REPUBLIC OF THE PHILIPPINES November 9, 2016, the date when plaintiff discovered the defendant’s possession over

MUNICIPAL TRIAL COURT his property. In accordance with Art. 1147 of the civil code, the action should have been
Fourth Judicial Region filed within one (1) year from November 9, 2016.
BRANCH 17
Imus City PRAYER
WHEREFORE, in view of the foregoing, defendant respectfully prays that
BOBBY S. PEREZ, plaintiff’s complaint be dismissed, with costs against the plaintiff.
Plaintiff,
------versus------- Case No. 17-071369 Other relief, just and equitable are also prayed for.
JAY P. SANTOS, For: Forcible Entry Imus City, Cavite, Philippines, February 27, 2018.
Defendant
x-----------------------x By:
Atty. VINCENT D. DANGANAN
MOTION TO DISMISS Counsel for the Defendant
NOW COMES Defendant, by his undersigned attorney, respectfully moves this Roll of Attorney’s No.: 461201
Honorable Court to dismiss the plaintiff’s complaint on the ground of: IBP No. 3669132/9 June 2016/Las Pinas
1. Plaintiff’s cause of action is barred by the statute of limitations. PTR No. 03123619/29 June 2016/Las Pinas
MCLE Requirement Compliance No. 9108023/9 December 2017
ARGUMENTS
PLAINTIFF’S CAUSE OF ACTION IS BARRED BY THE STATUTE OF
LIMITATIONS NOTICE OF HEARING
ATTY. ANGELICA R. PULIDO
Article 1147 of the New Civil Code of the Philippines provides that actions for Counsel for Plaintiff
forcible entry must be filed within one (1) year from the time cause of action arises, 3853-A Bermeo St. Palanan,
unless it will be barred by prescription. In cases of forcible entry, cause of action arises Makati City
once the plaintiff learns that another person entered and occupied his land or building by
force, intimidation, threat, strategy, or stealth without plaintiff’s consent thereby Greetings!
depriving him of his possession of his property. Also, cause of action arises from the very Please take notice that on Friday, May 17, 2018, at 2pm or as soons as
moment the defendant enters and occupies plaintiff’s property depriving latter’s thereafter as counsel may be heard, the undersigned will ask this Honorable Court to
possession over such party. approve the foregoing Motion to Dismiss.

The plaintiff owns a certain parcel of land located in Aguinaldo St., Medicion, ATTY. VINCENT D. DANGANAN
Imus City, Cavite. Sometime on August 9, 2016, the defendant entered the property of the
former by stealth and build a small house thereon without plaintiff’s consent or EXPLANATION AS TO SERVICE
knowledge. The defendant continued to occupy the said land. On November 9, 2016,
plaintiff discovered that the defendant is illegally occupying his property. Thus, upon Copy of this motion to dismiss was served the counsel for plaintiff thru
discovering such fact, plaintiff immediately went to his property being occupied by the registered mail. Personal service cannot be effected due to lack of manpower, as well as
defendant and demanded the latter to vacate the property. However, despite several distance and time constraints.
demands, defendant refused to vacate such property.
Atty. VINCENT D. DANGANAN
Due to defendant’s persistent refusal to vacate, the plaintiff filed an action for COPY FURNISHED:
forcible entry against the defendant on February 12, 2018. Defendant in this case, ATTY. ANGELICA R. PULIDO
contends that the action for forcible entry had already prescribe since the plaintiff filed Counsel for Plaintiff
an action more than one (1) year from the time the cause of action arose which is on 3853-A Bermeo St. Palanan, Makati City
 REPUBLIC OF THE PHILIPPINES Makati City
REGIONAL TRIAL COURT
National Capital Judicial Region Greetings!
Branch 16 Please take notice that on Friday, May 17, 2018, at 2pm or as soons as thereafter as
Makati City counsel may be heard, the undersigned will ask this Honorable Court to approve the foregoing
Motion for intervention.
JAYSON S. RETONEL,
Plaintiff, ATTY. VINCENT D. DANGANAN
---------versus--------- Civil case No. : 12-789012
SPOUSES MARK AND JENNIFER DIMAANO, For: Recovery of damages EXPLANATION AS TO SERVICE
Defendants, and attorney’s fees.
x-------------------------------------------------------x Copy of this motion for intervention was served the counsel for plaintiff and defendant
thru personal service.
MOTION FOR INTERVENTION
Atty. VINCENT D. DANGANAN
COMES NOW the Intervenor, LUKE R. ESTANO, by the undersigned counsel, and unto this
Honorable Court, most respectfully requests for leave to intervene in the above-captioned COPY FURNISHED:
case, for the following reasons: ATTY. ANGELICA R. PULIDO ATTY. FE GAMBOA
Counsel for Plaintiff Counsel for Defendant
1. That the Intervenor has legal interest in the matter in the litigation, or in the success of 3853-A Bermeo St. Palanan, Makati City 11 Durango Palanan, Makati City
either of the parties, or an interest against both, or that he is so situated as to be
adversely affected by a distribution or other disposition of the property which is the
VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING
subject of the controversy;
2. That this intervention will not, in the least, unduly delay or prejudice the
REPUBLIC OF THE PHILIPPINES)
adjudication of the rights of the original parties in the case; and
CITY OF MAKATI ) S.S.
3. That the Intervenor's rights can be fully protected in this proceeding rather than by
filing a separate proceeding.
I, LUKE R. ESTANO, Filipino, of legal age, residing at 1969 Abbey Road, Brgy. Karuhatan, Makati City,
after being sworn to in accordance with law, deposes and says that:
WHEREFORE, it is most respectfully prayed that the said LUKE R. ESTANO be
allowed to intervene in this action by filing a Complaint in Intervention, a copy of which is 1. I am the Petitioner in the above-entitled petitioner;
attached to this motion. 2. The facts stated in the above complaint are true and correct to the best of my knowledge
and authentic records;
Makati City, Philippines, October 17, 2018. 3. I have not commenced any action or filed any claim involving the same issues in any
court, tribunal or quasi-judicial agency and, to the best of my knowledge, no such other
By: action or claim is pending in them; and
Atty. VINCENT D. DANGANAN 4. If I should learn that the same or similar action or claim has been filed or is pending after
Attorney for Intervenor its filing, I shall report that fact within five (5) days from notice to the court or where the
Roll of Attorney’s No.: 461201 complaint or initiatory pleading has been filed.
IBP No. 3669132/9 June 2016/Las Pinas
October 18, 2018, Makati City, Philippines.
PTR No. 03123619/29 June 2016/Las Pinas
LUKE R. ESTANO
MCLE Requirement Compliance No. 9108023/9 December 2017 Affiant

