONG IL;
4. That during the said interview, KIM JONG IL boasted about the thousands of workers
which he has already sent to various countries in the Middle East as shown by
Manpower’s supposed numerous awards and citations posted on the walls of the office
of the said interviewer;
5. That after such interview, I was informed that I had all the necessary requirements
except the mandatory placement fee of One Hundred Thousand Pesos (Php
100,000.00) which they required as soon as I was able to pay such amount.
6. That after a month thereafter, or on January 03, 2013, I was able to raise such amount
through various loans from my relatives which I promptly paid to Manpower through KIM
JONG IL;
7. That after such payment I was scheduled to return for my employment papers and other
credentials after a week, or on January 10, 2013;
8. That after returning a week later, I was shocked to discover that the offices of
Manpower were already abandoned and that there wasn’t a trace to be found of the
said agency;
9. That thereafter, I learned, after inquiring about Manpower’s authority to conduct such
recruitment services from the Department of Labor and Employment (DOLE), that it was
never issued a valid license or authority to engage in recruitment and placement by the
Secretary of Labor and Employment nor did such agency exist in their records;
11. That because Manpower through its owner KIM JONG IL gave the distinct impression
that he had the power or ability to send me abroad for work such that I was convinced to
part with my hard-earned money in order to be deployed, I am hereby filing this
complaint against the Respondents for Illegal Recruitment or the violation of the
provisions of Republic Act 8042.
PSY GANGNAM
Affiant
SUBSCRIBED AND SWORN to before me this 14th day of February, 2013 at Baguio
City.
KRISTOFER J. CORPUZ
Asst. City Prosecutor
CERTIFICATION
I HEREBY CERTIFY that I have personally examined the affiant and I am fully satisfied that he
has read and understood his statement and that he executed the same freely and voluntarily.
KRISTOFER J. CORPUZ
Asst. City Prosecutor
COMPLAINT-AFFIDAVIT
I, PSY GANGNAM, of legal age, single, Filipino Citizen, with residence and postal
address at #69 Irisan, Baguio City, Philippines, after having duly sworn to an oath in
accordance with law do hereby depose and state the following, to wit:
1. That sometime on January 2, 2013, at about 6:30 p.m., while I was going home
from work, I passed by some people drinking alcohol along the street;
2. That while passing through, by accident I was pushed by one of them while he was
moving backward and I refer to the one who bumped me as a certain Mr. KIM JONG
IL;
4. That after a while his companion, a certain Mr. KIM SONG IL, aka “Nanoy”, asked
me what was my problem and I told him there is none. Then he said, (“Di pa tapos
and atraso mo sa amin ng misis ko,”) Your fault to me and wife has not been settled
yet. Which I completely knew nothing about.
5. That immediately after this his companion in drinking buddies held my hands, neck
and legs;
6. That I told them I will not fight but they did not listen and together they boxed and
mauled me on different parts of my body causing me a lot of injuries and they also
used iron pipe to strike me to which I suffered a 10-inch wound in my head, a fractured left
leg and two broken ribs due to the severe beating, and I have was hospitalized for 16
days and advised to get a complete rest for 4 weeks or more until my leg brace will be removed
and my ribs will be completely healed and I am attaching to this complaint the medical
certificates to attest to my wounds and injuries. A true and faithful machine
reproduction of my Medical Certificate is hereto attached as Annex “A”;
7. That because of these physical injuries I was feeling pain all over my body;
8. That the said complaint was referred to the Lupon Tagapamayapa but the
respondents did not appear despite notice;
9. That the said complaint was now certified for filing to the proper government office;
10. That also because of these mauling and injuries I am hereby filing this criminal
complaint for Physical Injuries against the respondents, Mr. KIM JONG IL, MR.
KIM SING IL, aka “Nanoy”, KIM CHIU IL AND JOHN DOES , and they may be
subpoenaed at the #21 Torres Bugallon St, Baguio City;
PSY GANGNAM
Affiant
SUBSCRIBED AND SWORN to before me this 14th day of February, 2013 at Baguio
City.
KRISTOFER J. CORPUZ
Asst. City Prosecutor
CERTIFICATION
I HEREBY CERTIFY that I have personally examined the affiant and I am fully satisfied that he
has read and understood his statement and that he executed the same freely and voluntarily.
KRISTOFER J. CORPUZ
Asst. City Prosecutor
COMPLAINT-AFFIDAVIT
I, PSY GANGNAM, of legal age, single, Filipino Citizen, with residence and postal
address at #69 Irisan, Baguio City, Philippines, after having duly sworn to an oath in
accordance with law do hereby depose and state the following, to wit:
1. That I am instituting this CRIMINAL COMPLAINT against KIM JONG IL, of legal
age, single, Filipino, and a resident of #70 Irisan, Baguio City, Philippines for ORAL
DEFAMATION as defined and penalized under Article 353 in relation to Article 358
of the Revised Penal Code of the Philippines;
b. The statement was uttered by KIM JONG IL on JANUARY 24, 2013 publicly
and clearly prompted not by any sense of moral duty but by personal ill-will,
spite and/or malice with the object of destroying my reputation and
discrediting and ridiculing me as an individual before the bar of public opinion
and contempt;
4. That I am executing this affidavit to attest to the truth of the foregoing averments and
for the purpose of criminally prosecuting said KIM JONG IL for ORAL
DEFAMATION/SLANDER for his grave utterances as determined by the
Prosecution Office in the preliminary investigation.
PSY GANGNAM
Affiant
SUBSCRIBED AND SWORN to before me this 14th day of February, 2013 at Baguio
City.
KRISTOFER J. CORPUZ
Asst. City Prosecutor
CERTIFICATION
I HEREBY CERTIFY that I have personally examined the affiant and I am fully satisfied that he
has read and understood his statement and that he executed the same freely and voluntarily.
KRISTOFER J. CORPUZ
Asst. City Prosecutor
COMPLAINT-AFFIDAVIT
I, OPPA GANGNAM, 10 yrs. of age, Filipino Citizen, with residence and postal address
at #69 Irisan, Baguio City, Philippines, after having duly sworn to an oath in accordance with
law do hereby depose and state the following, to wit:
12. That the accused, KIM JONG IL, is my uncle, being that his wife, KIM CHIU IL, is the
sister of my father PSY GANGNAM, and our neighbor, residing at #70 Irisan, Baguio
City;
13. That on January 24, 2013, at around 8:00 P.M., I heard the accused whistle for me;
14. That I went to the accused, thinking that he was going to send me on an errand,
whereupon, the accused brought me near a bench in the yard, and told me to remove
my underwear, otherwise he would kill me;
15. That the accused then embraced my, pulled out his penis and inserted his penis into my
vagina. The accused also prompted to wrap my legs around his midsection. All the
while, the accused kept on threatening me that (“Sasaktan kita kung papalag ka o kung
isusumbong mo ito kahit kanino”) “I will hurt you if you resist or if you tell anyone about
this”;
16. That while in this position, my mother, MINDA GANGNAM, saw what was being done to
me, whereupon, the accused upon seeing my mother, put me down and grabbed a
piece of wood, telling my mother that he was trying to kill some rats;
17. That my mother got angry and she pulled me inside the house and spanked me so that I
would tell the truth about what was going on;
18. That when my mother found out that I had no underwear I told her about everything that
happened;
19. That I was brought by my mother to the Baguio General Hospital where I was physically
examined, and after which, members of the local police asked me some questions
about the incident;
20. That the very next day, January 25, 2013, I was brought to the Justice Hall of Baguio to
file charges against the accused;
21. That upon consultation with my lawyer, I understand that the acts of the accused qualify
for RAPE punishable under Article 266-A of the Revised Penal Code;
22. That Article 266-A of the Revised Penal Code provides that RAPE is committed 1) by a
man who shall have carnal knowledge of a woman under any of the following
circumstances: xxx a) through force, threat or intimidation xxx;
23. That I am executing this complaint-affidavit to attest to the truth of the foregoing facts
and for the purpose of filing a criminal complaint for RAPE against the accused.
OPPA GANGNAM
Affiant
SUBSCRIBED AND SWORN to before me this 14th day of February, 2013 at Baguio
City.
KRISTOFER J. CORPUZ
Asst. City Prosecutor
CERTIFICATION
I HEREBY CERTIFY that I have personally examined the affiant and I am fully satisfied that he
has read and understood his statement and that he executed the same freely and voluntarily.
KRISTOFER J. CORPUZ
Asst. City Prosecutor
This is to certify that Ms. OPPA GANGNAM, 10 years old, with residence at #69 Irisan,
Baguio City, was examined and related in this hospital on January 24, 2013, with the following
findings
- Shallow healed lacerations at 3 and 8 oçlock positions
- In a non-virgin state physically
Issued this 24th day of January 2013, for whatever purposes it may serve
This certificate is issued by authority of the Director.
COMPLAINT-AFFIDAVIT
I, OPPA GANGNAM, of legal age, married, Filipino Citizen, with residence and postal
address at #69 Irisan, Baguio City, Philippines, after having duly sworn to an oath in
accordance with law do hereby depose and state the following, to wit:
24. That on January 01, 2013 while I was walking home with my husband, PSY
GANGNAM, at around 11:00 P.M. we passed by SANGER STORE located adjacent to
our residence;
25. That while we were peacefully walking and minding our business, some men having a
drinking session in the said store started to shout and heckle at me and my husband for
no apparent reason;
26. That my husband wanted to speak his mind but I convinced him to walk away as there
were three of them and he could not fight them alone;
27. That while we were walking away, their leader, MR. KIM JONG IL, shouted (“huwag mo
kaming talikuran, hindi porke kasama mo asawa mo e aatrasan ka namin”) “Don’t turn
28. That as we were trying to get away from the store in order to avoid trouble, two of the
companions of KIM JONG IL, namely KIM IL SUNG, and BURAT OBAMA held my
husband so as to prevent him from fighting back and they kept on pushing me away as I
was trying to help my husband which consequently caused me to lose my balance and
fall down on the pavement, breaking my ankle and leaving me incapacitated;
29. That as I was helpless to help my husband and while he was struggling to break free,
KIM IL SUNG said to KIM JONG IL, “banatan mo na ‘to para din a pumalag”, and then I
saw BURAT OBAMA hand over a knife to KIM JONG IL which he used to repeatedly
stab my husband which he then passed on to KIM IL SUNG and BURAT OBAMA, both
of whom continued stabbing my husband until he was already unable to move;
30. That while they were stabbing my husband I was shouting frantically for help from
anyone nearby to which some barangay tanods came to the rescue which caused the
group of KIM JONG IL to flee the scene;
31. That if it were not for the timely assistance of the barangay tanods, I would surely have
succumbed to the same fate as my husband;
32. That upon the arrival of the medical emergency unit, they examined my husband and
afterwards told me that he had already passed away;
33. That I am executing this complaint-affidavit to attest to the truth of the foregoing facts
and for the purpose of filing a criminal complaint for MURDER against the accused, KIM
JONG IL, KIM IL SUNG, and BURAT OBAMA.
OPPA GANGNAM
Affiant
SUBSCRIBED AND SWORN to before me this 14th day of February, 2013 at Baguio
City.
KRISTOFER J. CORPUZ
Asst. City Prosecutor
CERTIFICATION
I HEREBY CERTIFY that I have personally examined the affiant and I am fully satisfied that he
has read and understood his statement and that he executed the same freely and voluntarily.
KRISTOFER J. CORPUZ
Asst. City Prosecutor
POSTMORTEM FINDINGS
(1) 2.0 cms., located on the chest wall along mid axillary line, left side 24.5 cms., from the
anterior median line, directed forward, upward, medially, involving the skin underlying
soft tissues into the left thoracic, penetrating lower lobe of the left lung with an
approximate depth of 7.0 cms.
(2) 3.0 cms., located on the chest wall along posterior axillary line, left side, 24.5 cms. From
the posterior median line, directed forward, the left thoracic cavity, penetrating uppser
lobe of left lung with an approximate depth of 8.0 cms.
(3) 3.0 cms., located on the posterior abdominal wall, left side 18.0 cms., from the
posterioir medial line, directed backward, upward, upward medially, involving the skin
and underlying soft tissues, communicating with another wound, 2.5 cms., in length,
located on the posterior abdominal wall, left side, 7.5 cms. From the posterior median
line.
(4) 3.0 cms. Located on the anterior aspect, left leg, 29.0 cms., above the left heel, directed
backward, upward, laterally, involving the skin and underlying soft tissues,
communicating with another wound 2.0 cms., in length, located on the posterolateral
aspect, left 32.0 cms. Above the left heel.
