REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURTBRANCH _____,
MAKATI CITY

IN THE MATTER OF:

PETITION FOR REHABILITATION
WITH PRAYER FOR STAYING ALL
CLAIMS, ACTIONS AND PROCEEDINGS
AGAINST ABC INC.
SP Case No. ______

DEF BANK, Petitioner.

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PETITION

Petitioner DEF Bank (“Petitioner DEF Bank”), through undersigned counsel, most respectfully
submits this Petition to this Honorable Court pursuant to Republic Act No. 8799, also known as“The
Securities Regulation Code” (SRC), and the “Rules of Procedure on Corporate Rehabilitation of
Procedure on Corporate Rehabilitation”(A.M. No. 00-8-10-SC) dated 21November 2000 (the “Rules of
Procedure on Corporate Rehabilitation”)for ABC Inc. (“DEBTOR”) to be placed under corporate
rehabilitation.

1. Petitioner DEF Bank is a corporation duly organized andexisting under and by virtue of the laws of the
Republic of thePhilippines. Petitioner DEF Bank may be served with subpoena, orders,and other
processes of this Honorable Court at undersigned counsel’saddress as indicated below.

2.Petitioner DEF Bank is a creditor of ABC, Inc. [“DEBTOR”] fort h e a m o u n t o f One

Billion (PhP1,000,000,000.00)a s o f 1 8 September 2008. This is secured by a
Committ ed Revolving Credit

Facility Agreement (the “Agreement”), which was executed by its parent company, _____________.
(“XYZ”), on 30 August 2007, as anabsolute and unconditional guarantee in favor of Petitioner DEF Bank.
Petitioner DEF Bank’s Statement of Account evidencing theabove indebtedness is hereto attached and
marked as Annex“A”to form an integral part hereof.

3.Based on DEBTOR’s Audited Financial Statements as of 30November 2007, its total liabilities amount
to Two Billion SevenHundred Thirty Four Million Five Hundred Seventy Four Thousand FourHundred
Sixty Five Pesos (PhP2,734,574,465.00). Thus, DEBTOR’stotal outstanding obligation to Petitioner DEF
Bank of One BillionEight Hundred Fifty Nine Million One Hundred Forty SevenThousand Three Hundred
Twenty Three Pesos and Nine SevenCentavos (PhP1,859,147,323.97)as of 18 September 2008 is
morethan twenty-five percent (25%) of DEBTOR’s total liabilities.A copy of DEBTOR’s Audited Financial
Statements as of 30November 2007 is hereto attached and marked as Annex “B”toform an integral part
hereof. 4.DEBTOR’s Audited Financial Statement further shows thatit reported operating losses in
almost all financial performance indicesin 2007. In the same year alone it reported a resulting net
lossamounting to Two Hundred Million Two Hundred Sixty One ThousandThree Hundred Forty Pesos
(PhP200,261,340.00).
5. Other Averments
6. Other Averments

Very truly yours,

________________________
Signature of Petitioner

SUBSCRIBED AND SWORN TO before me this_____________________ day of ___________________ at

_________________________________________.

NOTARY PUBLIC