Republic of The Philippines Metropolitan Trial Court National Capital Judicial Region Branch - , Quezon City

Republic of the Philippines
METROPOLITAN TRIAL COURT

National Capital Judicial Region
Branch ____, Quezon City
NAPOLEON C. GATMAITAN
Plaintiff,
-versus- CIVIL CASE NO. _____

For: Collection of a Sum of
EDGARDO S. SANTOS Money
Defendant.
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COMPLAINT
PLAINTIFF, thru the undersigned Counsel, unto this Honorable Court,
respectfully alleges:
1. That Plaintiff is of legal age, Filipino, married to Nancy A.
Gatmaitan, and with residence at # 11 Bohol St., Barangay Horseshoe, Quezon
City;
2. That Defendant is likewise of legal age, Filipino, married and with
residence at # 15 Bohol St., Barangay Horseshoe, Quezon City, where he could be
served with summons and other processes of the Court;
3. That the above-named spouse of Plaintiff is the erstwhile business
partner of the defendant from year 2007 to 2009;
4. That in the course of their business, the plaintiff’s spouse made
financial contributions through the request and assurances of the defendant that
such amount will be repaid. That however, after several months and upon
inquiry, plaintiff’s spouse found out that defendant misappropiated the financial
investments made for his own personal use. That despite demands, defendant
failed to remit to and/or settle with the plaintiff’s spouse the aggregate amount of
Ninety Eight Thousand Seven Hundred Pesos (P98,700.00);
5. That in recognition of defendant’s obligation in favor of plaintiff’s
spouse, the former executed an Acknowledgement of Debt in favor of the
plaintiff on January 26, 2008, a photocopy of which is attached hereto as Annex
“A”;
6. That by reason of the kindness and generosity of plaintiff’s spouse,
defendant’s obligation through the Acknowledgement was reduced to the sum
of Sixty Thousand Pesos (P60,000.00), and transferred in favor of the plaintiff as
formalized n a duly-notarized Loan Agreement entered by and between the
plaintiff and the defendant on January 29 2008, a photocopy of which is hereto
attached as Annex “B”;
7. That part of said Loan Agreement is the obligation of the
defendant-debtor to pay the plaintiff-creditor the amount of Two Thousand Five
Hundred Pesos (P2,500.00) in monthly installments for thirty six (36) months, in
the form of cash from February 2008 to March 2011, and in the form of post-
dated checks from February 2008 onwards up to the full satisfaction of said loan,
including interest, set at two percent (2%) per month;
8. That after paying Two Thousand Five Hundred Pesos (P2,500.00) in
February 2008 and One Thousand Five Hundred Pesos (P1,500.00) only in March
2008 the defendant-debtor has started defaulting in the payment of his due
accounts;
9. That plaintiff-creditor sent separate letters (dated April 7, 2008 and
May 21, 2008) to the defendant-debtor containing a demand for the payment of
his outstanding payable, photocopies of which are hereto attached as Annexes
“C” and “C-1”;

10. That the continued refusal of defendant to settle his account
prompted the plaintiff-creditor to lodge a complaint with the barangay officials
of Barangay Horseshoe, Quezon City. A Certificate to File Action, copy of which
is hereto attached as Annex “D,” was subsequently issued for failure of the
parties to come to an Agreement.
11. That on June 1, 2008 a final demand letter was sent to the
defendant-debtor for the payment of his outstanding payable up to July 2008,
which however, was left unheeded, a photocopy of which is hereto attached as
Annex “E”;
12. That the demand letter was duly received by defendant thru his
wife Mrs. Veronica A. Santos on June 3, 2008, as shown by a Certification dated
June 25, 2008 issued by the Quezon City Central Post Office, copy of which is
hereto attached as Annex “F”;
13. That defendant-creditor has, as of this date, defaulted in the
payment of an aggregate amount of Twenty-six Thousand Pesos (P26,000.00);
14. That notwithstanding plaintiff-creditor’s repeated oral and written
demands, defendant-debtor failed and refused and still fails and refuses to heed
to the former’s just and valid demands, leaving the plaintiff no other recourse
but to litigate and file this acton.
15. That by reason of defendant’s unjustified acts as well as bad faith
and intentional refusal to pay his overdue obligation, Plaintiff is entitled to the
award of moral damages in the amount of P5,000.00;
16. That by reason of defendant’s violation and disregard of Plaintiff’s
rights, the award of exemplary damages in the amount of P5,000.00 is likewise
warrant to serve as a deterrent to the commission by the defendant and to others
similarly-minded of similar acts in the future.