PSY GANGNAM,
Accused.
X---------------------------------------X
(1) He is of legal age, single, Filipino citizen and a resident of Number 123 Buyagan, Poblacion, La
Trinidad, Benguet;
(2) On January 31, 2013, the Honorable Court rendered judgment on the above-entitled case
convicting him of the crime of serious physical injuries and sentencing him to suffer the penalty
of imprisonment, the dispositive portion of which read as follows:
(3) In view of the foregoing judgment, the accused hereby most respectfully applies before the
Honorable Court for probation;
(4) The accused further states that he is not one among those offenders disqualified to avail of the
benefits of probation, as provided under Section 9, of Presidential Decree No. 968, as
amended, to wit:
Section 9. Disqualified Offenders. The benefits of this Decree shall not be extended to
those:
(a) sentenced to serve a maximum term of imprisonment of more than six years;
(b) convicted of any offense against the security of the State;
(c) who have previously been convicted by final judgment of an offense punished by
imprisonment of not less than one month and one day and/or a fine of not less than Two
Hundred Pesos;
(d) who have been once on probation under the provisions of this Decree; and
(e) who are already serving sentence at the time the substantive provisions of this Decree
became applicable pursuant to Section 33 hereof. (italics supplied)
(5) The accused has not perfected nor does he intend to perfect an appeal from the
aforementioned judgment of the Honorable Court;
PRAYER
WHEREFORE, premises considered, it is respectfully prayed that this pleading be noted and
made part of the records of the above-entitled case and that this Application for Probation filed by the
accused Mr. PSY GANGNAM be granted.
Other relief just and equitable in the foregoing is likewise prayed for.
NOTICE OF HEARING
Greetings!
Please take notice that on February 22, 2013 at 2:00 in the afternoon or soon thereafter as
counsel may be heard, the undersigned will request the Honorable Court to approve the foregoing
Application for Probation without further argument and appearance from counsel.
C. SPECIAL PROCEEDINGS
OF ADMINISTRATION
PSY GANGNAM,
Plaintiff, SPECIAL PROCEEDINGS
CASE No. ___________
PAPA GANGNAM,
Respondent.
x--------------------------------------------------------x
PETITION
COMES NOW, the Plaintiff by and through the undersigned counsel and this Honorable Court,
most respectfully states:
1. That plaintiff is of legal age, married, Filipino Citizen, and a resident of Monticello Camp 7,
Baguio City, Philippines;
2. That he is the legitimate son of deceased OPPA GANGNAM who died intestate in the City
of Baguio on November 1, 2009;
3. That the deceased OPPA GANGNAM left the following legal heirs to wit:
Relation
Name Age to the Address
Deceased
PSY GANGNAM 35 Son Monticello Camp 7, Baguio City
PAPA GANGNAM 63 Husband Monticello Camp 7, Baguio City
MARIA GANGNAM 21 Daughter Monticello Camp 7, Baguio City
MYLA GANGNAM 16 Daughter Monticello Camp 7, Baguio City
4. That the deceased OPPA GANGNAM, during her marriage with the above-named PAPA
GANGNAM, acquired real and personal property, particularly described as follows, to wit:
5. That as far as the petitioner knows, the following are the names of the creditors of the
decedent, to wit:
NAME ADDRESS AMOUNT OF CREDIT
MAE DINGIL BALILI, LA TRINIDAD P50,000.00
CHRIS 11 BALSIGAN, Baguio P70,000.00
CAMPOS City
6. That the surviving husband PAPA GANGNAM, even during the lifetime of his legitimate wife
or the deceased OPPA GANGNAM had been maintaining marital relations with another
woman;
7. That the surviving husband, PAPA GANGNAM, since the death of his wife, OPPA
GANGNAM, had not made any settlement, judicial or extrajudicial, of the property of his
deceased wife;
8. That, on the contrary, the surviving husband PAPA GANGNAM, only continued to manage
and control the property left by the deceased wife, OPPA GANGNAM, to his own benefit
and advantage, to the exclusion of the legal rights of the above-named heirs, some of whom
are already of age, married, and heads of families;
9. That the herein petitioner, as one of the legal heirs of the deceased, OPPA GANGNAM, had
on several occasions, requested of his father, to make a settlement and liquidation of the
estate left by the said deceased, and to deliver to all the legal heirs what is due to each and
every one of them, but they said father refused to do so, without any justifiable reason;
10. That the said husband PAPA GANGNAM is managing and controlling the estate of the
deceased OPPA GANGNAM to his own advantage and to the advantage and benefit of his
illegitimate wife, and to the damage and prejudice of the herein petitioner and his co-heirs,
that unless another administrator is appointed by this Honorable Court, the property sought
herein to be divided and which was left by the deceased at the time of her death will likely
diminished, if not entirely perish;
11. That the petitioner, as the eldest son of the deceased is competent and willing to act as
such administrator of the estate of the deceased;
13. That the petitioner is also competent to act as such guardian ad litem for the minor MYLA
GANGNAM;
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court, that
after due notice and hearing:
a. That letters of administration be issued to the petitioner for the administration of the estate of
the deceased OPPA GANGNAM, upon giving of a bond in such reasonable sum as this
Honorable Court may fix;
b. That petitioner, PSY GANGNAM, be appointed guardian ad litem for the minor MYLA
GANGNAM, for the purposes of this proceedings;
c. That after all the property of the deceased have been inventoried and expenses and just
debts, if any, have been paid and the legal heirs of the deceased fully determined, that the
said estate of the deceased be settled and distributed among the legal heirs of the
deceased, all in accordance with law;
d. That such other reliefs and remedies which may be just and equitable under the
circumstances are likewise prayed for.
Respectfully submitted.
I, PSY GANGNAM, of legal age, single, Filipino Citizen and a resident of #69 Irisan, Baguio
City, after having been duly sworn to in accordance with law, do hereby depose and state:
1. That I am the petitioner in the above-entitled case;
3. That I have read and understood the contents of the foregoing petition and the allegations
therein are true and correct to the best of my personal knowledge and belief based on
authentic documents;
a. I have not commenced any proceeding involving the same issues before the Supreme
Court, Court of Appeals, or any other Government Agency or Tribunal;
b. To the best of my knowledge, no such action is pending before the Supreme Court,
Court of Appeals, or any other Government Agency or Tribunal;
c. If there be any similar action before the Supreme Court, Court of Appeals, or any other
Government Agency or Tribunal, I undertake to report the same within five (5) days to
the court where the original action and certification referred to herein has been filed.
IN WITNESS WHEREOF, I have hereunto set my hand this 21st day of February 2013, at
Baguio City, Philippines.
PSY GANGNAM
Affiant
SUBSCRIBED AND SWORN to before me in the City of Baguio this 21st day of February 2013,
by PSY GANGNAM, who has satisfactorily proven his identity to me through his Voter’s ID issued by
the COMELEC bearing his photograph and signature and with VIN 1102-0288J-F0974GJC10002-4,
that he is the same person who personally signed the foregoing document before me and
acknowledged that he executed the same.
WITNESS MY HAND AND SEAL this 21st day of February 2013 in Baguio City,
Philippines.
KRISTOFER J. CORPUZ
Notary Public
Until December 31, 2014
Doc. No. ____ PTR NO. 819105 – 1/10/11
Page No.____ IBP NO. 5440632 – 12/16/10
Book No.____ ROLL NO. 46915 May 3, 2010
Series of 2013 Baguio City
MCLE Compliance Certificate No.
II-0014738. DEC. 19, 2011
PETITION
Petitioner, by and through the undersigned counsel, with sufficient cause, hereby avers that:
1. Petitioner PSY OPPA GANGNAM is of legal age, married, Filipino citizen and a
resident of #69 Irisan, Baguio City;
2. Petitioner was born on July 10, 1981 in Baguio City to the spouses Johnny H. Gangnam
and Demetria L. Oppa;
3. The fact of petitioner’s birth was reported and recorded in the Office of the Local Civil
Registrar of Baguio City. A photocopy of his Certificate of Live Birth is hereto attached
as Annex “E” and made an integral part hereof;
4. In his Certificate of Live Birth, particularly under entry No. 8 (“Name of child”),
petitioner’s first name as indicated therein was erroneously entered as “BABY BOY”,
instead of his supposed correct name which should have been PSY;
7. In order therefore to set Petitioner’s Certificate of Live Birth in conformity with his correct
and true identity; an Order of the Honorable Court is therefore needed to effect the
necessary changes in his Certificate of Live Birth.
PRAYER
WHEREFORE, premises considered, it is respectfully prayed of this Honorable Court that after
due notice and hearing, to render a judgment:
Such other reliefs and remedies which may be just and equitable under the circumstances are
likewise prayed for.
Respectfully submitted.
I, PSY OPPA GANGNAM, of legal age, married, Filipino Citizen and a resident of #69 Irisan,
Baguio City, after having been duly sworn to in accordance with law, do hereby depose and state:
6. That I have read and understood the contents of the foregoing petition and the
allegations therein are true and correct to the best of my personal knowledge and
belief based on authentic documents;
d. I have not commenced any proceeding involving the same issues before the Supreme
Court, Court of Appeals, or any other Government Agency or Tribunal;
e. To the best of my knowledge, no such action is pending before the Supreme Court,
Court of Appeals, or any other Government Agency or Tribunal;
f. If there be any similar action before the Supreme Court, Court of Appeals, or any other
Government Agency or Tribunal, I undertake to report the same within five (5) days to
the court where the original action and certification referred to herein has been filed.
g. That I am executing this verification and certification to attest to the truth of the foregoing
facts and in compliance with the pertinent provisions of Administrative Circular No. 04-94
of the Supreme Court.
IN WITNESS WHEREOF, I have hereunto set my hand this 20th day of February 2013, at
Baguio City, Philippines.
OPPA A. GANGNAM
Affiant
SUBSCRIBED AND SWORN to before me in the City of Baguio this 20th day of
February 2013, by PSY OPPA GANGNAM, who has satisfactorily proven his identity to me
through his Voter’s ID issued by the COMELEC bearing his photograph and signature and
with VIN 1102-0288J-F0974GJC10002-4, that he is the same person who personally signed
the foregoing document before me and acknowledged that he executed the same.
KRISTOFER J. CORPUZ
Notary Public
Until December 31, 2014
Doc. No. ____ PTR NO. 819105 – 1/10/11
Page No.____ IBP NO. 5440632 – 12/16/10
Book No.____ ROLL NO. 46915 May 3, 2010
Series of 2013 Baguio City
MCLE Compliance Certificate No. II-0014738.
DEC. 19, 2011
EXPLANATION
Service of this pleading is made through registered mail due to lack of personnel to effect
personal service.
PETITION
With all due respect to the Honorable Court, the minor Petitioner, represented herein by his
father and guardian, PSY GANGNAM, through counsel and unto this Honorable Court, states that:
1. The petitioner is a minor, one (1) year and one (1) month old, Filipino citizen, with postal
address at #69 Irisan, Baguio City, Philippines; while his representative, who is his father
and guardian, is of legal age, Filipino citizen, married and with postal address at #69
Irisan, Baguio City, Philippines, where he may be served with summons and other
processes of the Honorable Court;
2. The Local Civil Registrar of Baguio City is a government entity charged with the
recording, registration, and custody of public records and other matters, with postal
address at T. Alonzo St, Baguio City, Philippines;
3. Minor petitioner OPPA GANGNAM was born on January 20, 2012, and is the natural
child of Spouses PSY GANGNAM and LOVELY GANGNAM. His birth was duly
registered with the Baguio City Local Civil Registry under Local Civil Registry No. 2010-
1035. A photocopy of the Certificate of Live Birth of the said minor is hereto attached as
ANNEX “A”, to form part hereof;
4. In the said Certificate of Live Birth of the minor petitioner, the date and place of marriage
of his parents was entered as “MARCH 20, 2011 – BAGUIO CITY”. In all truth and
honesty, the afore-stated entry was furnished by minor petitioner’s parents in good faith
merely to avoid the stigma of illegitimacy, considering that they had not yet married at
the time of his birth;
5. The parents of minor petitioner eventually got married on March 20, 2012 in Baguio City,
Philippines. A photocopy of their Marriage Certificate is hereto attached as Annex “B”
and made to form part hereof;
7. In order therefore to set the Certificate of Live Birth which is the subject matter of this
petition in conformity with the correct facts and entries and further to avoid confusion that
may later arise because of the discrepancy, an Order by the Honorable Court directing
the Local Civil Registrar is therefore needed to effect the needed changes.