SUBSCRIBED AND SWORN TO before me this 26 th day of July 2020 in Valenzuela City,
NOTICE OF HEARING Philippines, affiant exhibiting to me his competent evidence of identity by way of Passport with
ATTY. ANGELICA R. PULIDO number XX0739639, issued at Manila, Philippines on March 14, 2014.
Counsel for Plaintiff
NOTARY PUBLIC
3853-A Bermeo st. Palanan.
Commision Serial No.
Makati City Until Dec. 31, 2018
Doc. No. Roll of Attorneys No.
ATTY. FE GAMBOA Page No. IBP NO.
Counsel for Defendant Book No. PTR No.
11 Durango St. Palanan, Series of 2020.
 REPUBLIC OF THE PHILIPPINES NOTICE OF HEARING
REGIONAL TRIAL COURT ATTY. ANGELICA R. PULIDO
National Capital Judicial Region Counsel for Plaintiff
Branch 7 3853-A Bermeo St. Palanan,
Pasay City Makati City

FRANCHESKA DOMINGUEZ, Greetings!

Plaintiff, Please take notice that on Friday, Sept. 17, 2018, at 2pm or as soon as
---versus--- Civil Case No. 12-089901 thereafter as counsel may be heard, the undersigned will ask this Honorable Court to
MARY JERES PARRA, For: Damages approve the foregoing Motion for leave to effect summons by publication.
Defendant.
x--------------------------------------x ATTY. VINCENT D. DANGANAN

MOTION FOR LEAVE TO EFFECT SERVICE OF SUMMONS BY PUBLICATION EXPLANATION AS TO SERVICE

COMES NOW, the plaintiff, through the undersigned counsel and unto this Copy of this motion was served the counsel for plaintiff thru registered mail.
Honorable Court, most respectfully avers: Personal service cannot be effected due to lack of manpower, as well as distance and
time constraints.
1. That on August 25, 2018, copy of the summons was served by the process
server of this Honorable Court to the defendant on his given address, but Atty. VINCENT D. DANGANAN
defendant is no longer residing on his given address; COPY FURNISHED:
2. That considering that the whereabouts of the defendant is unknown and this ATTY. ANGELICA R. PULIDO
case affects the property of the defendant, plaintiff most respectfully move with Counsel for Plaintiff
leave of court to serve summons by publication. 3853-A Bermeo St. Palanan, Makati City

WHEREFORE, plaintiff prays that the summons be served by publication based

on the above reasons.

Such other relief and remedies as may be deemed just and equitable under the
premises are likewise prayed for.