PRAYER
WHEREFORE, PREMISES CONSIDERED, it is most respectfully prayed
of this Honorable Court that, after due hearing, judgment be rendered against
the defendant ordering the latter to pay the plaintiff as follows:
1. The amount of TWENTY SIX THOUSAND PESOS representing the
unpaid monthly installments due under the Loan Agrement dated August 6,
2005;
2. The amount of P5,000.00 as and by way of moral damages;
3. The amount of P5,000.00 as and by way of exemplary damages;
4. Cost of suit.
Other reliefs just and equitable under the premises are likewise prayed
for.
Quezon City,______________
Atty. ANGELICO ZENON M. DELOS REYES

Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave., Libis, Quezon City
Roll No. 76430 IBP No. 352980 dated 1-2-08
MCLE Compliance No. 11-00043527
VERIFICATION/CERTIFICATION
OF NON-FORUM SHOPPING
I, NAPOLEON C. GATMAITAN, Filipino, of legal age with address at #11

Bohol St., Barangay Horseshoe, Quezon City after having been duly sworn on
accordance with law depose and say:
1. That I am the plaintiff in the above-entitled case;
2. That I caused the preparation of the foregoing Complaint and I have

read the allegations therein and certify that the same are true and correct of my
own personal knowledge;
3. That I further certify that I have not commenced any other action
involving the same issues before the Supreme Court, Court of Appeals or any
division thereof or any tribunal or agency; and to the best of my knowledge no
such action is pending before the Supreme Court, Court of Appeals or any
division thereof or any tribunal or agency;
4. That in the event that any action involving the same should be made
known, I hereby bind myself to report the same within five (5) days from
knowledge thereof to this Honorable Court.
WITNESS WHEREOF, I hereunto set my hand this _______ day of

________, ________ at Quezon City, Metro Manila, Philippines.
Plaintiff
SUBSCRIBED AND SWORN TO before me this ______ day of ______,

______ at Quezon City, affiant having exhibited to me her CTC No. ___________
issued on __________ at __________.
NOTARY PUBLIC
Doc. No._____
Page No. ____
Book No. _____
Series of _____
REGIONAL TRIAL COURT
Plaintiff,

Defendant.
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MOTION FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADING
COMES NOW the Defendant, by the undersigned counsel, and unto this
Honorable Court, respectfully moves:
1. The Complaint in this matter was served on Edgardo S. Santos on
_______________________, making his Answer due on ____________________;
2. Due to the scheduling logistics of undersigned counsel, Defendant need
and respectfully request a short extension in which to file his Answer to the
Complaint;
3. Undersigned counsel request a two-week extension, making his Answer
due on ___________________.
WHEREFORE, Defendant herein and undersigned counsel respectfully
request a two-week extension from__________ to _________ in which to file their
Answer to the Complaint.
Quezon City, __________________

ATTY. LOUISE MARIE S. PEREZ
Counsel for Defendant
Citibank Tower Eastwood City Bagumbayan, Quezon City
NOTICE OF HEARING
To: Atty. Angelico Zenon M. Delos Reyes

Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City
Greetings:
Please take notice that on Friday, _______________, at 8:00 o’clock A.M., or as

soon thereafter as counsel may be heard, the undersigned will ask Branch _____
of the Regional Trial Court of Quezon City to approve the foregoing Motion for
Extension of Time to File Responsive Pleading.

Citibank Tower Eastwood City
Bagumbayan, Quezon City
COPY FURNISHED:
Atty. Angelico Zenon M. Delos Reyes

Libis, Quezon City
EXPLANATION
The foregoing Motion for Extension of Time to File Responsive Pleading
has been served on Plaintiff’s counsel by registered mail due to lack of time and
personnel to effect personal delivery.