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of the Honorable Court that,
after due notice and hearing, a decision be rendered in favor of herein Petitioner, ordering the Local
Civil Registrar of Baguio City, to cancel the erroneous entry in the birth certificate of OPPA GANGNAM
under paragraph 18 – Date and Place of Marriage of Parents, which states “MARCH 20, 2011 –
BAGUIO CITY” and amending it to “MARCH 20, 2012 - BAGUIO CITY”.
Such other reliefs and remedies which may be just and equitable under the circumstances are
likewise prayed for.
Respectfully submitted.
I, PSY GANGNAM, of legal age, single, Filipino Citizen and a resident of #69 Irisan, Baguio
City, after having been duly sworn to in accordance with law, do hereby depose and state:
7. That I am the petitioner in the above-entitled case;
9. That I have read and understood the contents of the foregoing petition and the
allegations therein are true and correct to the best of my personal knowledge and
belief based on authentic documents;
h. I have not commenced any proceeding involving the same issues before the Supreme
Court, Court of Appeals, or any other Government Agency or Tribunal;
i. To the best of my knowledge, no such action is pending before the Supreme Court,
Court of Appeals, or any other Government Agency or Tribunal;
j. If there be any similar action before the Supreme Court, Court of Appeals, or any other
Government Agency or Tribunal, I undertake to report the same within five (5) days to
the court where the original action and certification referred to herein has been filed.
IN WITNESS WHEREOF, I have hereunto set my hand this 20th day of February 2013, at
Baguio City, Philippines.
PSY GANGNAM
Affiant
SUBSCRIBED AND SWORN to before me in the City of Baguio this 20th day of
February 2013, by PSY GANGNAM, who has satisfactorily proven his identity to me through
his Voter’s ID issued by the COMELEC bearing his photograph and signature and with VIN
1102-0288J-F0974GJC10002-4, that he is the same person who personally signed the
foregoing document before me and acknowledged that he executed the same.
WITNESS MY HAND AND SEAL this 20th day of February 2013 in Baguio City,
Philippines.
KRISTOFER J. CORPUZ
Notary Public
Until December 31, 2014
Doc. No. ____ PTR NO. 819105 – 1/10/11
Page No.____ IBP NO. 5440632 – 12/16/10
Book No.____ ROLL NO. 46915 May 3, 2010
Series of 2013 Baguio City
MCLE Compliance Certificate No.
II-0014738. DEC. 19, 2011
EXPLANATION
Service of this pleading is made through registered mail due to lack of personnel to effect
personal service.
In the Matter of
Petition for Declaration of Presumption of Death
SP. PROC. NO. _________
OPPA GANGNAM,
Petitioner.
x-----------------------------------------------------------------------x
PETITION
Petitioner, by counsel and to this Honorable Court, alleges that:
1. The petitioner is of legal age, Filipino citizen, and a residence and postal address at #69 Irisan,
Baguio City where she may be served with summons and other court processes;
2. The petitioner and her husband, PSY GANGNAM, were married to each other, on November
26, 1992, before Fr. James Desmet, CICM, at the Saint William the Hermit, Roman Catholic
Church, San Fernando City; Attached herewith, marked as Annex “A” and made an integral part
of this petition is a copy of the marriage certificate;
BRYAN R. GANGNAM
Born on November 7, 1996 at Baguio City
- and -
(Attached herewith, are the birth certificates of said children correspondingly marked as Annex
“B”, Annex “C” and Annex “D”);
4. The petitioner’s husband left the conjugal abode sometime in 1999 and no news about said
respondent had been received since then;
5. The common children have since been legally adopted by the petitioner’s parents who are U.S.
citizens and have been living in the United States since their respective adoptions were granted;
6. The petitioner has exhausted all possible means as mandated by law to ascertain the
whereabouts of her husband but to no avail;
7. Given the lapse of time since the last news or sighting of the petitioner’s husband, the latter may
now be declared legally dead for all intents and purposes;
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court, that
after due notice and hearing, a decision be rendered:
b. That petitioner be given such other reliefs and remedies which may be just and equitable under
the circumstances.
Respectfully submitted.
I, OPPA GANGNAM, of legal age, Filipino Citizen and a resident of #69 Irisan, Baguio City,
after having been duly sworn to in accordance with law, do hereby depose and state:
12. That I have read and understood the contents of the foregoing petition and the
allegations therein are true and correct to the best of my personal knowledge and
belief based on authentic documents;
k. I have not commenced any proceeding involving the same issues before the Supreme
Court, Court of Appeals, or any other Government Agency or Tribunal;
l. To the best of my knowledge, no such action is pending before the Supreme Court,
Court of Appeals, or any other Government Agency or Tribunal;
m. If there be any similar action before the Supreme Court, Court of Appeals, or any other
Government Agency or Tribunal, I undertake to report the same within five (5) days to
the court where the original action and certification referred to herein has been filed.
IN WITNESS WHEREOF, I have hereunto set my hand this 20th day of February 2013, at
Baguio City, Philippines.
OPPA GANGNAM
Affiant
SUBSCRIBED AND SWORN to before me in the City of Baguio this 20th day of
February 2013, by OPPA GANGNAM, who has satisfactorily proven her identity to me through
her Voter’s ID issued by the COMELEC bearing her photograph and signature and with VIN
1102-0288J-F0974GJC10002-4, that she is the same person who personally signed the
foregoing document before me and acknowledged that she executed the same.
WITNESS MY HAND AND SEAL this 20th day of February 2013 in Baguio City,
Philippines.
KRISTOFER J. CORPUZ
Notary Public
Until December 31, 2014
Doc. No. ____ PTR NO. 819105 – 1/10/11
Page No.____ IBP NO. 5440632 – 12/16/10
Book No.____ ROLL NO. 46915 May 3, 2010
Series of 2013 Baguio City
MCLE Compliance Certificate No.
II-0014738. DEC. 19, 2011
EXPLANATION
Service of this pleading is made through registered mail due to lack of personnel to effect
personal service.
PETITION
Petitioner, through the undersigned counsel and before this Honorable Court, states that:
1. Petitioner PSY GANGNAM, is of legal age, a Filipino citizen, single and a resident of #69 Irisan,
Baguio City;
2. KIM JONG IL, whom guardianship is prayed is an 11-year-old minor, and a resident of No. 42
Lualhati Road, Pacdal, Baguio City, attached herewith is the photocopy of the minor’s birth
certificate and marked as Annex “A”;
3. Sometime in September 16, 2012, Ms. KIM CHIU IL, the mother of KIM JONG IL was
diagnosed with ENDOMETRIAL CARCINOMA STAGE III-C CANCER and hereby consents to
the petition for guardianship over the person of the above-named minor and for the issuance of
the corresponding letters of guardianship in favor of Mr. PSY GANGNAM;
4. The biological father of KIM JONG IL is a Canadian citizen living in Calgary, Canada with
another family;
6. The names, ages and residences of the relatives of the named minor are the following:
7. Letters of guardianship over the person and properties are prayed for by petitioner, who is the
godfather of the minor, and with whom the minor is entrusted every time the mother of the minor
is not capable of performing her obligations due to her unfortunate health condition and
considering the fact that the father of minor is not residing in the Philippines, the latter being a
Canadian citizen and has his own family there.
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court, that
after due notice and hearing, the petitioner be appointed guardian over the person and properties of
minor KIM JONG IL and that corresponding letters of guardianship be issued in his favor.
Such other reliefs and remedies which may be just and equitable under the circumstances are
likewise prayed for.
Respectfully submitted.
I, PSY GANGNAM, of legal age, single, Filipino Citizen and a resident of #69 Irisan, Baguio
City, after having been duly sworn to in accordance with law, do hereby depose and state:
13. That I am the petitioner in the above-entitled case;
15. That I have read and understood the contents of the foregoing petition and the
allegations therein are true and correct to the best of my personal knowledge and
belief based on authentic documents;
n. I have not commenced any proceeding involving the same issues before the Supreme
Court, Court of Appeals, or any other Government Agency or Tribunal;
o. To the best of my knowledge, no such action is pending before the Supreme Court,
Court of Appeals, or any other Government Agency or Tribunal;
p. If there be any similar action before the Supreme Court, Court of Appeals, or any other
Government Agency or Tribunal, I undertake to report the same within five (5) days to
the court where the original action and certification referred to herein has been filed.
IN WITNESS WHEREOF, I have hereunto set my hand this 20th day of February 2013, at
Baguio City, Philippines.
PSY GANGNAM
Affiant
SUBSCRIBED AND SWORN to before me in the City of Baguio this 20th day of
February 2013, by PSY GANGNAM, who has satisfactorily proven his identity to me through
his Voter’s ID issued by the COMELEC bearing his photograph and signature and with VIN
1102-0288J-F0974GJC10002-4, that he is the same person who personally signed the
foregoing document before me and acknowledged that he executed the same.
WITNESS MY HAND AND SEAL this 20th day of February 2013 in Baguio City,
Philippines.
KRISTOFER J. CORPUZ
Notary Public
Until December 31, 2014
Doc. No. ____ PTR NO. 819105 – 1/10/11
Page No.____ IBP NO. 5440632 – 12/16/10
Book No.____ ROLL NO. 46915 May 3, 2010
Series of 2013 Baguio City
MCLE Compliance Certificate No.
II-0014738. DEC. 19, 2011
EXPLANATION
Service of this pleading is made through registered mail due to lack of personnel to effect
personal service.
LILY GANGNAM,
Two (2) years of age,
Represented by her mother,
OPPA GANGNAM, S.P. No._______
Petitioner, For: HABEAS CORPUS
-versus-
PETITION
COMES NOW the petitioner, represented by her mother, OPPA GANGNAM, through her
undersigned counsel and unto this Honorable Court most respectfully states that:
1. The petitioner is a minor, two years of age, and under the legal custody of and residing with her
mother OPPA GANGNAM at #69 Irisan, Baguio City while the respondents are of legal age and
are residing at Number 53-A Trancoville, Baguio City where they may be served with processes;
2. The petitioner is the legitimate child of OPPA GANGNAM with the respondent PSY GANGNAM;
3. Due to several attempts made by respondent PSY GANGNAM on the life of his wife OPPA
GANGNAM, the parties have separated with the minor child remaining in the custody of her
mother;
4. The legal custody of the said minor, being under five years of age, is vested in OPPA
GANGNAM;
5. On December 20, 2012, at about 2:30 in the afternoon, the respondent PSY GANGNAM,
resorting to ruse and trickery, abducted with the petitioner surreptitiously, leaving OPPA
GANGNAM in a mall at Magsaysay Avenue, Baguio City, without returning the said minor to the
custody of her mother;
6. The petitioner, in whose behalf this application is being made, is actually restrained of her liberty
by the respondent PSY GANGNAM in the residence of his mother MOMMY GANGNAM who
has knowledge that her son is continuously restraining the petitioner;
7. The petitioner is a child in a very delicate state of health and can easily get sick without special
care and attention;
8. The petitioner has exhausted all means allowed by law, and that she has no other plain, speedy
or adequate remedy to protect her rights except by application for a writ of Habeas Corpus.
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court, that
a Writ of Habeas Corpus be issued, directed to the respondents PSY GANGNAM and MOMMY
GANGNAM commanding them to have the body of the minor, LILY GANGNAM before this Court at the
time and place specified therein, and to summon the said respondents then and there, to appear and to
show the cause of the detention of the said petitioner, and that after due proceedings, the said minor,
LILY GANGNAM be discharged from restraint.
Such other reliefs and remedies which may be just and equitable under the circumstances are
likewise prayed for.
Respectfully submitted.
I, OPPA GANGNAM, of legal age, Filipino Citizen and a resident of #69 Irisan, Baguio City,
after having been duly sworn to in accordance with law, do hereby depose and state:
18. That I have read and understood the contents of the foregoing petition and the allegations
therein are true and correct to the best of my personal knowledge and belief based on
authentic documents;
q. I have not commenced any proceeding involving the same issues before the Supreme
Court, Court of Appeals, or any other Government Agency or Tribunal;
r. To the best of my knowledge, no such action is pending before the Supreme Court,
Court of Appeals, or any other Government Agency or Tribunal;
s. If there be any similar action before the Supreme Court, Court of Appeals, or any other
Government Agency or Tribunal, I undertake to report the same within five (5) days to
the court where the original action and certification referred to herein has been filed.
IN WITNESS WHEREOF, I have hereunto set my hand this 21st day of February 2013, at
Baguio City, Philippines.