City of Pasay, Philippines, August 29, 2018.

By:
Atty. VINCENT D. DANGANAN
Counsel for the Defendant
Roll of Attorney’s No.: 461201
IBP No. 3669132/9 June 2016/Las Pinas
PTR No. 03123619/29 June 2016/Las Pinas
MCLE Requirement Compliance No. 9108023/9 December 2017
 REPUBLIC OF THE PHILIPPINES Please take notice that on Friday, Sept. 17, 2018, at 2pm or as soon as
MUNICIPAL TRIAL COURT thereafter as counsel may be heard, the undersigned will ask this Honorable Court to
Fourth Judicial Region approve the foregoing Motion for leave to amend answer.
Branch 7
Kawit, Cavite ATTY. VINCENT D. DANGANAN

DEBBIE R. PULIDO EXPLANATION AS TO SERVICE

Plaintiff,
---versus--- Civil Case No. 12-089901 Copy of this motion was served the counsel for plaintiff thru registered mail.
KITKAT R. RETONEL For: Unlawful Detainer Personal service cannot be effected due to lack of manpower, as well as distance and
Defendant. time constraints.
x--------------------------------------x
Atty. VINCENT D. DANGANAN
MOTION FOR LEAVE TO AMEND ANSWER COPY FURNISHED:
ATTY. ANGELICA R. PULIDO
Defendant thru counsel, and unto this Honorable Court, respectfully moves this Counsel for Plaintiff
Court for leave to amend her answer, filed, dated April 24, 2018, and for this purpose 3853-A Bermeo St. Palanan, Makati City
hereby present the attached AMENDED ANSWER, wherein the amendments sought to be
incorporated are indicated by being underscored.

WHEREFORE, in order that the real matter in dispute and all matters in this
action may be completely determined, it is respectfully prayed that the attached
AMENDED ANSWER be admitted.

Kawit, Cavite, Philippines, May 7, 2018.

By:
Atty. VINCENT D. DANGANAN
Counsel for the Defendant
Roll of Attorney’s No.: 461201
IBP No. 3669132/9 June 2016/Las Pinas
PTR No. 03123619/29 June 2016/Las Pinas
MCLE Requirement Compliance No. 9108023/9 December 2017

NOTICE OF HEARING
ATTY. ANGELICA R. PULIDO
Counsel for Plaintiff
3853-A Bermeo St. Palanan,
Makati City

Greetings!
 REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT NOTICE OF HEARING
National Capital Judicial Region ATTY. ANGELICA R. PULIDO
Branch 7 Counsel for Plaintiff
Makati City 3853-A Bermeo St. Palanan,
Makati City
FRANCHESKA DOMINGUEZ,
Plaintiff, Greetings!
---versus--- Civil Case No. 12-089901 Please take notice that on Friday, Augus 17, 2018, at 2pm or as soon as
MARY JERES PARRA, For: Damages thereafter as counsel may be heard, the undersigned will ask this Honorable Court to
Defendant. approve the foregoing Motion for bill of particulars.
x--------------------------------------x
ATTY. VINCENT D. DANGANAN
MOTION FOR BILL OF PARTICULARS
EXPLANATION AS TO SERVICE
Defendant, thru undersigned counsel and unto this Honorable Court,
respectfully avers: Copy of this motion was served the counsel for plaintiff thru registered mail.
Personal service cannot be effected due to lack of manpower, as well as distance and
1. That the plaintiff’s complaint in paragraph 5 alleges: time constraints.
“From August 3 to December 2016, defendant never paid anything to herein
plaintiff. The check that he issued as a partial payment for the first month also Atty. VINCENT D. DANGANAN
bounced”; COPY FURNISHED:
2. That said allegation is not covered with sufficient definiteness and ATTY. ANGELICA R. PULIDO
particularity, specifically it does not mention the amount of the check therein Counsel for Plaintiff
mentioned, its check number, date and the drawee bank; and 3853-A Bermeo St. Palanan, Makati City
3. That a more definite statement on the matters as above-indicated is
necessary in order to enable the defendant to prepare its responsive pleading.

WHEREFORE, it is respectfully prayed that an order be issued by this

Honorable Court requiring the plaintiff to make a more definite and certain his complaint
in the particulars above mentioned.

Makati City, Philippines, August 9, 2018.