Plaintiff,

Defendant.
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MOTION FOR BILL OF PARTICULARS
Honorable Court, respectfully alleges:
1. That the plaintiff's complaint in its paragraphs 3 to 6 alleges:
“3. That the above-named spouse of Plaintiff is the erstwhile business partner
of the defendant from year 2007 to 2009;
4. That in the course of their business, the plaintiff’s spouse made financial
contributions through the request and assurances of the defendant that such amount will
be repaid. That however, after several months and upon inquiry, plaintiff’s spouse found
out that defendant misappropiated the financial investments made for his own personal
use. That despite demands, defendant failed to remit to and/or settle with the plaintiff’s
spouse the aggregate amount of Ninety Eight Thousand Seven Hundred Pesos
(P98,700.00);
5. That in recognition of defendant’s obligation in favor of plaintiff’s spouse,
the former executed an Acknowledgement of Debt in favor of the plaintiff on January 26,
2008, a photocopy of which is attached hereto as Annex “A”;

6. That by reason of the kindness and generosity of plaintiff’s spouse,
defendant’s obligation through the Acknowledgement was reduced to the sum of Sixty
Thousand Pesos (P60,000.00), and transferred in favor of the plaintiff as formalized n a
duly-notarized Loan Agreement entered by and between the plaintiff and the defendant
on January 29 2008, a photocopy of which is hereto attached as Annex “B”;”
2. That said allegations are insufficient and defective in that it fails to specify
the genuineness and authenticity of documents and the exact circumstances
which actually prevailed;
3. That a more definite statement on the matter as above indicated is
necessary in order to enable the defendant to properly prepare his responsive
pleading.
WHEREFORE, it is respectfully prayed that an Order be issued by this
Honorable court requiring the Plaintiff to make more definite and certain his
complaint in the particulars above indicated.
Quezon City, __________________

NOTICE OF HEARING

Libis, Quezon City
Greetings:

Bill of Particulars.

COPY FURNISHED:

Libis, Quezon City
EXPLANATION
The foregoing Motion for Bill of Particulars has been served on the
Plaintiff’s counsel by registered mail due to lack of time and personnel to effect
personal delivery.

Plaintiff,

Defendant.
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SECOND MOTION FOR EXTENSION OF TIME
TO FILE RESPONSIVE PLEADING
1. That the extended deadline for the filing of the Defendant’s Answer is
already tomorrow ________________ which was granted by this Honorable
Court as per Order dated ______________;
2. That the undersigned counsel was suddenly stricken by the dreadful and
painful sore-eyes infection last two days ago, Defendant need and respectfully
request another short extension in which to file his Answer to the Complaint;
3. Undersigned counsel hereby request a two-week extension, making their
Answer due on ___________________.

request another two-week extension from__________ to _________ in which to
file their Answer to the Complaint.
Quezon City, __________________

NOTICE OF HEARING

Libis, Quezon City
Greetings:

of the Regional Trial Court of Quezon City to approve the foregoing Second
Motion for Extension of Time to File Responsive Pleading.

COPY FURNISHED:

Libis, Quezon City
EXPLANATION
The foregoing Second Motion for Extension of Time to File Responsive
Pleading has been served on Plaintiff’s counsel by registered mail due to lack of
time and personnel to effect personal delivery.

Plaintiff,

Defendant.
X - - - - - - - - - - - - - - - - - - - - - - - - - - -X
FINAL MOTION FOR EXTENSION OF TIME
TO FILE RESPONSIVE PLEADING
1. That the second extended deadline for the filing of the Defendant’s
Answer is already tomorrow ________________ which was granted by this
Honorable Court as per Order dated ______________;
2. That the undersigned counsel, not yet fully recovered from the dreadful
sore-eyes, conducted an initial interview with the Defendant for the preparation
of his Answer but yesterday, when the draft pleading will be shown for
comments, Defendant failed to arrive at undersigned’s office because the latter
contracted also the same disease;

3. Undersigned counsel hereby requests a short two-week extension, making
their Answer due on ___________________;
4. That this final request for extension of the hearing is not for the purpose
of delaying the disposition of the case.
request another two-week extension from__________ to _________ in which to
file their Answer to the Complaint.
Quezon City, __________________

NOTICE OF HEARING

Libis, Quezon City
Greetings:

of the Regional Trial Court of Quezon City to approve the foregoing Final
Motion for Extension of Time to File Responsive Pleading.