OPPA GANGNAM
Affiant
SUBSCRIBED AND SWORN to before me in the City of Baguio this 21st day of February 2013,
by OPPA GANGNAM, who has satisfactorily proven her identity to me through her Voter’s ID issued
by the COMELEC bearing her photograph and signature and with VIN 1102-0288J-F0974GJC10002-4,
that she is the same person who personally signed the foregoing document before me and
acknowledged that she executed the same.
WITNESS MY HAND AND SEAL this 21st day of February 2013 in Baguio City,
Philippines.
KRISTOFER J. CORPUZ
Notary Public
Until December 31, 2014
Doc. No. ____ PTR NO. 819105 – 1/10/11
Page No.____ IBP NO. 5440632 – 12/16/10
Book No.____ ROLL NO. 46915 May 3, 2010
Series of 2013 MCLE Compliance Certificate No.
II-0014738. DEC. 19, 2011
In the Matter of
Voluntary Recognition of Minor Child
KIM JONG IL,
SPECIAL PROCEEDINGS
NO. _____
PETITION
Petitioners, by and through the undersigned counsel, with sufficient cause, hereby avers that:
1. Petitioners are of legal age, Filipino Citizens and with residence at #69 Irisan, Baguio City;
2. PSY GANGNAM is the natural father of the child KIM JONG IL, who is 7 years of age and lives
with him and his wife OPPA GANGNAM, at the indicated address and who, since birth, has
been living with them at the above indicated address. Petitioner and his wife have continuously
recognized the child as their legitimate child since birth, introduced him to other persons as their
child, and enrolled him as their child in the kindergarten and in the elementary school as his
legitimate child. The child has been part of any and all family gatherings;
3. The natural mother of the child, KIM CHIU IL died during giving birth to the child on January 30,
2006. Attached hereto is a copy of the Death Certificate of Ms. KIM CHIU IL marked as Annex
“A”;
4. That the petitioner, PSY GANGNAM was never legally married to Ms. KIM CHIU IL as there are
no records in the Local Civil Registrar that show that the petitioner was married prior to his
current marriage to Ms. OPPA GANGNAM. Attached hereto is a certification by the Local Civil
Registrar marked as Annex “B”;
5. The names and residences of those who acknowledged the child, apart from herein petitioners,
and their compulsory heirs, are as follows:
WHEREFORE, premises considered, it is respectfully prayed of this Honorable Court that after
due notice and hearing, to render a judgment approving the voluntary recognition of KIM JONG IL as
the natural child of the petitioners.
Such other reliefs and remedies which may be just and equitable under the circumstances are
likewise prayed for.
Respectfully submitted.
We, PSY GANGNAM and OPPA GANGNAM, both of legal age, married, Filipino Citizens
and residing at #69 Irisan, Baguio City, after having been duly sworn to in accordance with law, do
hereby depose and state:
21. That we have read and understood the contents of the foregoing petition and the
allegations therein are true and correct to the best of our personal knowledge and
belief based on authentic documents;
t. We have not commenced any proceeding involving the same issues before the Supreme
Court, Court of Appeals, or any other Government Agency or Tribunal;
u. To the best of our knowledge, no such action is pending before the Supreme Court,
Court of Appeals, or any other Government Agency or Tribunal;
v. If there be any similar action before the Supreme Court, Court of Appeals, or any other
Government Agency or Tribunal, we undertake to report the same within five (5) days to
the court where the original action and certification referred to herein has been filed.
IN WITNESS WHEREOF, I have hereunto set my hand this 20th day of February 2013, at
Baguio City, Philippines.
SUBSCRIBED AND SWORN to before me in the City of Baguio this 20th day of
February 2013, by PSY GANGNAM and OPPA GANGNAM, who have satisfactorily proven
their identity to me through their Passport No. ZZ123456 valid until December 25, 2014 and
Professional Driver’s License No.AO090384, respectively, both bearing their photograph
and signature, that they are the same persons who executed and voluntarily signed the
foregoing document which they acknowledged before me as their free and voluntary act and
deed.
WITNESS MY HAND AND SEAL this 20th day of February 2013 in Baguio City,
Philippines.
KRISTOFER J. CORPUZ
Notary Public
Until December 31, 2014
Doc. No. ____ PTR NO. 819105 – 1/10/11
Page No.____ IBP NO. 5440632 – 12/16/10
Book No.____ ROLL NO. 46915 May 3, 2010
Series of 2013 Baguio City
MCLE Compliance Certificate No. II-0014738.
DEC. 19, 2011
EXPLANATION
Service of this pleading is made through registered mail due to lack of personnel to effect
personal service.
Petitioners.
x------------------------------------------------------x
PETITION
COMES NOW, the Petitioners by and through the undersigned counsel and this Honorable
Court, most respectfully states:
14. That the petitioners are of legal ages, Filipino Citizens, and reside at #69 Irisan, Baguio City,
where they may be served with summons and other court processes;
15. That the petitioners hereby desire to adopt the minor child named PSY GANGNAM, who
happens to be the nephew of herein Petitioners, who was born on August 8, 2011 at Baguio
City, Philippines as could be shown by his Certificate of Live Birth hereto attached and
marked as Annex “A” and forming part hereof;
16. That the petitioners are the ones who are providing support for the minor child PSY
GANGNAM since birth up to this time;
17. That DADDY GANGNAM (representing himself and his deceased wife, OPPA I.
GANGNAM), the biological father of the minor PSY GANGNAM has full knowledge of the
intention of Petitioners in adopting said minor and hereby expressly gives his written
consent to the Petitioners as evidenced by Annex “B” and forming part hereof;
18. That the petitioners are qualified to adopt PSY GANGNAM and are morally, spiritually,
physically and financially capable of taking care, bringing up and educating him properly and
adequately;
19. That the child of herein petitioners has likewise given her written consent to show that she is
in favor of the said adoption as could be shown by Annex “C” attached hereto;
20. That the said minor is being supported by petitioners even at present considering the fact
that the father had abandoned the child since birth and has no steady job and could not
properly take care of said minor child and likewise because of his financial difficulty at
present, it would serve to the best interest of said minor child if she be adopted by said
Petitioners;
21. That the petitioners have all the qualifications to adopt said minor child and none of the
disqualifications and they are willing to comply and abide by whatever requirements this
Honorable Court would require;
Atty Isagani Calderon 214 | L L B I I I - A
School Year 2012-2013 Second Semester
LEGAL FORMS
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court that
after due notice and hearing that judgment be rendered directing that the minor PSY
GANGNAM be freed from all legal obligations of obedience with respect to his natural parent
and he shall be declared for all legal intents and purposes, the adopted child of herein
Petitioners.
Such other reliefs and remedies which may be just and equitable under the circumstances are
likewise prayed for.
Respectfully submitted.
WE, KIM JONG IL and KIM CHIU IL, both of legal age, Filipino Citizens and residing at of #69
Irisan, Baguio City, after having been duly sworn to in accordance with law, do hereby depose and
state:
24. That we have read and understood the contents of the foregoing petition and the
allegations therein are true and correct to the best of my personal knowledge and
belief based on authentic documents;
x. We have not commenced any proceeding involving the same issues before the Supreme
Court, Court of Appeals, or any other Government Agency or Tribunal;
y. To the best of our knowledge, no such action is pending before the Supreme Court,
Court of Appeals, or any other Government Agency or Tribunal;
z. If there be any similar action before the Supreme Court, Court of Appeals, or any other
Government Agency or Tribunal, we undertake to report the same within five (5) days to
the court where the original action and certification referred to herein has been filed.
SUBSCRIBED AND SWORN to before me in the City of Baguio this 21st day of February 2013,
by KIM JONG IL and KIM CHIU IL who have satisfactorily proven their identity to me through their
Voter’s ID issued by the COMELEC bearing their photograph and signature and with VIN 1102-0288J-
F0974GJC10002-4 and VIN 2132-0328G-G0974KCC12302-5 respectively, that they are the same
persons who personally signed the foregoing document before me and acknowledged that they
executed the same.
WITNESS MY HAND AND SEAL this 21st day of February 2013 in Baguio City,
Philippines.
KRISTOFER J. CORPUZ
Notary Public
Until December 31, 2014
Doc. No. ____ PTR NO. 819105 – 1/10/11
Page No.____ IBP NO. 5440632 – 12/16/10
Book No.____ ROLL NO. 46915 May 3, 2010
Series of 2013 Baguio City
MCLE Compliance Certificate No.
II-0014738. DEC. 19, 2011
EXPLANATION
Service of this pleading is made through registered mail due to lack of personnel to effect
personal service.
VI. ANSWERS
ANSWERS
ANSWER the principal pleading on the part of the defendant in response to plaintiff's complaint; it
must contain a denial of all the allegations of plaintiff's complaint which the defendant wishes to controvert;
it may also contain affirmative defenses which the defendant may have, which should be stated separately; it
may contain a statement of any permissive counterclaim which the defendant has against the plaintiff and
which is legally available to him in the action; compulsory counterclaims arising out of the same transaction
must generally be pleaded in the answer or they will be barred in any subsequent separate suit.
TEOFILO CIANO,
Plaintiff, CIVIL CASE NO. 7369-R
For
- versus -
Annulment / Cancellation of REM
with Prayer for Preliminary
JUAN DELA CRUZ, Injunction with Issuance of TRO
Defendant.
ANSWER
NOW COMES the defendant, by the undersigned counsel, and in answer to
plaintiff’s complaint, in the above-entitled case and to this Honorable Court most
respectfully alleges:
1) That defendant specifically denies under oath the genuineness and due execution
of the alleged promissory note (Annex B) attached to said complaint;
2) That said promissory note was executed through fraud, threats, and intimidation,
and therefore null and void.
PRAYER
Other relief's, just and equitable under the premises are likewise prayed for.
RESPECTFULLY SUBMITTED this 5th day of March 2013, Baguio City, Philippines.
ANGELICA F. VIVAS
Of Counsel
Roll No. 53516; May 3, 2008
PTR No. 486686; 01.11.2013; Baguio City
IBP Member 844018; 01.10.2013; Baguio City
MCLE Cert. of Compliance No. IV-0000732;
09.08.2012; Pasig City
EXPLANATION
Copy of the foregoing Answer was served through registered mail because of time
constraint and due to distance and lack of office personnel who can serve the same in
person.
ANGELICA F. VIVAS
TEOFILO CIANO,
Plaintiff, CIVIL CASE NO. 7369-R
For
- versus -
INSOLVENCY
ANSWER
COMES NOW the defendant, the debtor mentioned in the above-entitled insolvency
proceedings, and in ANSWER to the petition to have him adjudged insolvent alleges:
That he denies that he has committed any of the acts of insolvency set forth in said
petition, or that he is insolvent.
PRAYER
Other relief's, just and equitable under the premises are likewise prayed for.
RESPECTFULLY SUBMITTED this 5th day of March 2013, Baguio City, Philippines.
ANGELICA F. VIVAS
EXPLANATION
Copy of the foregoing Answer was served through registered mail because of time
constraint and due to distance and lack of office personnel who can serve the same in
person.
ANGELICA F. VIVAS
TEOFILO CIANO,
Plaintiff, CIVIL CASE NO. 7369-R
For
- versus -
CANCELLATION OF TITLE
ANSWER
RESPONDENT, by undersigned counsel and to this Honorable Court, answering the
petition for cancellation of title, respectfully alleges:
1) That the parcel of land in question is a conjugal property of respondent and his
wife, Betty Diyosa;
2) That the court in Civil Case NO. 123 has not acquired jurisdiction over the
person of his wife because she was not a party litigant therein:
3) That the money judgment in Civil Case No 123 arose from the personal
transaction of petitioner in connection with the accommodation surety he
executed to secure payment of the loan extended by respondent to the
corporation, X, which loan did not benefit the conjugal property, and
accordingly said conjugal property is exempt from execution to satisfy said
personal judgment of respondent.
4) That the execution sale is invalid because there was no valid levy made by the
sheriff, as at the time the court in Civil Case No. 123 has not acquired
jurisdiction over the person of respondent’s wife, who was not a party litigant
in said case.
5) The value of the land in question has market value far exceeding the amount of
money judgment rendered in favor of petitioner, as to unfairly and unjustly
enrich petitioner.
6) As the Supreme Court ruled in Padilla, Jr. v. Phil. Producers’ Cooperative Marketing
Assn., G.R. No. 141256, July 15, 2005:
PRAYER
WHEREFORE, respondent respectfully prays that the petition be dismissed for lack
of merit.
Other relief's, just and equitable under the premises are likewise prayed for.
RESPECTFULLY SUBMITTED this 13th day of May 2011, Baguio City, Philippines.
