COMPLAINT

b. Plaintiff ZHAYK CORPORATION, by counsel, respectfully states:

1.  An assertion made without proof.

2.  An assertion that someone has done something wrong, often without proof.

3.  An allegation is defined as an accusation made by a person or a group of people in a

legal setting, which then needs to be proven through an investigation.

PRAYER

e. WHEREFORE, plaintiff ZHAYK CORPORATION respectfully prays that the Honorable

Court 

All other just and equitable reliefs are also prayed for.

e. Quezon City for Marikina City, 5 November 2021.

ATTY. CELLONA ALBERT JOHN

Counsel for Plaintiff ZHAYK CORPORATION

44D San Ponciano San Antonio Homes Culiat QC and #09123456789

Roll of Attorney No. 35599

PTR No. M L A 21 June 2021

MCLE Compliance No. 16-4972 21 June 2021

 REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT

MARIKINA CITY, BRANCH 85

ZHAYK CORPORATION,

                                            Plaintiff,

                                                              Civil Case No. R-QZN-19-1290

                            -Versus-                      For: Specific Performance

MAN CORPORATION,

                                            Defendant,

x-------------------------------------------------x

REPUBLIC OF THE PHILIPPINES)

(CITY/MUNICIPALITY                    ) S.S.                                 

JUDICIAL AFFIDAVIT

I, JOSE MIGUEL AGDEPPA, of legal age, SINGLE / FILIPINO, residing at SEVILLA ST.

BRGY 121 TONDO MANILA, employed as Marketing Manager at ZHAYK
CORPORATION, 44D SAN PONCIANO SAN ANTONIO HOMES CULIAT QC after having
been duly sworn to in accordance with law and fully conscious that I do so under oath and
that I may face criminal liability for false testimony or perjury in way of answers to the
questions propounded to me during the examination conducted on June 12, 2021 by TIM
JAVELOSA, with office address Red Arrow St, Marikina City, do hereby depose and state:

Q1: Please state your name and other personal circumstances.

A:   I am Jose Miguel Agdeppa 21 years old, Filipino, single and a resident of Red Arrow st,
Marikina City.

Q2: Why are you here in court today, Mr. Agdeppa?

A:  To give my testimony on the relationship of the accused and the victim and to also give
my testimony of what I heard from the accused.     

Q3: How are you related to the victim and the accused?          

A:  I am the Marketing Manager of ZHAYK CORPORATION, the agency of both the accused
and the victim. Both the accused and the victim are under my care.           

NO FURTHER QUESTIONS AT THIS TIME.

IN WITNESS WHEREOF, I have hereunto signed this instrument this  11th day of June,
2021 at Red Arrow Marikina City.

Gordon Ransey

Affiant

JURAT FOR THE WITNESS

  

ATTESTATION AND OFFER

  

I, Gordon Ransey, of legal age, with office address Malanday Marikina City, do hereby
certify that:

I propounded questions to  Jose Miguel Agdeppa and faithfully recorded or caused to be

recorded the questions I asked and the corresponding answers that Tim Javelosa gave, as
above stated.

 
Neither I nor any other person then present or assisting him coached him
regarding her answers and which testimony is being offered to prove Both the accused and
the victim are under my care.

IN WITNESS WHEREOF, I have hereunto signed this instrument this 11th day of June,
2021 at Red Arrow Marikina City.

Gordon Ransey

 
 MOTION FOR EXTENSION OF TIME

COMES NOW the Defendant by his undersigned counsel and to this Honourable Court
respectfully states that:

1.   Defendant engaged the services of undersigned counsel only on June 20, 2021

2.   Defendant was served with Summons and copy of the Complaint on June 13, 2021 and
thus has until June 20, 2021 within which to submit the Answer

3.  However, due to the pressured of equally urgent professional work and prior
commitments, the undersigned counsel will not be able to meet the said deadline [any other
meritorious reason for an extension];

4.   As such, the undersigned counsel is constrained to request for an additional period of 7
Days from June 20, 2021 or until June 27, 2021 within which to submit Defendant’s Answer.
Moreover, this additional time will also allow the undersigned to interview the available
witness and study this case further;

5.   This motion is not intended for delay but solely due to the foregoing reasons.

PRAYER

WHEREFORE, Defendant most respectfully prays of this Honorable Court that he be given
an additional period of 7 Days from June 20, 2021 or until June 27, 2021 within which to
submit the Defendant's Answer

Other just and equitable reliefs prayed for.