By:
Atty. VINCENT D. DANGANAN
Counsel for the Defendant
Roll of Attorney’s No.: 461201
IBP No. 3669132/9 June 2016/Las Pinas
PTR No. 03123619/29 June 2016/Las Pinas
MCLE Requirement Compliance No. 9108023/9 December 2017
 REPUBLIC OF THE PHILIPPINES
MUNICIPAL TRIAL COURT NOTICE OF HEARING
Fourth Judicial Region ATTY. ANGELICA R. PULIDO
Branch 7 Counsel for Defendant
Kawit, Cavite 3853-A Bermeo St. Palanan,
Makati City
CAMILLE BERNAL,
Plaintiff, Greetings!
---versus--- Civil Case No. 12-089901 Please take notice that on Friday, October 27, 2018, at 2pm or as soon as
BEEJAY VIDICION, For: Unlawful Detainer thereafter as counsel may be heard, the undersigned will ask this Honorable Court to
Defendant. approve the foregoing Motion for judgement on the pleadings.
x--------------------------------------x
ATTY. VINCENT D. DANGANAN
MOTION FOR JUDGEMENT ON THE PLEADINGS
EXPLANATION AS TO SERVICE
Plaintiff, thru the undersigned counsel, and unto this Honorable Court,
respectfully shows: Copy of this motion was served the counsel for plaintiff thru registered mail.
Personal service cannot be effected due to lack of manpower, as well as distance and
1. That the defendant, in his answer, admits the material allegations of the time constraints.
plaintiff’s complaint;
2. That said admission which fails to tender an issue, refers to the following Atty. VINCENT D. DANGANAN
matters: COPY FURNISHED:
“That the defendant, in his answer, admitted that the act complained ATTY. ANGELICA R. PULIDO
of by the plaintiff is true and that he failed to pay the rents and vacate Counsel for Defendant
the property despite the plaintiff’s final demand for him to pay the 3853-A Bermeo St. Palanan, Makati City
rents and vacate the property”;
3. That a judgement on the pleadings, in view of the above admission, may be
entered at this stage of the proceedings.

WHEREFORE, it is respectfully prayed that this Honorable Court direct

judgement on the pleadings pursuant to rule 34 of the Rule of Court.

Kawit, Cavite, Philippines, October 18, 2018.

By:
Atty. VINCENT D. DANGANAN
Counsel for the Plaintif
Roll of Attorney’s No.: 461201
IBP No. 3669132/9 June 2016/Las Pinas
PTR No. 03123619/29 June 2016/Las Pinas
MCLE Requirement Compliance No. 9108023/9 December 2017
 REPUBLIC OF THE PHILIPPINES
MUNICIPAL TRIAL COURT
Fourth Judicial Region NOTICE OF HEARING
Branch 7 ATTY. ANGELICA R. PULIDO
Bacoor City Counsel for Defendant
MAX DIMAANO, 3853-A Bermeo St. Palanan,
Plaintiff, Makati City
---versus--- Civil Case No. 12-089901
FE O. GAMBOA, For: Unlawful Detainer Greetings!
Defendant. Please take notice that on Friday, October 27, 2018, at 2pm or as soon as
x--------------------------------------x thereafter as counsel may be heard, the undersigned will ask this Honorable Court to
approve the foregoing Motion for New Trial
MOTION FOR NEW TRIAL
ATTY. VINCENT D. DANGANAN
Plaintiff in the above-entitled case by the undersigned attorney, and moves
unto this Honorable Court to set aside its judgement rendered therein, and to grant a EXPLANATION AS TO SERVICE
new trial on the following grounds:
Copy of this motion was served the counsel for plaintiff thru registered mail.
1. That a decision was rendered by this Honorable Court which plaintiff Personal service cannot be effected due to lack of manpower, as well as distance and
received on September 11, 2018, dismissing his complaint; time constraints.
2. That the plaintiff seeks a NEW TRIAL on the ground that the court’s decision
was not sufficiently supported by existence. The Court dismissed his complaint Atty. VINCENT D. DANGANAN
due to the lack of final demand made by him to the defendant for the latter to COPY FURNISHED:
pay the rents due and vacate the property, However, plaintiffs has given the ATTY. ANGELICA R. PULIDO
Court a copy of the final demand letter he sent to the defendant; and Counsel for Defendant
3. That plaintiff, in respect of this motion, attaches an Affidavit of Merit, marked 3853-A Bermeo St. Palanan, Makati City
as Annex “A” and made part of this motion.

WHEREFORE, it is respectfully prayed that the judgement rendered be set aside

and a new trial be granted.

Other relief just and equitable are also prayed for.

Bacoor City, Philippines, September 16, 2018.