ANGELICA F. VIVAS
Of Counsel
Roll No. 53516; May 3, 2008
PTR No. 486686; 01.11.2013; Baguio City
IBP Member 844018; 01.10.2013; Baguio City
MCLE Cert. of Compliance No. IV-0000732;
09.08.2012; Pasig City
Copy furnished by registered mail with registry return card:
EXPLANATION
Copy of the foregoing Answer was served through registered mail because of time
constraint and due to distance and lack of office personnel who can serve the same in
person.
ANGELICA F. VIVAS
- versus - For
ANSWER
The undersigned defendant in the above-entitled case hereby makes due return of
the writ of Habeas Corpus issued by this Court on February 23, 2009, and by way of answer,
most respectfully states:
1) That the herein respondent has Amor Power under restraint in the police
detention cell at the Ormoc Police Department headquarters, pending completion
of and transfer to the city jail now under reconstruction;
2) That the herein respondent caused the apprehension of the said Amor Power on
January 30, 2009, and the authority, the true, and the whole story and cause of the
said restraint of the said person are the following, to wit:
a) That said party, Amor Power, was apprehended and placed under police
custody on suspicion of having smuggled unlicensed firearm found
abandoned in an army bag at the corner of Teresa and Magallanes
Streets, this city, reported by a person to have been carried by said Amor
Power;
c) That in the above-mentioned criminal case, the detainee has not posted a
bond for her provisional liberty up to the present time;
PRAYER
Other relief's, just and equitable under the premises are likewise prayed for.
RESPECTFULLY SUBMITTED this 5th day of March 2013, Baguio City, Philippines.
ANGELICA F. VIVAS
Of Counsel
Roll No. 53516; May 3, 2008
PTR No. 486686; 01.11.2013; Baguio City
IBP Member 844018; 01.10.2013; Baguio City
MCLE Cert. of Compliance No. IV-0000732;
09.08.2012; Pasig City
EXPLANATION
Copy of the foregoing Answer was served through registered mail because of time
constraint and due to distance and lack of office personnel who can serve the same in
person.
ANGELICA F. VIVAS
5. Answer to Petition for Legal Separation:
Atty Isagani Calderon 224 | L L B I I I -
A
School Year 2012-2013 Second Semester
LEGAL FORMS
REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
FIRST JUDICIAL REGION
BRANCH 60
BAGUIO CITY
TEOFILO CIANO,
Plaintiff, CIVIL CASE NO. 7369-R
For
- versus -
LEGAL SEPARATION
ANSWER
DEFENDANT, answering petitioner’s petition for legal separation, alleges:
2) He denies the allegations in the rest of the petition, the truth being that he was
forced to leave the conjugal home because petitioner committed acts which are
also ground for legal separation, such as sexual infidelity, attempt on the life of
respondent and abusive conduct against their two children.
PRAYER
WHEREFORE, respondent prays that the petition be dismissed for lack of merit.
Other relief's, just and equitable under the premises are likewise prayed for.
RESPECTFULLY SUBMITTED this 5th day of March 2013, Baguio City, Philippines.
ANGELICA F. VIVAS
Of Counsel
Roll No. 53516; May 3, 2008
PTR No. 486686; 01.11.2013; Baguio City
IBP Member 844018; 01.10.2013; Baguio City
MCLE Cert. of Compliance No. IV-0000732;
09.08.2012; Pasig City
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LEGAL FORMS
EXPLANATION
Copy of the foregoing Answer was served through registered mail because of time
constraint and due to distance and lack of office personnel who can serve the same in
person.
ANGELICA F. VIVAS
TEOFILO CIANO,
Plaintiff, CIVIL CASE NO. 7369-R
For
- versus -
Annulment / Cancellation of REM
with Prayer for Preliminary
JUAN DELA CRUZ, Injunction with Issuance of TRO
Defendant.
ANSWER
1) Defendant admits that portion of par. 1 of the complaint regarding the names,
residences and status of the parties, but denies the rest thereof, for lack of
knowledge sufficient to form a belief as to the truth thereof.
3) Assuming, arguendo, that the promissory is genuine and duly executed; it was
executed by a person on behalf of defendant, without any authority from
defendant.
4) Assuming, further, that the agent who signed the promissory note on behalf is
duly authorized to do so, the amount of indebtedness therein stated represented
payment of gambling losses of defendant in favor of plaintiff.
5) Assuming, finally, that the indebtedness shown in the promissory note and the
promissory note is legitimate, plaintiff has been paid the amount thereof.
PRAYER
WHEREFORE, defendant respectfully prays that the complaint be dismissed for lack
of merit, with costs against plaintiff.
Other relief's, just and equitable under the premises are likewise prayed for.
RESPECTFULLY SUBMITTED this 5th day of March 2013, Baguio City, Philippines.
ANGELICA F. VIVAS
Of Counsel
Roll No. 53516; May 3, 2008
PTR No. 486686; 01.11.2013; Baguio City
IBP Member 844018; 01.10.2013; Baguio City
MCLE Cert. of Compliance No. IV-0000732;
09.08.2012; Pasig City
Copy of the foregoing Answer was served through registered mail because of time
constraint and due to distance and lack of office personnel who can serve the same in
person.
ANGELICA F. VIVAS
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LEGAL FORMS
7. Answer with Permissive Counterclaim:
TEOFILO CIANO,
Plaintiff, CIVIL CASE NO. 7369-R
For
- versus -
Annulment / Cancellation of REM
with Prayer for Preliminary
JUAN DELA CRUZ, Injunction with Issuance of TRO
Defendant.
ANSWER
PRAYER
WHEREFORE, defendant respectfully prays that the complaint be dismissed for lack
of merit.
Under his counterclaim, judgment be rendered ordering plaintiff to pay the amount
of P2, 000, 000.00, with legal interests therein until the principal amount and interest are
fully paid.
Other relief's, just and equitable under the premises are likewise prayed for.
ANGELICA F. VIVAS
Of Counsel
Roll No. 53516; May 3, 2008
PTR No. 486686; 01.11.2013; Baguio City
IBP Member 844018; 01.10.2013; Baguio City
MCLE Cert. of Compliance No. IV-0000732;
09.08.2012; Pasig City
EXPLANATION
Copy of the foregoing Answer was served through registered mail because of time
constraint and due to distance and lack of office personnel who can serve the same in
person.
ANGELICA F. VIVAS
TEOFILO CIANO,
Plaintiff, CIVIL CASE NO. 7369-R
For
- versus -
Annulment / Cancellation of REM with
Prayer for Preliminary Injunction with
JUAN DELA CRUZ, Issuance of TRO
Defendant.
ANSWER
NOW COMES the defendant, by the undersigned counsel, in the above-entitled case
and to this Honorable Court most respectfully alleges:
3) Defendant does not admit the allegations contained in paragraph 5 and 6 of the
complaint as it lacks in form and substance to support any cause of action against
the defendant;
4) Defendant does not admit the allegation in paragraph 7 as it has no basis in law
and in facts.
Defendants adopt and replead the foregoing allegations, and raise by way of special
and affirmative defenses the following:
The complaint states no cause of action. The rule requires that every action must be
prosecuted or defended in the name of the real party in interest. (Sec. 2, Rule 3 of 1997 Rules
of Civil Procedure). Only parties to a contract may sue or be sued upon that contract.
COUNTERCLAIM
That by virtue of this unwarranted and initiated by the plaintiff, defendant was
forced to engage counsel in the sum of ten thousand pesos (Php10, 000.00).
PRAYER
WHEREFORE, it is respectfully prayed that the complaint be dismissed for lack of
cause of action and defendant be awarded the amount of ten thousand pesos (Php
10,000.00).
Other relief's, just and equitable under the premises are likewise prayed for.
RESPECTFULLY SUBMITTED this 5th day of March 2013, Baguio City, Philippines.
ANGELICA F. VIVAS
Of Counsel
Roll No. 53516; May 3, 2008
PTR No. 486686; 01.11.2013; Baguio City
IBP Member 844018; 01.10.2013; Baguio City
MCLE Cert. of Compliance No. IV-0000732;
09.08.2012; Pasig City
Copy furnished by registered mail with registry return card:
EXPLANATION
Copy of the foregoing Answer was served through registered mail because of time
constraint and due to distance and lack of office personnel who can serve the same in
person.
ANGELICA F. VIVAS
TEOFILO CIANO,
Plaintiff, CIVIL CASE NO. 7369-R
For
- versus -
Annulment / Cancellation of REM with
Prayer for Preliminary Injunction with
JUAN DELA CRUZ, Issuance of TRO
Defendant.
ANSWER
That defendant, by the undersigned counsel, and to this Honorable Court specifically
denies under oath the genuineness and due execution of the instrument a copy of which is
attached to Plaintiff’s complaint as Annex “A”, the truth being that his signature thereon is
forged and that he did in fact sign the said instrument.
PRAYER
WHEREFORE, it is respectfully prayed that the complaint be dismissed.
Other relief's, just and equitable under the premises are likewise prayed for.
RESPECTFULLY SUBMITTED this 5th day of March 2013, Baguio City, Philippines.
ANGELICA F. VIVAS
Of Counsel
Roll No. 53516; May 3, 2008
PTR No. 486686; 01.11.2013; Baguio City
IBP Member 844018; 01.10.2013; Baguio City
MCLE Cert. of Compliance No. IV-0000732;
09.08.2012; Pasig City
EXPLANATION
Copy of the foregoing Answer was served through registered mail because of time
constraint and due to distance and lack of office personnel who can serve the same in
person.
ANGELICA F. VIVAS
10. Answer-in-Intervention:
TEOFILO CIANO,
Plaintiff, CIVIL CASE NO. 7369-R
For
- versus -
Annulment / Cancellation of REM
with Prayer for Preliminary
JUAN DELA CRUZ, Injunction with Issuance of TRO
Defendants,
CISA PEDRO
Intervenor.
ANSWER-IN-INTERVENTION
1) He is one of the co-owners of the property, subject matter of the petition for
partition, whose undivided share he sold to plaintiff intervenor.
1) Plaintiff-intervenor has not paid the full purchase of the property to answering
defendant, as he has not paid the unpaid balance of P2, 000,000.00, which he
refused to pay and still continues to refuse to pay the same, notwithstanding
demands.
PRAYER
WHEREFORE, defendant Juan dela Cruz respectfully prays that the complaint-in-
intervention be dismissed for lack of merit.
Alternatively, Pedro Manzano be ordered to pay the balance of the purchase price of
P2, 000,000, before the share off defendant de Castro may be transferred to him, as
purchaser of the undivided share.
Other relief's, just and equitable under the premises are likewise prayed for.
RESPECTFULLY SUBMITTED this 5th day of March 2013, Baguio City, Philippines.
LEON CRUZ
Of Counsel
Roll No. 53516; May 3, 2008
PTR No. 486686; 01.11.2013; Baguio City
IBP Member 844018; 01.10.2013; Baguio City
MCLE Cert. of Compliance No. IV-0000732;
09.08.2012; Pasig City
Copy of the foregoing Answer was served through registered mail because of time
constraint and due to distance and lack of office personnel who can serve the same in
person.
LEON CRUZ
I, JUAN DELA CRUZ, of legal age, Filipino citizen, with residence address at No.
203 Lopez Building, Session Road, Baguio City, under oath hereby depose and state that:
2. I have caused the preparation and filing of the Answer and have read the
allegations contained therein;
3. I have read and understood all the factual and material allegations in the said
Answer and that they are true and correct of our own personal knowledge and
based on authentic records;
IN WITNESS WHEREOF, I have hereunto set my hand this 5th day of March 2013 at
Baguio City, Philippines.
SUBSCRIBED AND SWORN to personally before me this 5th day of March 2012 at
Baguio City. Affiants JUAN DELA CRUZ, whom I indentified through his TIN ID with No.
144-064-477 bearing his photograph and signature, signed the document in my presence and
avowed under the penalty of law to the whole truth of the contents of the foregoing document.
ANGELICA F. VIVAS
Doc. No. ; NOTARY PUBLIC
Page No. ; UNTIL DECEMBER 31, 2013
Book No. ; 2nd FLOOR CUEVAS BLDG.,
Series of 2013. HILL AVENUE, BAGUIO CITY
TEL. NO. (074) 444-3333
PTR NO. 1234, 01-12-13
IBP MEMBERSHIP NO. 1234
ROLL OF ATTORNEY'S NO. 4567
COMMISSION SERlAL NO. 76-DS
MCLE COMPL. No. 022, 02-1-13
VII. INFORMATIONS
1. Information for Acts of Lasciviousness:
VICTORIA ABAD,
Complainant
NPS No. 1111
- versus -
FOR
ACTS OF LASCIVIOUSNESS
JUAN DELA CRUZ,
Accused.
