REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 158, PASIG CITY

IN THE MATTER OF THE PETITION

FOR DECLARATION OF INSOLVENSY

SP. CASE NO. 09987

BLUSH SKIN CARE STUDIO CORP.,

Petitioner,

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

PETITION

PETITIONER by counsel, to this Honorable Court, respectfully states, that:

1. Petitioner is a domestic corporation duly organized and existing under Philippine laws,
with principal office at #2 Bouganville Subd., Mapa Subdivision, Sta. Lucia, Pasig City. It
may be served with court processes and orders of this Honorable Court, and pleadings
through its counsel, Jun P. Alcazar.

2. Petitioner is filing this petition under Section 12 of Republic Act No. 10142, otherwise
known as the “Financial Rehabilitation and Insolvency Act (FRIA) of 2010, to declare it
Insolvent considering that it has no sufficient assets, cash or property, to pay its
outstanding obligations now or hereafter.

3. That due to continued losses it has incurred starting January 1, 2021 which resulted in
its operation at a loss; thus, it was not able to pay its obligations as they fall due; the
salaries of its employees were not paid on time, and its tax liabilities remain unpaid;
petitioner was constrained to cease and totally stopped and closed its operations as of
June 30, 2022. Photocopies of the Secretary’s Certificate on the total closure of
petitioner’s operation is attached as Annex “A”.

4. As of the filing of this Petition, petitioner is not aware of any pending action or
proceedings initiated by any person, private or government firm or agency, against it.
5. To its knowledge, petitioner’s existing obligation amounts to Fifteen Million Seven
Hundred Twenty Nine Thousand Pesos (Php15,729,000), listed in the Inventory of
Liabilities as Annex “B”.

6. Petitioner does not pray for a suspension of payment nor purpose any mode of payment
of its aforesaid liabilities because it has no means, property or asset or cash, or financial
capacity to pay or offer to pay the same because it has no asset, cash or property, or
financial capacity to offer payment;
 7. In compliance with the Rules, attached are the Audited Financial Statements for the
years 2021 and interim financial statement June 30, 2022 as Annexes “C”.

8. The petitioner prays for the issuance of a Stay Order against any and all claims, of
whatever nature and kind, that any person, private or government agency, firm,
corporation or entity may have against herein petitioner;

9. Considering that the petitioner had ceased and closed operation as early as July 1, 2022,
and that it has no assets for liquidation and distribution to its creditors, hence, the
appointment of a Liquidator is no longer necessary.

PRAYER

WHEREFORE, it is respectfully prayed of this Honorable Court, that:

1. Upon filing of this Petition:

a. Consider this Petition for Declaration of Voluntary Insolvency;

b. Issue a Stay Order under such terms under RA 10142 (FRIA) Law of 2010 restraining
all claims or demands of whatever nature of character against the petitioner;
c. Upon due completion of notice to its creditors and publication of this petition, set
creditor’s conference or initial hearing;
2. After appropriate proceedings:
a. Issue an Order declaring petitioner an insolvent debtor;

Other reliefs just and equitable are likewise prayed for.

Blush Skin Care Studio Corp, (September 25, 2022)

Jun P. Alcazar
Counsel for the Plaintiff

VERIFICATION AND CERTIFICATION

AGAINST FORUM SHOPPING

I, Juliana Santos, Petitioner in the above-captioned case, married, of legal age, Filipino,
after having been sworn, in accordance with law, hereby depose and state that:

1. I am the Petitioner in the above-captioned case;

2. I have read and understood the contents hereof if this Petition for Review, and the facts
herein alleged are true and correct of my own knowledge and based on available verifiable
records.

3. I heretofore have not commenced any other action or proceeding or any claim, or filed any
claim involving the same issues raised in the above-captioned case, in this Honorable Supreme
Court, in the Court of Appeals, nor the different Divisions thereof, nor in any other court or
tribunal or agency and, to the best of my knowledge, no such other action or claim is pending
therein;

4. I hereby undertake to notify this Honorable Court of such fact within five (5) days from
receipt of such knowledge, should I come to learn that the same or a similar action or claim has
been filed or pending in the Supreme Court, Court of Appeals, the different Divisions thereof,
or any other court or tribunal or agency;

5. I am executing this sworn statement in compliane with Section 5, Rule 7 of the 1997 Rules of
Court.

Juliana Santos
Affiant

SUBSCRIBED AND SWORN TO before me this 23rd day of September 2022 at, Pasig City,
Philippines, affiant exhibiting to me her SSS ID with ID no. 12817976 issued by the Social
Security System, as competent evidence of here identity, and she personally acknowledged to
me that the foregoing “Petition” is for her free and voluntary act and deed. Machine copy of
this SSS ID is hereto attached.

Atty. Davin Catalan

Notary Public
PTR No. 1234567, Pasig City, 1/15/2022
IBP Roll No. 654321, Pasig City, 1/18, 1985
MCLE Compliace Certificate No. IV-0012861, Pasig City, 2/15/2021
San Vincent Building, 2250 Ave., Ortigas Ext., Rosario, Pasig City