By:
Atty. VINCENT D. DANGANAN
Counsel for the Plaintiff
Roll of Attorney’s No.: 461201
IBP No. 3669132/9 June 2016/Las Pinas
PTR No. 03123619/29 June 2016/Las Pinas
MCLE Requirement Compliance No. 9108023/9 December 2017
 REPUBLIC OF THE PHILIPPINES Please take notice that on Friday, November 5, 2018, at 2pm or as soon as
MUNICIPAL TRIAL COURT thereafter as counsel may be heard, the undersigned will ask this Honorable Court to
Fourth Judicial Region approve the foregoing Motion for Execution.
Branch 7
Imus City RONNA A. PALOMO
RONNA A. PALOMO
Plaintiff, EXPLANATION AS TO SERVICE
---versus--- Civil Case No. 12-089901
AHREEN BUENCONSEJO, For: Forcible Entry Copy of this motion was served the counsel for plaintiff thru registered mail.
Defendant. Personal service cannot be effected due to lack of manpower, as well as distance and
x--------------------------------------x time constraints.

MOTION FOR EXECUTION RONNA A. PALOMO

COPY FURNISHED:
Plaintiff, unto this Honorable Court, respectfully alleges that: AHREEN BUENCONSEJO
1. On October 7, 2018, a judgement was rendered by the Court, the dispositive Defendant
portion of which reads: 312 Aguinaldo St. Medicion,
WHEREFORE, in view of the foregoing consideration, this Court finds Imus City
in favor of the plaintiff entitled the prayer sought and hereby orders
defendant to vacate that house structure located at 312 Aguinaldo St.,
Medicion, Imus City and to pay plaintiff the sum of Php 10,000.00 as
damages suffered from her property and Php 5,000.00 as attorney’s
fees plus cost of suit;
2. The judgement is final and conclusive;
3. The defendant has not complied with the judgement.

WHEREFORE, premises considered, it is respectfully prayed that a writ of

execution be issued to implement the judgement of the Court date October 7, 2018.

Imus City, Philippines, October 29, 2018.

RONNA A. PALOMO
Plaintiff

NOTICE OF HEARING
AHREEN BUENCONSEJO
Defendant
312 Aguinaldo St. Medicion,
Imus City

Greetings!
REPUBLIC OF THE PHILIPPINES) REPUBLIC OF THE PHILIPPINES
CITY OF MANDALUYONG ) S.S. National Capital Judicial Region
Metropolitan Trial Court
Branch 6
COMPLAINT-AFFIDAVIT
Mandaluyong City

I, BRYAN ADAMS, of legal age, Filipino, and a resident of 69 Summer Lane, Brgy.
Addition Hills, Mandaluyong City, after having been sworn to in accordance with law PEOPLE OF THE PHILIPPINES,
hereby depose and state: Plaintiff,
-versus- Criminal Case No. 18-350127
1. That I am accusing JUSTIN BIEBER, a resident of 327 Samal St., JUSTIN BIEBER, For: Theft
Mandaluyong City of THEFT; Accused.
x-----------------------------------x
2. That on June 30, 2018, at my residence, we are having a thanksgiving
party for my cousin who passed the entrance test at Harvard University, in which JUSTIN INFORMATION
BIEBER (Justin) and I were present; The undersigned Prosecutor accuses JUSTIN BIEBER of the crime of theft, committed as
3. That on the same date, Justin asked me where the toilet was and I follows:
gave him directions to go there; That on or about June 30, 2018 in the city of Mandaluyong, Philippines, within the
4. That when I went to the toilet after Justin left, I realized that my jurisdiction of this court, the said accused did then and there willfully, unlawfully and feloniously,
iPhone X cellular phone worth SEVENTY THOUSAND PESOS (Php 70,000.00) which I left with intent to gain and without consent of the owner thereof, take, steal, and carry away the
at the toilet cabinet was missing; following personal property belonging to one, BRYAN ADAMS to wit: an iPhone X cellular phone, of
5. That in order to recover my phone, I asked Justin if he had my phone the total value of SEVENTY THOUSAND PESOS (Php 70,000.00), Philippine currency.
with him, but he said the phone was not with him; CONTRARY TO LAW.
6. That on the next day, we met at the waiting shed in Shaw Blvd., near
Jose Rizal University when I saw Justin holding an iPhone X cellular phone which is Manila, Philippines, July 17, 2018.
exactly similar with my missing phone;
7. That on that same day, I asked Justin to return the phone but he ATTY. EMI NEM
insisted that the said phone is his which he bought two weeks ago and he rarely used Assistant City Prosecutor
that; APPROVED:
8. That I referred the incident to the barangay for mediation proceedings
ATTY. PEPE SMITH
but Justin refused to obey the summons sent to him. Hence, I was advised by the City Prosecutor
barangay secretary who happens to be a lawyer to file a criminal action against Justin,
after I was issued a certificate to file action by the barangay; I HEREBY CERTIFY that I have conducted a preliminary investigation in this case in
9. In view of the foregoing, I am executing this Affidavit to support the accordance with law; I have, or as shown by the record, an authorized officer has personally
filing of a criminal case for theft against JUSTIN BIEBER. examined complainant and its witnesses; that on the basis of the sworn statements and other
evidence submitted before me there is reasonable ground to believe that the crime has been
IN WITNESS WHEREOF, I have hereunto set my hand this 16 th day of July 2018, committed and accused is probably guilty thereof; that accused was informed of the complaint and
in the city of Manila, Philippines. of the evidence submitted against him and was given the opportunity to submit controverting
evidence. I further certify that the filing of this Information is upon prior written authority or
approval of the City Prosecutor.