INFORMATION
The undersigned hereby accuses, upon sworn complaint originally filed by the
offended party accuses JUAN DELA CRUZ of the crime of ACTS OF LASCIVIOUSNESS,
committed as follows:
That on or about February 16, 2013, in the City of Baguio, Philippines, within the
jurisdiction of this court, the said accused, actuated by lust, did then and there wilfully,
unlawfully, and feloniously, commit an act of lasciviousness on the person of Victoria Abad
by then and there embracing and kissing her and touching her breasts and sexual organs,
against her will and by means of force.
CONTRARY TO LAW.
PEDRO LIWANAG
Asst.City Prosecutor
APPROVED:
PETER SANTOS
City Prosecutor
CERTIFICATION
This is to certify that a preliminary investigation has been conducted in the above-
entitled case, wherein the accused was given a chance to appear and that on the basis of the
evidence presented there is reasonable ground to believe that the offense charged has been
committed and the accused is probably guilty thereof.
Bail Recommended: P 10,000.00
.Baguio City, Philippines, this 5th day of March, 2013.
PEDRO LIWANAG
Asst.City Prosecutor
ADULTERY
JUANA DELA CRUZ and JUAN
TAMAD,
Accused.
INFORMATION
The undersigned hereby accuses JUANA DELA CRUZ y SIPAG and JUAN
TAMAD of the crime of ADULTERY, committed as follows:
That on or about February 16, 2013, prior to and subsequent thereto, and
continuously up to the present time, in the City of Baguio, Philippines, and within the
jurisdiction of this Honorable Court, the said accused JUANA DELA CRUZ y SIPAG, being
then united in lawful wedlock with JUAN DELA CRUZ, willfully, unlawfully and
feloniously lay with and have carnal knowledge of her co-accused JUAN TAMAD, who in
turn, knowing that said JUANA DELA CRUZ was a married woman, willfully, unlawfully
and feloniously lay with and have carnal knowledge of her.
CONTRARY TO LAW.
PEDRO LIWANAG
City Prosecutor
APPROVED:
PETER SANTOS
City Prosecutor
CERTIFICATION
This is to certify that a preliminary investigation has been conducted in the above-
entitled case, wherein the accused was given a chance to appear and that on the basis of the
evidence presented there is reasonable ground to believe that the offense charged has been
committed and the accused is probably guilty thereof.
PEDRO LIWANAG
Asst.City Prosecutor
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LEGAL FORMS
3. Information for Concubinage:
CONCUBINAGE
JUAN DELA CRUZ and NOVITA
ORTIZ,
Accused.
INFORMATION
The undersigned hereby accuses JUAN DELA CRUZ and NOVITA ORTIZ, of the
crime of CONCUBINAGE, committed as follows:
That on or about February 16, 2013 and continuously up to the present time, in the
City of Baguio, Philippines, and within the jurisdiction of this Honorable Court, the said
JUAN DELA CRUZ, willfully, unlawfully and feloniously at the said time and place, being
then legally married to said complainant JUANA DELA CRUZ, cohabit with NOVITA
ORTIZ, a woman not his wife, living with her as husband and wife at No.28 Queen of
Peace, Baguio City, and the said NOVITA ORTIZ, knowing JUAN DELA CRUZ to be
married, unlawfully and feloniously cohabit with JUAN DELA CRUZ, living with him as
husband and wife at No. 28 Queen of Peace, Baguio City.
CONTRARY TO LAW.
PEDRO LIWANAG
City Prosecutor
APPROVED:
PETER SANTOS
City Prosecutor
CERTIFICATION
This is to certify that a preliminary investigation has been conducted in the above-
entitled case, wherein the accused was given a chance to appear and that on the basis of the
evidence presented there is reasonable ground to believe that the offense charged has been
committed and the accused is probably guilty thereof.
PEDRO LIWANAG
Asst.City Prosecutor
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LEGAL FORMS
4. Information for Damages:
INFORMATION
The undersigned hereby accuses JUAN DELA CRUZ of the crime of DAMAGE TO
PROPERTY THROUGH RECKLESS IMPRUDENCE, committed as follows, to wit:
That on or about February 16, 2013, at about 10:00 pm, in the City of Baguio and
within the jurisdiction of this Honorable Court, the said accused did then and there, while
driving his Sarao jeepney with Plate No. AYD 567 under the influence of liquor and in a
reckless and imprudent manner, bumped the his said jeepney into the residential house of
PEDRA SANTOS situated at No.72, Marcos Highway, Baguio City and along the national
highway, thereby causing damage to the front wall of the said residential house to the
damage and prejudice of its owner, PEDRA SANTOS, in the amount of P500, 000.
CONTRARY TO LAW.
PEDRO LIWANAG
City Prosecutor
APPROVED:
PETER SANTOS
City Prosecutor
CERTIFICATION
This is to certify that a preliminary investigation has been conducted in the above- entitled
case, wherein the accused was given a chance to appear and that on the basis of the evidence
presented there is reasonable ground to believe that the offense charged has been committed
and the accused is probably guilty thereof.
PEDRO LIWANAG
Asst.City Prosecutor
INFORMATION
“That sometime in April of 2004 and sometime subsequent thereto, in the City of
Baguio, Philippines, and within the jurisdiction of this Honorable Court, the accused
RODELIO V. PEREZ and VIRGINIA R. PEREZ, conspiring, confederating and mutually
aiding one another, with intent to defraud and by means of false pretenses or fraudulent
acts executed prior to or simultaneously with the commission of the fraud, did then and
there willfully, unlawfully and feloniously defraud JESUSA B. FREDERICK, in the
following manner, to wit: the said accused pretending that they had lawful and legal rights
and interest and the power and authority to sell a parcel of land particularly described as
Lot 9, Block 5 of the Woodsgate Square Subdivision containing an area of 263 square meters,
located at Camp 7, Baguio City and simultaneous thereto, by means of other similar deceits
take and receive the total sum of ONE MILLION FOUR HUNDRED FORTY SIX
THOUSAND FIVE HUNDRED PESOS (P1,446,500.00) Philippine Currency, from JESUSA
B. FREDERICK, in consideration for the sale of rights and interests over the said property in
favor of the latter, accused knowing that said manifestation and representations to be false
and fraudulent, and far from complying with their obligation to deliver the title of the
subject property, and despite repeated demands made upon them to do so or to return the
said amount, said accused then and there, willfully, unlawfully and feloniously with intent
to defraud, misappropriated, misapplied and converted the aforesaid amount of money to
their own personal use and benefit, to the damage and prejudice of JESUSA B. FREDERICK
in the aforementioned sum of ONE MILLION FOUR HUNDRED FORTY SIX THOUSAND
FIVE HUNDRED PESOS (P1,446,500.00) Philippine Currency.
CONTRARY TO LAW.”
PEDRO LIWANAG
City Prosecutor
APPROVED:
PETER SANTOS
City Prosecutor
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LEGAL FORMS
CERTIFICATION
This is to certify that a preliminary investigation has been conducted in the above-
entitled case, wherein the accused was given a chance to appear and that on the basis of the
evidence presented there is reasonable ground to believe that the offense charged has been
committed and the accused is probably guilty thereof.
No Bail Recommended.
.
Baguio City, Philippines, this 5th day of March, 2013.
PEDRO LIWANAG
Asst.City Prosecutor
ATTEMPTED HOMICIDE
JUAN DELA CRUZ
Accused.
INFORMATION
The undersigned hereby accuses JUAN DELA CRUZ of the crime of ATTEMPTED
HOMICIDE, committed as follows, to wit:
That on or about ,February 16,2009, in the City of Baguio, and within the jurisdiction
of this Honorable Court, the said accused, armed with a jungle knife, and with evident
intent to kill, did then and there willfully, unlawfully, and feloniously attack JUAN
TAMAD, with his said weapon, missing said JUAN TAMAD by only a fraction of an inch,
and would have continued his criminal act had not the said JUAN TAMAD successfully
resisted him with the help of some bystanders who responded to his cry for help.
CONTRARY TO LAW.
PEDRO LIWANAG
City Prosecutor
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LEGAL FORMS
APPROVED:
PETER SANTOS
City Prosecutor
CERTIFICATION
This is to certify that a preliminary investigation has been conducted in the above-
entitled case, wherein the accused was given a chance to appear and that on the basis of the
evidence presented there is reasonable ground to believe that the offense charged has been
committed and the accused is probably guilty thereof.
PEDRO LIWANAG
Asst.City Prosecutor
JUAN TAMAD,
Complainant NPS No. 1111
- versus -
FOR
FRUSTRATED HOMICIDE
JUAN DELA CRUZ
Accused.
INFORMATION
That on or about February 16,2009, in the City of Baguio and within the jurisdiction
of this Honorable Court, the said accused, armed with a jungle knife, and with evident
intent to kill, did then and there willfully, unlawfully, and feloniously assault, attack and
wound one JUAN TAMAD inflicting mortal wounds in different parts of his body, which
would have directly caused the death of said JUAN TAMAD, thus performing all acts of
execution which would have produced the crime of homicide as a consequence, but
nevertheless did not produce the same by reason of caused independent of his will, that is,
because of the timely medical assistance rendered on the said JUAN TAMAD.
CONTRARY TO LAW.
PEDRO LIWANAG
City Prosecutor
APPROVED:
PETER SANTOS
City Prosecutor
CERTIFICATION
This is to certify that a preliminary investigation has been conducted in the above- entitled
case, wherein the accused was given a chance to appear and that on the basis of the evidence
presented there is reasonable ground to believe that the offense charged has been committed
and the accused is probably guilty thereof.
PEDRO LIWANAG
Asst.City Prosecutor
JUAN TAMAD,
Complainant NPS No. 1111
FOR
- versus -
LESS SERIOUS PHYSICAL
INJURIES
JUAN DELA CRUZ
Accused.
INFORMATION
The undersigned hereby accuses JUAN DELA CRUZ of the crime of LESS
SERIOUS PHYSICAL INJURIES, committed as follows, to wit:
That on or about February 16, 2013 at about 9:00 pm, in the City of Baguio and within
the jurisdiction of this Honorable Court, the said accused did there and then willfully,
unlawfully and feloniously, and without justifiable cause therefor, attack, assault, and beat
one JUAN TAMAD, punching and kicking him in different parts of his body, thereby
CONTRARY TO LAW.
PEDRO LIWANAG
City Prosecutor
APPROVED:
PETER SANTOS
City Prosecutor
CERTIFICATION
This is to certify that a preliminary investigation has been conducted in the above-
entitled case, wherein the accused was given a chance to appear and that on the basis of the
evidence presented there is reasonable ground to believe that the offense charged has been
committed and the accused is probably guilty thereof.
Bail Recommended: P 10,000.00
.
Baguio City, Philippines, this 5th day of March, 2013.
PEDRO LIWANAG
Asst.City Prosecutor
ILLEGAL DETENTION/KIDNAPPING
JUAN DELA CRUZ
Accused.
INFORMATION
The undersigned accuses JUAN DELA CRUZ, of the crime of SERIOUS ILLEGAL
DETENTION/KIDNAPPING, committed as follows:
That about and during the period beginning the 3rd day of January, 2013, in the City of
Baguio, Philippines, and within the jurisdiction of the Honorable Court, said JUAN DELA
CRUZ suspecting that one JUAN TAMAD had knowledge of the elopement of her sister, did
then and there wilfully, unlawfully, feloniously and by force, take said JUAN TAMAD, a man
40 years of age, while the latter was walking in Harrison Road, whom said accused detained
and kept locked in his room from January 3 to March 3, 2009, or a period of 58 days under
restraint and against the will of the said JUAN TAMAD, and said accused did, during said
period of detention, maltreat and refuse to release said JUAN TAMAD until the accused was
found.
CONTRARY TO LAW.
PEDRO LIWANAG
City Prosecutor
APPROVED:
PETER SANTOS
City Prosecutor
CERTIFICATION
This is to certify that a preliminary investigation has been conducted in the above- entitled
case, wherein the accused was given a chance to appear and that on the basis of the evidence
presented there is reasonable ground to believe that the offense charged has been committed
and the accused is probably guilty thereof.
PEDRO LIWANAG
Asst.City Prosecutor
JUAN TAMAD,
Complainant NPS No. 1111
FOR
- versus -
MALVERSATION
JUAN DELA CRUZ
Defendant.