COPY FURNISHED:

Libis, Quezon City
EXPLANATION
The foregoing Final Motion for Extension of Time to File Responsive
Pleading has been served on Plaintiff’s counsel by registered mail due to lack of
time and personnel to effect personal delivery.

Plaintiff,

Defendant.
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MOTION TO DECLARE DEFENDANT IN DEFAULT
PLAINTIFF, thru the undersigned Counsel, unto this Honorable Court,
respectfully alleges:
1. Defendant was served Summons together with a copy of the Complaint
and annexes thereto in the above-entitled case at his address # 15 Bohol St.,
Barangay Horseshoe, Quezon City, where he was residing;
2. Mr. Steven R. Lucas served the Summons on ___________ per Sheriff's
Return of same date attached herewith as Annex “A”;
3. Under Sec. 1 Rule 11 of the Revised Rules of Court of the Philippines,
the defendant has fifteen (15) days after service of Summons to file his answer to
the complaint. More than fifteen (15) days has lapsed since Summons was
served upon the defendant and up this date, defendant has not filed his answer
or any responsive pleading for that matter;
4. Notwithstanding the fact that the defendant requested and filed three
Motions for extensions of time, still, they failed to file an Answer on the deadline
approved by this Honorable Court as per Order dated ______________ attached
herewith as Annex “B”.
IN VIEW of the failure of the defendant to file his answer or any
responsive pleading, plaintiff respectfully prays to the Honorable Court to
declare the defendant in default pursuant to Sec. 3 Rule 9 of the Rules of Court.
Other reliefs just and equitable under the premises are likewise prayed
for.
Quezon City, ______________________

NOTICE OF HEARING
To: Atty. Louise Marie S. Perez

Counsel for the Defendant
Greetings:

of the Regional Trial Court of Quezon City to approve the foregoing Motion to
Declare Defendant in Default.
ATTY. ANGELICO ZENON M. DELOS REYES
Counsel for Plaintiff
Libis, Quezon City
COPY FURNISHED:
Atty. Atty. Louise Marie S. Perez

EXPLANATION
The foregoing Motion to Declare Defendant in Default has been served on
Defendant’s counsel by registered mail due to lack of time and personnel to
effect personal delivery.

Plaintiff,

Defendant.
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MOTION TO LIFT ORDER OF DEFAULT
COMES NOW the defendant, EDGARDO S. SANTOS thru the
undersigned counsel and unto this Honorable Court, respectfully avers:
1. That defendant and undersigned counsel was not able to timely file an
answer for the reason that both suffered a very infectious disease of sore-eyes
from _____________ upto _______________;
2. That undersigned counsel, despite the pain and misery managed to
prepare and draft the Answer but defendant himself suffered worst and was
even confined for three days. A doctor’s certificate, to attest the truthfulness of
this unfortunate event is hereby attached as Annex “A”;

3. That defendant’s Answer will be filed tomorrow already;
4. That both the defendant and the undersigned counsel is committed to
the speedy disposition of this case.
WHEREFORE, it is respectfully prayed that the order declaring the
defendant in default be lifted and that this Honorable Court allow the defendant
to file an answer to the plaintiff’s complaint.
Quezon City,_____________

NOTICE OF HEARING

Libis, Quezon City
Greetings:

of the Regional Trial Court of Quezon City to approve the foregoing Motion to
Lift Order of Default.

COPY FURNISHED:

Libis, Quezon City
EXPLANATION
The foregoing Motion to Lift Order of Default has been served on
Plaintiff’s counsel by registered mail due to lack of time and personnel to effect
personal delivery.

Plaintiff,

Defendant.
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ANSWER
COMES NOW the defendant EDGARDO S. SANTOS thru the
undersigned counsel, respectfully alleges:
1. That he specifically denies under oath the genuineness and due
execution of the alleged Acknowledgement of Debt (Annex A) and Loan
Agreement (Annex B) attached to the plaintiff’s complaint;
2. That the said two documents were fraudulently executed by the
plaintiff NAPOLEON C. GATMAITAN, the defendant EDGARDO S. SANTOS

not having executed any such promissory note in favor of the former, thus, the
said promissory note is null and void.
WHEREFORE, it is respectfully prayed that the plaintiff’s complaint be
dismissed with costs against the plaintiff. The defendant further prays for such
other relief as the Honorable Court may deem just and equitable.
Quezon City,_____________