BRYAN ADAMS ATTY. LENIN KING F. TOLENTINO

Affiant Assistant City Prosecutor
SUBSCRIBED AND SWORN TO before me this 17th day of July 2018 at Manila.

SUBSCRIBED AND SWORN TO before me this 16 th day of July 2018 in ATTY. JHOROLAR N. ANDRES
Mandaluyong City, Philippines. I hereby certify that I have personally examined the Senior Assistant City Prosecutor
Witnesses:
affiant and I am satisfied that he fully understood and voluntarily executed his
1. Bryan Adams – 69 Summer Lane, Brgy. Addition Hills, Mandaluyong City.
complaint-affidavit. 2. Atty. John Legend – Barangay Secretary – Barangay Addition Hills, Mandaluyong City.
3. And others.

ATTY. EMI NEM BAIL RECOMMENDED: TWENTY-FIVE THOUSAND PESOS (Php 25,000.00)
Assistant City Prosecutor
Enclosure: Complaint-Affidavit of Bryan Adams
 Republic of the Philippines NOTICE OF HEARING
REGIONAL TRIAL COURT
Fourth Judicial Region PROVINCIAL PROSECUTION’S OFFICE
Branch 13 _____________________
Imus City
CLERK OF COURT
PEOPLE OF THE PHILIPPINES, Regional Trial Court
Plaintiff, Branch ___
---versus---- Criminal Case No. 12-99001 ___________________________
CARDO DALISAY, For: Violation of RA 9165
Accused. ” MA’AM/SIR:
Accused.
x-------------------------x Greetings!

PETITION FOR BAIL Please take notice that on ________________ at ___________ o’clock in the morning or
ACCUSED, through the undersigned counsel, unto this Honorable upon the approval of the Honorable Court the instant Petition shall be heard.
Court, respectfully states:
Thank you.
1. That accused is currently detained at the Bureau of Jail Management and
Penology for the charge of Violation of RA 9165 and has been behind bars since ATTY. ___________________________
his arrest;
2. That no bail has been recommended for his temporary release on the
assumption that the evidence of guilt is strong;
3. That the burden of showing that evidence of guilt is strong rest upon the Copy furnished:
prosecution, and unless this fact is satisfactorily shown, the defendant is
entitled to bail as a matter of right; PROVINCIAL PROSECUTION’S OFFICE
_____________________

      WHEREFORE, it is most respectfully prayed of this Honorable Court that accused CLERK OF COURT
CARDO DALISAY be allowed to post bail for his temporary liberty pending trial of the Regional Trial Court
criminal charge against him. Branch ___
   ___________________________
       Other just and equitable reliefs are likewise prayed for.

October 17, 2018, Imus City, Cavite, Philippines.

BY:

ATTY. ___________________
Roll No. ________
PTR No. __________/____-___-___/______________
IBP No. _____________/__-__-___/________________
MCLE Compliance No. __________
Issued on _______________________
 REPUBLIC OF THE PHILIPPINES
National Capital Judicial Region A: About P40,000.00 to P65,000.00 a month.
Regional Trial Court
Branch 13 7. Q: What is your relation to the adoptee Billie Jean C. Hernandez?
Pasay City
A: I am her aunt. She is the only daughter of my elder brother Arnulfo S.
IN THE MATTER OF THE ADOPTION OF THE MINOR BILLIE JEAN C. HERNANDEZ. Hernandez.

MA. ASUNCION S. HERNANDEZ, Special Proc. No. 18-029612 8. Q: How old is Billie Jean C. Hernandez?
Petitioner. For: Adoption
x-----------------------------------------------x A: She is eleven (11) months old.

JUDICIAL AFFIDAVIT OF 9. Q: What is her date of birth?