INFORMATION
That on or about February 16,2009,in the City of Baguio and within the jurisdiction of
this Honorable Court, the said accused, then being then the Treasurer of the City of
|Baguio, did then and there willfully, unlawfully, and feloniously, and with grave abuse of
confidence, misappropriate, take, withdraw, and convert for his own personal use and
benefit, the total amount of P500,000.00 which are public funds belonging to the City of
Baguio, to the damage and prejudice of the public interest.
CONTRARY TO LAW.
PEDRO LIWANAG
City Prosecutor
APPROVED:
PETER SANTOS
City Prosecutor
CERTIFICATION
This is to certify that a preliminary investigation has been conducted in the above-
entitled case, wherein the accused was given a chance to appear and that on the basis of the
evidence presented there is reasonable ground to believe that the offense charged has been
committed and the accused is probably guilty thereof.
PEDRO LIWANAG
Asst.City Prosecutor
JUAN TAMAD,
Complainant NPS No. 1111
FOR
- versus -
PARRICIDE
JUAN DELA CRUZ
Defendant.
INFORMATION
The undersigned hereby accuses JUAN DELA CRUZ of the crime of PARRICIDE,
committed as follows, to wit:
That on or about February 16, 2013 at about 11:00 pm, in the City of Baguio and
within the jurisdiction of this Honorable Court, the said accused, motivated by extreme
jealously, and while armed with a .38 caliber pistol, did then willfully, unlawfully, and
feloniously, suddenly, unexpectedly, and treacherously fired several shots at JUANA DELA
CRUZ, his lawfully wedded wife, which caused the instantaneous death of his said wife.
CONTRARY TO LAW.
PEDRO LIWANAG
City Prosecutor
APPROVED:
PETER SANTOS
City Prosecutor
CERTIFICATION
This is to certify that a preliminary investigation has been conducted in the above-
entitled case, wherein the accused was given a chance to appear and that on the basis of the
evidence presented there is reasonable ground to believe that the offense charged has been
committed and the accused is probably guilty thereof.
No Bail Recommended.
PEDRO LIWANAG
Asst.City Prosecutor
VICTORIA ABAD,
Complainant
NPS No. 1111
- versus -
FOR
RAPE
JUAN DELA CRUZ,
Accused.
INFORMATION
The undersigned hereby accuses, upon sworn complaint originally filed by the
offended party accuses JUAN DELA CRUZ of the crime of RAPE, committed as follows:
That on or about February 16, 2013, in the City of Baguio, Philippines, within the
jurisdiction of this court, the said accused, actuated by lust, did then and there wilfully,
unlawfully, and feloniously, commit a , had carnal knowledge against her will and by
means of force, violence, intimidation and threats on the person of Victoria Abad.
CONTRARY TO LAW.
PEDRO LIWANAG
Asst.City Prosecutor
APPROVED:
PETER SANTOS
City Prosecutor
CERTIFICATION
This is to certify that a preliminary investigation has been conducted in the above-
entitled case, wherein the accused was given a chance to appear and that on the basis of the
evidence presented there is reasonable ground to believe that the offense charged has been
committed and the accused is probably guilty thereof.
PEDRO LIWANAG
Asst.City Prosecutor
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LEGAL FORMS
13. Information for Robbery:
FOR
- versus -
ROBBERY
JUAN DELA CRUZ
Defendant.
INFORMATION
The undersigned hereby, accuses JUAN DELA CRUZ of the crime of ROBBERY,
committed as follows, to wit:
That on or about February 16,2009 at about 11:00 pm, in the City of Baguio and
within the jurisdiction of this Honorable Court, the said accused did then and there,
willfully, unlawfully, feloniously, with intent to gain and with intimidation upon the person
of JUAN TAMAD by threatening him with a .38 caliber pistol, took and carry away the
latter's T303 SONY ERRICSON mobile phone valued at P15,000 Philippine Currency, to the
to the damage and prejudice of the said JUAN TAMAD in the said amount.
CONTRARY TO LAW.
PEDRO LIWANAG
City Prosecutor
APPROVED:
PETER SANTOS
City Prosecutor
CERTIFICATION
This is to certify that a preliminary investigation has been conducted in the above-
entitled case, wherein the accused was given a chance to appear and that on the basis of the
evidence presented there is reasonable ground to believe that the offense charged has been
committed and the accused is probably guilty thereof.
No Bail Recommended.
.
Baguio City, Philippines, this 5th day of March, 2013.
PEDRO LIWANAG
Asst.City Prosecutor
FOR
- versus -
SEDUCTION
JUAN DELA CRUZ
Defendant.
INFORMATION
The undersigned upon sworn complaint filed by the offended party, copy of which is
attached hereto, accuses JUAN DELA CRUZ, of the crime of SIMPLE SEDUCTION,
committed as follows:
That on or about February 16, 2009, in the City of Baguio Philippines, within the
jurisdiction of the court, the said accused did then and there wilfully, unlawfully and
feloniously and by means of deceit, have sexual intercourse with PEDRA SIPAG, an
unmarried girl over twelve but under eighteen years of age.
CONTRARY TO LAW.
PEDRO LIWANAG
City Prosecutor
APPROVED:
PETER SANTOS
City Prosecutor
CERTIFICATION
This is to certify that a preliminary investigation has been conducted in the above-
entitled case, wherein the accused was given a chance to appear and that on the basis of the
evidence presented there is reasonable ground to believe that the offense charged has been
committed and the accused is probably guilty thereof.
No Bail Recommended.
.Baguio City, Philippines, this 5th day of March, 2013.
PEDRO LIWANAG
Asst.City Prosecutor
FOR
- versus -
VIOLATION OF R.A. 9262
JUAN DELA CRUZ
Defendant.
INFORMATION
The undersigned hereby accuses JUAN DELA CRUZ of VIOLATION OF R.A. 9262
(ANTI-WOMEN’S VIOLENCE ACT) committed as follows:
That sometime in February 16,2009 in the City of Baguio, Philippines and within the
jurisdiction of this Honorable Court, the above-named accused did there and then, willfully,
unlawfully and criminally and with intent to manipulate the conduct of his wife and
children to beg money from him, commit acts of economic abuse against his wife, JUANA
DELA CRUZ and their minor children, by refusing to give them any financial support,
which is legally due them under the law, to their damage and prejudice.
PEDRO LIWANAG
City Prosecutor
APPROVED:
PETER SANTOS
City Prosecutor
CERTIFICATION
This is to certify that a preliminary investigation has been conducted in the above-
entitled case, wherein the accused was given a chance to appear and that on the basis of the
evidence presented there is reasonable ground to believe that the offense charged has been
committed and the accused is probably guilty thereof.
No Bail Recommended.
.Baguio City, Philippines, this 5th day of March, 2013.
PEDRO LIWANAG
Asst.City Prosecutor
EJECTMENT is a legal action brought by one claiming a right to possess real property against another who
possesses the premises adversely or who is a holdover tenant who remains beyond the termination of a lease
but who is not merely a trespasser.
-COMPLAINT-
PLAINTIFF, through undersigned counsel, unto this Honorable Court, most respectfully states that:
Plaintiff is of legal age, single, a Filipino citizen, with residence and postal address located at #05 Purok 2, Camp
7, Baguio City.
Defendant is likewise of legal age, a Filipino citizen, single, and resident of No. 3 Upper Engineer's Hill, Baguio
City where he may be served with summons and other notices of the Honorable Court;
On January 14, 2011, Defendant entered into a lease agreement with the Plaintiff over an apartment covered by
ARP No. 2346 (Annex “A”) which the latter owns is located at No. 3 Upper Engineer's Hill, Baguio City. The
aforementioned apartment, which is specifically described as Unit C First Floor was rented out on a monthly rental
rate of TEN THOUSAND (P/ 10, 000.00) Pesos, renewable upon the discretion of the Plaintiff. This is evidenced
by the Contract of Lease signed by the parties, attached hereto as Annex “B” and made an integral part hereof;
During the second one (1) year period, Defendant started the failure to pay the stipulated monthly rentals on time,
sometimes six months late. Consequently, the defendant has incurred huge rental arrearages and that her stay
over at the lease premises was merely tolerated by the plaintiff and payable on a month to month basis;
Repeated demands were then made on the defendant to pay her rental arrearages which on January 14 2012
already amounted to SIXTY THOUSAND (P/ 60, 000.00) Pesos, Philippine Currency (photocopy of the demand
letter is hereto attached as Annex “C” and made an integral part hereof) and vacate the apartment reiterating that
the Contract of Lease has not been fulfiled. Despite having received the same however, the defendant refused to
pay the entire amount which she owe the plaintiff and continued to make use of the leased premises;
Defendant with evident bad faith also unjustifiably ignored the numerous pleas of the plaintiff for them to pay their
valid obligation which the latter had also earlier earmarked as payment of their obligations. Defendant’s actions
caused moral anguish, anxiety, and sleepless nights as well as wounded feelings to the Plaintiff;
Likewise, due to the deleterious actions of the Defendant, the Plaintiff were forced to litigate this case in court and
in the process was compelled to seek legal services which fees amounted to P/ 20,000 by way of acceptance fees
and further expects to incur P/ 1,500.00 as appearance fees for each and every time this case is set for hearing.
These amounts should be assessed against the Defendant and that they should be ordered to reimburse the said
amounts to the plaintiff.
PRAYER
Wherefore, premises considered, it is respectfully prayed, after due notice and hearing that the decision be rendered by this
Honorable Court granting the following relief, viz:
1. Defendant be made to pay to the Plaintiff the amount of SIXTY THOUSAND (P/ 60, 000) Pesos, Philippine
Currency representing unpaid rental arrearages as well as forthcoming monthly rentals until the premises is
vacated.
2. To pay moral damages to be assessed by the Honorable Court which amount is prayed to be not less than P/
20,000.00 and to reimburse the Plaintiff of the amount which they paid as attorney’s fees (I.e. P/ 20,000.00 as
acceptance fee and P/ 1,500.00 appearance fee each every time the case set for hearing);
Other reliefs just and equitable are likewise prayed for.
I, MARIA AQUINO, single, of legal age, a Filipino citizen, with residence located at #05 Purok 2, Camp 7, Baguio City, under
oath state that:
I am the Plaintiff in the above captioned case. I have caused the preparation of the foregoing complaint, and all the
allegations therein are true and correct to the best of my knowledge and discretion.
I further certify that I have not heretofore commenced by any other action or proceeding involving the same issue in
any court, tribunal, or agency.
MARIA AQUINO
CTC No. 123456
Issued 10-23-09
At Baguio City, Philippines
SUBSCRIBED AND SWORN to before me, this 30th day of January 2013 at Baguio City, Benguet,, affiant exhibited to me this
Community Tax Certificate indicated below her name and signature.
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Cc:
Atty. Minda Aquino
Counsel for Defendant
Suite A, Jia Yo Bldg., Baguio City, Benguet
NOTICE TO VACATE
January 30, 2013
Please be informed that your stay in our apartment has long been overdue. This is to the fact that you have not paid your monthly
rentals as you have promised to pay for almost five months now. We are now instructing you to vacate the said apartment as soon
as possible five (5) days upon receiving the notice to vacate.
Sincerely yours.
MARIA AQUINO
#05 Purok 2, Camp 7
Baguio City
Plaintiff, through undersigned counsel, unto this Honorable Court, most restpectfully states that:
1. Plaintiff is a Filipino, of legal age, single with residence and postal address located at Gibraltar Rd.,, Baguio City;
2. Defendant is also a Filipino, of legal age, single, and a resident of #9 Lexber Homes, Camp 8, Baguio City, where she may
be served court summons and processes;
3. Plaintiff owns a residential lot containing Four Hundred Fifty (450) Square Meters at #10 Lexber Homes, Baguio City as
described by TCT No. T-5138 and Tax Declaration No. 88-012-01064, and herein attached as Annexes “A” and “B” to form
an integral part thereof;
4. Sometime in August 2012, the defendant, by means of force, intimidation, strategy and stealth, unlawfully entered upon the
above described property thereby ejecting the caretakers of the plaintiff;
5. As if to add injury, defendant commenced building an extension of her house and planting vegetables on the said property
of plaintiff;
6. On September 2012, the caretakers reported to the plaintiff that the defendant commenced such activities;
7. The plaintiff confronted the defendant but she refused to remove said improvements and still persists in continuing the
unlawful acts upon the property.