COPY FURNISHED:

Libis, Quezon City
VERIFICATION
I, EDGARDO S. SANTOS, of legal age, Filipino and with address at # 15
Bohol St., Barangay Horseshoe, Quezon City, having been duly sworn to in
accordance with law hereby depose and say:
1. That I am the Defendant in the above-entitled case; that I have caused
the preparation of the foregoing Answer Pleading; that all the allegations stated
therein are true and correct of my own knowledge and supported by authentic
documents;
2. That I have not commenced any other action or proceeding involving
the same issues is the Supreme Court, the Court of Appeals, or any other tribunal
or agency; that to the best of my knowledge, no such action or proceeding is
pending in the Supreme Court, the Court of Appeals, or any other tribunal or
agency; that there is no other action or proceeding which is either pending or
may have been terminated, and if I should thereafter learn that a similar action or
proceeding has been filed or is pending before the Supreme Court, the Court of
Appeals, or any tribunal or agency, I undertake to report that fact within five (5)
days there from to this Honorable Court.
EDGARDO S. SANTOS
Affiant
SUBSCRIBED AND SWORN to before me this ____ day of _______ at

Quezon City affiant exhibiting to me her Community Tax Certificate No.
__________ issued in ___________ on ____________
NOTARY PUBLIC
Doc. No.________;
Page No.________;
Book No.________;
Series of ________;
Plaintiff,

Defendant.
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MANIFESTATION AND MOTION TO WITHDRAW AS COUNSEL WITH
SUBSTITUTION OF COUNSEL
The Clerk of Court
Regional Trial Court of Quezon City
Branch _________
COMES NOW Atty. Louise Marie S. Perez, counsel of record for the
Defendant and unto this Honorable Court respectfully moves to withdraw as
counsel for Defendant with the express consent of the defendant as shown in this
motion.
That in substitution thereof, Atty. Corazon Alma T. Soliman whose
services have been retained by Defendant, hereby enters her appearance as
counsel for the Defendant.
That upon the approval of this Honorable Court, all pleadings, notices and
papers in connection with the above entitled case be addressed to the new
counsel, Atty. Corazon Alma T. Soliman, with address at 13th floor, Will Tower
Mother Ignacia St., Barangay South Triangle, Quezon City.
Quzon City, _________________

Former Counsel for Defendant
ATTY. CORAZON ALMA T. SOLIMAN

13th floor, Will Tower
Mother Ignacia St.,
Barangay South Triangle, Quezon City
WITH DEFENDANT’S CONSENT
EDGARDO S. SANTOS
NOTICE OF HEARING

Libis, Quezon City
Greetings:
of the Regional Trial Court of Quezon City to approve the foregoing
Manifestation and Motion to Withdraw as Counsel with Substitution of Counsel.

COPY FURNISHED:

Libis, Quezon City
EXPLANATION
The foregoing Manifestation and Motion to Withdraw as Counsel with
Substitution of Counsel has been served on Plaintiff’s counsel by registered mail
due to lack of time and personnel to effect personal delivery.

Plaintiff,

Defendant.
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MOTION FOR EXECUTION OF JUDGMENT
COMES NOW the Plaintiff, by the undersigned counsel, and unto this
Honorable Court, respectfully moves for the execution of judgment under the
following premise:
1. That a decision has been rendered in this case on August 1, 2011, in favor of
the Plaintiff and against the Defendant;
2. That the period for appeal has already expired without the Defendant
having perfected an appeal from said decision;

3. That said decision is now final and executory.
WHEREFORE, it is respectfully prayed that an Order be issued for the
execution of the above judgment.
Quezon City, ___________________.

NOTICE OF HEARING
TO: ATTY. CORAZON ALMA T. SOLIMAN

Mother Ignacia St.,
Greetings:

Execution of Judgment.

Libis, Quezon City
COPY FURNISHED:
ATTY. CORAZON ALMA T. SOLIMAN

Consel for the Defendant
Mother Ignacia St.,
EXPLANATION
The foregoing Motion for Execution of Judgment has been served on
Defendant’s counsel by registered mail due to lack of time and personnel to
effect personal delivery.