PETITIONER MA. ASUNCION S. HERNANDEZ
A: She was born on August 5, 2017.
I, MA. ASUNCION S. HERNANDEZ, of legal age, living at Unit 1130 Studio Zen, Taft Avenue,
Brgy. San Isidro, Pasay City, a petitioner in this case, state under oath as follows: 10. Q: Where was the place of her birth?

PRELIMINARY STATEMENT A: At the Far Eastern University – Dr. Nicanor Reyes Medical Foundation
Hospital in Novaliches, Quezon City.
The person examining me is ATTY. RYAN JAMES S. EDQUILAG with office address at
Baysa, Ariston, Bawalan, and Edquilag (BABE) Law Offices, Unit 106 Champagne Building 2, St. 11. Q: Who are the biological parents of the adoptee Billie Jean C. Hernandez?
Josemaria Escriva Drive, Pasig City. The examination is being held at the same address. I am
answering his questions fully conscious that I do so under oath and may face criminal liability for A: Arnulfo S. Hernandez, my elder brother and Anabelle C. Hernandez.
false testimony and perjury.
12. Q: Where are the biological parents of the adoptee Billie Jean C. Hernandez?
PURPOSE: This Judicial Affidavit of the petitioner MA. ASUNCION S. HERNANDEZ is being
offered as evidence for the petitioner to prove the following: A: They both died in a plane crash about seven (7) months ago when she was
about five (5) months old.
1. That the petitioner Ma. Asuncion S. Hernandez complied all the requirements provided
under the law, making her eligible for the adoption of minor Billie Jean C. Hernandez. 13. Q: Where did the plane crash occurred?
2. All other related matters, facts and circumstances relevant and material to this case.
A: Along Perth, Australia.
1. Q: Do you know why you are here?
14. Q: When did it happened?
A: Yes. I am here to give a sworn statement by way of a judicial affidavit, which
constitutes as my direct testimony, in the case for adoption. A: On January 23, 2018, early in the evening, Philippine time.

2. Q: In what language do you want to be asked? 15. Q: Where was their last known residence before their deaths?

A: In English. A: In Batasan Hills, Quezon City.

3. Q: State your name and personal circumstances. 16. Q: Are there any proceedings initiated within six (6) months upon the death of
the biological parents?
A: My name is Ma. Asuncion S. Hernandez, I am 23 years old, and residing at
Unit 1130 Studio Zen, Taft Avenue, Brgy. San Isidro, Pasay City. A: There are none.

4. Q: What is your civil status? 17. Q: Why do you want to adopt Billie Jean C. Hernandez?

A: I am single. A: Because both her parents had already died and there being no other
relatives remaining, no one can take care of her aside from me, being the only
5. Q: What is your occupation? remaining relative she have.

A: I am an owner and general manager of April Fool’s Restaurant located at Gil 18. Q: Are you convicted of any crime involving moral turpitude?
Puyat Avenue cor. Dian St., Makati City.
A: No. Even there are no cases filed against me in any court.
6. Q: How much does your restaurant earn monthly?
 No further questions.

IN WITNESS WHEREOF, I have hereunto set my hand this 25 th day of July 2018 here in the City NOTARY PUBLIC
of Pasay. Commision Serial No.
Until December 31,2018
Roll of Attorneys No.
MA. ASUNCION S. HERNANDEZ IBP No.
Affiant PTR No.
SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in and for the City of Pasay
this 26th day of July 2018. Affiant personally came and appeared with Passport Number XX0972167,
bearing her photograph and signature, known to me as the same person who personally signed the
foregoing instrument before me and avowed under penalty of law to the whole truth of the contents Doc. No.
of said instrument. Page No.
Book No.
Series of 2018.
NOTARY PUBLIC
Commision Serial No.
Until December 31,2018
Roll of Attorneys No.
IBP No.
PTR No.

Doc. No.
Page No.
Book No.
Series of 2018.

ATTESTATION

I, RYAN JAMES S. EDQUILAG, of legal age, Filipino, single, with office address at Baysa,
Ariston, Bawalan, and Edquilag (BABE) Law Offices, Unit 106 Champagne Building 2, St. Josemaria
Escriva Drive, Pasig City, on oath depose and state that:

I was the lawyer who conducted the examination of the petitioner MA. ASUNCION S.
HERNANDEZ at my aforementioned office in Pasig City;

I have faithfully recorded or caused to be recorded the questions I asked and the
corresponding answer that the witness gave;

I nor any other person then present or assisting her coached the witness regarding her
answers;

IN WITNESS WHEREOF, I have hereunto set my hand this 25th day of July 2018 at the
City of Pasay.