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court that:
9. After due notice and hearing, to issue Writ of Preliminary Injunction ordering defendant:
1. To allow plaintiff to take possession of her property;
2. To make the Preliminary Injunction against defendant permanent and indefinite;
I, MAY ANN SOLIS, of legal age, a Filipino Citizen, with residence and postal address located at Gibraltar Rd.,, Baguio
City, under oath states that:
3. I am plaintiff in the above-captioned case, I have caused the preparation of the foregoing Complaint, and all the
allegations therein are true and correct to the best of my knowledge and discretion;
4. I further certify that I have not here-to-fore commence any other action or proceeding involving the same issue in
any court, tribunal, or agency;
In witness whereof, I have hereunto set my hand this 30th day of January 2013, Baguio City, Philippines.
Subscribed and sworn to before me this 30th day of January 2013, Baguio City, Philippines, plaintiff, who is personally
known to me, exhibited her CTC indicated under her name and signature.
Doc. No. ;
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Cc:
Daphne Castro
Counsel for Defendant
AV Bldg.
Baguio City
Tiong San Department Store, a business company existing and registered under the Securities
and Exchange Commission (SEC), owned by Edward Lao, located at Magsaysay, Baguio City, herein
after known as the Client;
and
Dela Cruz Law Firm and Associates under the leadership of Atty. Juan Dela Cruz, based and
located at Chanum St., Baguio City herein known as the corporate counsel for the client;
WITNESSETH:
WHEREAS, the client entered into and acquired the legal services of Atty. Juan Dela Cruz as
the counsel of the Tiong San Department Store in the case instituted by the latter against Maria
Aquino, docketed as No. E1 – 23456, at Branch 7 of the Regional Trial Court for the case of Shop
Lifting;
WHEREAS, while the engagement of Atty. Mau Tang – ad as lawyer for the Tiongsan
Department Store, the following terms and conditions have agreed upon:
1. That Atty. Juan Dela Cruz shall not engage his legal services to any business
corporations and institutions having related and similarities to that of the business operated by
the Tiongsan;
2. That the legal services agreement between the Tiongsan and Atty. Juan Dela Cruz would
expire after five (5) years or on February 2, 2015;
3. That the Tiongsan would not engage the legal services of other lawyers without the prior
consent of Atty. Juan Dela Cruz;
4. That any violation committed by either party to the terms and conditions of this contract
shall be subject to legal sanctions.
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 9th day of January 2013,
personally appeared EDWARD LAO and ATTY. JUAN DELA CRUZ personally known to me to
be the same persons who voluntary executed the foregoing Contract of Legal Services which they
acknowledged before me as their free and voluntary acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this
acknowledgment is written has been signed on the left margin of each and every page thereof by the
parties and their witnesses.
I, PEDRO RAMOS, single, of legal age, Filipino citizen, with residence and postal address at
No.14 M. Roxas, Trancoville, Baguio City, Philippines, DO HEREBY NAME, CONSTITUTE AND
APPOINT PABLO DE LEON, of legal age, single, Filipino, and a resident of No. 09-C Rimando
Road, Baguio City, Philippines, to be my true and lawful attorney-in-fact, for me and in my name,
place and stead to perform the following acts and things, to wit:
To manage and administer all my property, real and personal, that may be found in the
Philippines;
To ask demand, sue for, recover, collect and receipt for any and all sums of money, debts,
accounts, legacies, bequests, interest, dividends, demands, and other things of value of
whatsoever nature or kind as may now be or may hereafter become due, owing, payable or
belonging to me , and to have, use and take any and all lawful ways and means for the recovery
thereof by suit, attachment, garnishment or otherwise, and to compromise, settle and agree for
the same;
To buy or negotiate for the sale, hire or lease, mortgage, or otherwise hypothecate lands,
tenements and hereditaments or other forms of real property, upon such terms and conditions
and under such covenants as my said attorney-in-fact shall see fit and proper;
To purchase and sell, mortgage pledge or otherwise hypothecate goods, wares, merchandise,
chattels, and other personal property or in action;
To attend any and all meetings, special, regular, ordinary or extraordinary, of any and all firms,
corporations, association, or other concerns of which I may now be or hereafter become a
member or stockholder, and then and there to exercise my voice and vote and whatsoever other
privileges, rights and prerogatives as may correspond to me by reason of my membership,
shares or other participation therein;
To make, sign, execute and deliver contracts, documents, agreements, and other writings of
whatever nature or kind, with any and all third persons, concerns, or entities, upon terms and
conditions acceptable to my said attorney;
To delegate in whole or in part any or all of the powers herein granted or conferred, by means
of an instrument in favor of any third person whom my said attorney may select.
HEREBY GIVING AND GRANTING unto my said attorney full power and authority
whatsoever requisite or necessary or proper to be done in and about the premises as fully to all intents
and purposes as I might or could lawfully do if personally present, with power of substitution and
revocation, and hereby, ratifying and confirming all that my said attorney or his substitute shall
lawfully do or cause to be done under and by virtue of this presents.
IN WITNESS WHEREOF, I have hereunto set my hand this 10th day of January 2013, in the
City of Baguio, Philippines.
PEDRO RAMOS
Principal
Passport No.zz0023023
Valid until May 30, 2016
Conforme:
PABLO DE LEON
Attorney-in-fact
TIN 090-922-000
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 10th day of January 2013,
personally appeared PEDRO RAMOS AND PABLO DE LEON who exhibited to me their respective
identification documents as appearing below their respective names and signatures, known to me as the
same persons who executed and voluntarily signed the foregoing GENERAL POWER OF
ATTORNEY which they acknowledged before me as their free and voluntary acts and deeds.
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WE, SPOUSES CRISTINA DE LEON and PABLO DE LEON, both of legal age, Filipino
citizens, with residence and postal address at No. 37 Barangay Ferdinand, Campo Sioco, Baguio City,
hereby NAME, CONSTITUTE AND APPOINT LORNA JUAN, single, of legal age, with residence and
postal address at No. 132-B Fairview Subdivision, Baguio City, Philippines, as our true and legal
representative to act for and in our names and stead, within a period of ONE (1) YEAR, and to perform the
following acts, deeds and things, to wit:
To Sell, offer for sale, and come to an agreement as to the purchase price, and thereafter
to sign for us and in our name and receive payment from the sale of our property, a motor
vehicle, more particularly described as follows:
To sign, execute and deliver the Deed of Absolute Sale, contract or any other instrument
or document of whatever kind, as may be necessary or proper as said Attorney-in-Fact may, in
her discretion, deem to be our best interest.
To demand, collect, receive and accept the proceeds thereof, the purchase price be on
the amount of SIX HUNDRED THOUSAND PESOS (Php600,000.00), in cash or in check,
and, if in check, to endorse and encash the same in any third party and/or any bank or banking
institution.
HEREBY GRANTING unto our representative full power and authority to execute and
perform every act necessary to render effective the power to sell the foregoing properties, as fully to
all intents and purposes as we might or could do if personally present shall lawfully do or cause to be
done by virtue of these presents with full power of substitution and revocation, and HEREBY
RATIFYING AND CONFIRMING ALL that our Attorney-in-fact or her substitute shall lawfully
do or cause to be done by virtue hereof.
IN WITNESS WHEREOF, we have hereunto set our hands this 10th day of January 2013, in
the City of Baguio, Philippines.
Conforme:
LORNA JUAN
Attorney-in-Fact
BEFORE ME, a Notary Public in and for the City of Baguio, this 10th day of January 2013,
personally appeared Spouses CRISTINA DE LEON AND PABLO DE LEON who exhibited to me
their respective identification documents as indicated below their respective names and signatures,
known to me as the same persons who executed and voluntarily signed the foregoing Special Power of
Attorney to Sell a Personal Property which they acknowledged before me as their free and voluntary
acts and deeds.
This instrument consisting of TWO (2) pages, including the page on which this
Acknowledgment is written has been signed on the left margin of each and every page thereof by the
parties and their witnesses.
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Series of 2013.
I, PEDRO RAMOS, Filipino, of legal age, single and a resident of No. 89-C Military Cut-off,
Baguio City, Philippines, after being sworn to in accordance with law, hereby depose and state:
1. That by these presents, I hereby state that I have voluntarily resigned as STAFF NURSE of
ALL IS WELL HOSPITAL located at No. 67 Magsaysay Avenue, Baguio City;
2. That I hereby acknowledge to have received from my employer the sum of ONE
HUNDRED THOUSAND PESOS (P100,000.00) which is in full and final satisfaction of my salary
and other benefits that may be due me for the service which I have rendered for the latter;
3. That I hereby declare that I have no further claims whatsoever against my employer, its
President, members of the Board, officers or any of its staff and that I hereby release and forever
discharge all of them from any and all claims, demands, cause of action of whatever nature arising out
of my employment with the latter;
4. I further agree that this WAIVER, RELEASE AND QUITCLAIM may be pleaded in bar to
any suit or proceeding (Civil, SSS, PhilHealth, Medicare, Labor, etc.) to which either I, or my heirs and
assigns, may have against my employer in connection with my employment with the latter;
5. That the payment which I have received as provided herein should not in any way be
construed as an admission of liability on the part of my employer and is voluntarily accepted by me and
will, if need be, serve as full and final settlement of any amounts due me or any claims or cause of
action, either past, present, future, which I may have in connection with my employment with my
employer;
5. As such, I finally make manifest that I have no further claims or cause of action against
my employer or any person connected with the administration and operation of the latter and forever
release the latter from any and all liability.
IN WITNESS WHEREOF, I have hereunto set my hand this 14th day of February 2012 in
Baguio City, Philippines.
PEDRO RAMOS
Affiant
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WHEREAS, I, MYLA CRUZ, of legal age, married, resident of Aurora Hill, Baguio City, by
a certain public instrument made and executed in Kayang St., Baguio City on January 30, 2012 before
Atty. Jed Cristobal, Notary Public for and in the City of Baguio, and bearing not. Reg. No. 23; page 2,
Book V, Series of 2009 of his Notarial Register, did name, constitute, and appoint Jed Cristobal,
resident of Bakakeng, Baguio City, mt true and lawful ATTORNEY – IN – FACT, for the purpose
and with powers mentioned in said public instrument;
WHEREAS, the said public instrument or Power of Attorney, was duly registered in the Office
of the Register of Deeds of Baguio City on February 2, 2012, as per entry no. 2, Vo. II, Book I, of said
Office;
ACKNOWLEDGMENT
BEFORE ME, a Notary Public in and for the City of Baguio, this 10th day of January 2013,
personally appeared MYLA CRUZ personally known to me to be the same person who voluntary
executed the foregoing Revocation of Power of Attorney which they acknowledged before me as their
free and voluntary acts and deeds.
This instrument consisting of ONE (1) page, including the page on which this acknowledgment
is written has been signed on the left margin of each and every page thereof by the parties and their
witnesses.
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WHEREAS, I KIM ANDERSON, of legal age, married, resident of North Sanitary Camp,
Baguio City, had been appointed ATTORNEY – IN – FACT of Gerald Chiu, of legal age, married,
resident of Camp Dangwa, La Trinidad, Benguet, by virtue of a POWER OF ATTORNEY executed
in Baguio City on January 30, 2012 and acknowledged before Emilia Sandejas, Notary Public for and
in the City of Baguio, and bearing Not. Reg. No. 12, Page no. 3, Book II, Series of 2012 of her Notarial
register;
WHEREAS, by the said power of attorney, I was granted full power to appoint a substitute of
my choice for and in respect of all or any of the matters mentioned in said power of attorney;
WHEREAS, by virtue of said grant, I hereby name, constitute and appoint Jake Benca, my
true and lawful SUBSTITUTE ATTORNEY for me and my name as Attorney – in – Fact of said
Gerald Chiu, and in his name, place and stead, to do and perform any and all acts and things which I, as
Attorney – in – Fact of said Gerald Chiu could lawfully do and perform under said power of attorney,
as fully to all intents and purposes as I or said Gerald Chiu, might or could lawfully do if personally
present, save only in the matter of appointing a substitute other than the substitute herein designated;
and
HEREBY RATIFYING AND CONFIRMING all that said Jake Benca may lawfully do or
cause to be done by virtue of this presents.
th
IN WITNESS WHEREOF, I have hereunto set my hand this 10 day of January 2013 in the
City of Baguio, Philippines.
________________
(Sgd) KIM ANDERSON
BEFORE ME, a Notary Public in and for the City of Baguio, this 10th day of January 2013,
personally appeared MYLA CRUZ personally known to me to be the same person who voluntary
executed the foregoing Revocation of Power of Attorney which they acknowledged before me as their
free and voluntary acts and deeds.
This instrument consisting of ONE (1) page, including the page on which this acknowledgment
is written has been signed on the left margin of each and every page thereof by the parties and their
witnesses.
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