Republic of The Philippines Metropolitan Trial Court National Capital Judicial Region Branch - , Quezon City

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Republic of the Philippines

METROPOLITAN TRIAL COURT

-versus- CIVIL CASE NO. _____

PLAINTIFF, thru the undersigned Counsel, unto this Honorable Court,

1. That Plaintiff is of legal age, Filipino, married to Nancy A.

Gatmaitan, and with residence at # 11 Bohol St., Barangay Horseshoe, Quezon

2. That Defendant is likewise of legal age, Filipino, married and with

residence at # 15 Bohol St., Barangay Horseshoe, Quezon City, where he could be

served with summons and other processes of the Court;

3. That the above-named spouse of Plaintiff is the erstwhile business

partner of the defendant from year 2007 to 2009;

4. That in the course of their business, the plaintiff’s spouse made

Ninety Eight Thousand Seven Hundred Pesos (P98,700.00);

5. That in recognition of defendant’s obligation in favor of plaintiff’s

spouse, the former executed an Acknowledgement of Debt in favor of the

plaintiff on January 26, 2008, a photocopy of which is attached hereto as Annex

6. That by reason of the kindness and generosity of plaintiff’s spouse,

defendant’s obligation through the Acknowledgement was reduced to the sum

of Sixty Thousand Pesos (P60,000.00), and transferred in favor of the plaintiff as

formalized n a duly-notarized Loan Agreement entered by and between the

plaintiff and the defendant on January 29 2008, a photocopy of which is hereto

attached as Annex “B”;

7. That part of said Loan Agreement is the obligation of the

defendant-debtor to pay the plaintiff-creditor the amount of Two Thousand Five

including interest, set at two percent (2%) per month;

8. That after paying Two Thousand Five Hundred Pesos (P2,500.00) in

9. That plaintiff-creditor sent separate letters (dated April 7, 2008 and

his outstanding payable, photocopies of which are hereto attached as Annexes

“C” and “C-1”;

prompted the plaintiff-creditor to lodge a complaint with the barangay officials

of Barangay Horseshoe, Quezon City. A Certificate to File Action, copy of which

parties to come to an Agreement.

defendant-debtor for the payment of his outstanding payable up to July 2008,

which however, was left unheeded, a photocopy of which is hereto attached as

wife Mrs. Veronica A. Santos on June 3, 2008, as shown by a Certification dated

hereto attached as Annex “F”;

13. That defendant-creditor has, as of this date, defaulted in the

payment of an aggregate amount of Twenty-six Thousand Pesos (P26,000.00);

14. That notwithstanding plaintiff-creditor’s repeated oral and written

but to litigate and file this acton.

15. That by reason of defendant’s unjustified acts as well as bad faith

award of moral damages in the amount of P5,000.00;

16. That by reason of defendant’s violation and disregard of Plaintiff’s

rights, the award of exemplary damages in the amount of P5,000.00 is likewise

warrant to serve as a deterrent to the commission by the defendant and to others

similarly-minded of similar acts in the future.

WHEREFORE, PREMISES CONSIDERED, it is most respectfully prayed

the defendant ordering the latter to pay the plaintiff as follows:

1. The amount of TWENTY SIX THOUSAND PESOS representing the

2. The amount of P5,000.00 as and by way of moral damages;

3. The amount of P5,000.00 as and by way of exemplary damages;

Atty. ANGELICO ZENON M. DELOS REYES

I, NAPOLEON C. GATMAITAN, Filipino, of legal age with address at #11

1. That I am the plaintiff in the above-entitled case;

2. That I caused the preparation of the foregoing Complaint and I have

WITNESS WHEREOF, I hereunto set my hand this _______ day of

SUBSCRIBED AND SWORN TO before me this ______ day of ______,

-versus- CIVIL CASE NO. _____

MOTION FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADING

Honorable Court, respectfully moves:

1. The Complaint in this matter was served on Edgardo S. Santos on

_______________________, making his Answer due on ____________________;

2. Due to the scheduling logistics of undersigned counsel, Defendant need

SUBSCRIBED AND SWORN TO before me this day of ,

___, making his Answer due on ;

request a two-week extension from__ to _ in which to file their

request another two-week extension from__ to _ in which to

request another two-week extension from__ to _ in which to