Malanday Marikina, June 11, 2021.

All other just and equitable reliefs are also prayed for.

Marikina City for the Quezon City, 11 June 2021

 

Signature

Nonito Donaire Jr. Attorney for Defendant 3F PNCH Bldg. Marikina City

PTR No. 6741/ Marikina City / June 11,2021

IBP No. 1234  / Marikina City / June 11, 2021

MCLE Compliance No. 8965

NOTICE OF HEARING

The undersigned will submit the foregoing Motion for Extension of Time for the
consideration and approval of the Honourable Court on June 20, 2021 at 10:45 AM

COPIES FURNISHED

Juan Miguel Attorney for Plaintiff 69 Ave, Justice Bldg. Marikina City

Marikina Metropolitan Trial Court - Clerk of Court Regional Trial Court of  Marikina

City Branch 85

EXPLANATION

This motion will be served on Plaintiff’s counsel by registered mail due to lack of time and
distance between his office and the office of the undersigned.
 MOTION TO DISMISS

COMES NOW the defendant by his undersigned counsel, and to this Honorable Court
respectfully moves that the complaint be dismissed on the following grounds:

[GROUNDS]

Discussion

[ARGUMENTS

PRAYER

WHEREFORE, it is respectfully prayed that the complaint be dismissed.

Marikina City, June 11, 2021.

Nonito Donaire Jr. Attorney for Defendant 3F PNCH Bldg. Marikina City

Roll No. 5234

PTR No. 6741 / Marikina City / June 11, 2021 IBP No. 1234  / Marikina City / June 11,

2021 MCLE Compliance No. 8965

NOTICE OF HEARING

The undersigned will submit the foregoing Motion to Dismiss for the consideration and
approval of the Honorable Court on June 20, 2021 at 10:45 AM.

COPIES FURNISHED
 

Juan Miguel Attorney for Plaintiff 69 Ave, Justice Bldg. Marikina City

Marikina Metropolitan Trial Court - Clerk of Court Regional Trial Court of  Marikina
City Branch 85

EXPLANATION

This motion will be served on Plaintiff’s counsel by registered mail due to lack of time and
distance between his office and the office of the undersigned.
 REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT

MARIKINA CITY, BRANCH 85

XYZ CORPORATION,

                                            Plaintiff,

                                                              Civil Case No. R-QZN-19-1290

                            -versus-                      For: Specific Performance

MAN CORPORATION,

                                            Defendant,

x-------------------------------------------------x

MOTION TO DECLARE DEFENDANT IN DEFAULT

COMES NOW the Plaintiff by his undersigned counsel and to this Honourable Court
respectfully moves that the Defendant be declared in default. Plaintiff respectfully states
that:

1.   The records of the Honourable Court show that the Defendant was served with copy

of the summons and of the complaint, together with annexes thereto on June 27, 2021;

2.   Upon verification however, the records show that Defendant Joselito Matanglawin has
failed to file his Answer within the reglementary period specified by the Rules of Court
despite the service of the summons and the complaint;

 
 PRAYER

WHEREFORE, it is respectfully prayed that the Defendant Joselito Matanglawin be declared

in default pursuant to the Rules of Court and that the Honourable Court proceed to render
judgment as the complaint may warrant.

Other just and equitable reliefs prayed for.

Marikina City, June 11, 2021.

Juan Miguel Attorney for Plaintiff 69 Ave, Justice Bldg. Marikina City

Roll No. 5234

PTR No. 6741 / Marikina City / June 11, 2021 IBP No. 1234  / Marikina City / June 11,

2021 MCLE Compliance No. 8965

NOTICE OF HEARING

The undersigned will submit the foregoing Motion to Declare in Default for the consideration
and approval of the Honourable Court on June 27, 2021 at 10:45 AM.

COPIES FURNISHED

Nonito Donaire Jr.

Attorney for Defendant

3F PNCH Bldg. Marikina City

Marikina Metropolitan Trial Court - Clerk of Court Regional Trial Court of  Marikina
City Branch 85

EXPLANATION

This motion will be served on Defendant’s counsel by registered mail due to lack of time
and distance between his office and the office of the undersigned.