ATTY. RYAN JAMES S. EDQUILAG

SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in and for the City of Pasay
this 26th day of July 2018. Affiant personally came and appeared with Passport Number XX0739639,
bearing his photograph and signature, known to me as the same person who personally signed the
foregoing instrument before me and avowed under penalty of law to the whole truth of the contents
of said instrument.
 3. That KITKAT RETONEL be declared the child of herein petitioners.
REPUBLIC OF THE PHILIPPINE
REGIONAL TRIAL COURT Other reliefs just and equitable are likewise prayed for.
Fourth Judicial Region
Branch 18 Imus City, Cavite, Philippines, August 9, 2018.
Imus City

IN RE: IN THE MATTER OF ADOPTION OF

Atty. VINCENT D. DANGANAN
MINOR KITKAT RETONEL AND CHANGE OF
Counsel for the Petitioners
NAME TO KITKAT PULIDO SPECIAL PROCEEDING NO.: 35160789
Roll of Attorney’s No.: 461201
IBP No. 3669132/9 June 2016/Las Pinas
SPS. MANUEL AND DIVINIA R. PULIDO,
PTR No. 03123619/29 June 2016/Las Pinas
Petitioner,
MCLE Requirement Compliance No. 9108023/9 December 2017
x-----------------------------------------------------x

PETITION
VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING
Petitioners, thru counsel and unto this Honorable Court, respectfully avers that: REPUBLIC OF THE PHILIPPINES)
1. Petitions are husband and wife, Filipinos, both of age and residents of 431 Cammella St. CITY OF IMUS ) S.S.
Veraneo Subd. Toclong II, Imus City, Cavite;
2. They have no legitimate children or descendant and hereby desire to jointly adopt a We, spouses MANUEL PULIDO AND DIVINIA R. PULIDO, Filipino, of legal age, residing at 1969
minor named KITKAT RETONEL, 9 years of age, and a resident of 123 Medicion St. Imus Abbey Road, Brgy. Karuhatan, Makati City, after being sworn to in accordance with law, deposes and
City, Cavite as what appears in her birth certificate (Annex “A”) and school records says that:
(Annexes “B” and “C”);
5. We are the Petitioners in the above-entitled petition;
3. KITKAT RETONEL is a legitimate child of TAGPI and MIHO RETONEL; 6. The facts stated in the above complaint are true and correct to the best of our knowledge
4. Both TAGPI RETONEL and MIHO RETONEL died in an accident on the 10 th day of July and authentic records;
2017; 7. We have not commenced any action or filed any claim involving the same issues in any
5. That KITKAT RETONEL is not disqualified to be adopted; court, tribunal or quasi-judicial agency and, to the best of my knowledge, no such other
6. That KITKAT RETONEL does not own any personal nor real property; action or claim is pending in them; and
7. That petitioners are in possession of all civil and legal rights and have not been 8. If we should learn that the same or similar action or claim has been filed or is pending
after its filing, we shall report that fact within five (5) days from notice to the court or
convicted of any crime involving moral turpitude;
where the complaint or initiatory pleading has been filed.
8. That petitioners are emotionally and psychologically capable of caring for KITKAT
RETONEL; August 9, 2018, Imus City, Cavite, Philippines.
9. That petitions are more than sixteen (16) years older than the prospective adoptee;
10. That petitioners are in a position to support and care for KITKAT RETONEL in MANUEL PULIDO DIVINIA PULIDO
keeping with the means of the family and has undergone pre-adoption services as Affiant Affiant
required by R.A. No. 8522, Sec. 4;
11. Attached as annexes to this petition are the Child and Home Study Reports (Annex “D”
and “E”) conducted by FE GAMBOA, a social worker from the Department of Social SUBSCRIBED AND SWORN TO before me this 26 th day of July 2020 in Valenzuela City,
Philippines, affiant exhibiting to me his competent evidence of identity by way of Passport with
Welfare and Development (DSWD) and a certificate from the DSWD declaring KITKAT
number XX0739639, issued at Manila, Philippines on March 14, 2014.
RETONEL to be legally available for adoption; and
12. Upon finality of the decree of adoption, KITKAT RETONEL shall be known and NOTARY PUBLIC
registered in the Civil Registry as KITKAT PULIDO, following our surname. Commision Serial No.
Until Dec. 31, 2018
WHEREFORE, it is respectfully prayed that upon due notice and hearing, judgement be Doc. No. Roll of Attorneys No.
entered: Page No. IBP NO.
Book No. PTR No.
1. Decreeing the adoption of KITKAT RETONEL in favor of petitioners MANUEL and
Series of 2018..
DIVINIA PULIDO;
2. Changing the name of KITKAT RETONEL to KITKAT PULIDO and the same be entered
in the Civil Register; and