COMPROMISE AGREEMENT

KNOW ALL MEN BY THESE PRESENTS:

This COMPROMISE AGREEMENT is executed by and between:

KURT SORIANO of legal age and a resident of Unit 820, Tower 11, Trees
Residences, Barangay Pasong Putik, Quezon City, Philippines represented herein
by Atty. Juan Dela Cruz (hereinafter referred to as “the plaintiff”).

-and-

DAGUL ROXAS, of legal age and a resident of Unit 820, Tower 12, Trees
Residences, Barangay Pasong Putik, Quezon City, Philippines represented herein
by Atty. Victoria Sarabia (hereinafter referred to as “the defendant”).

WITNESSETH:

WHEREAS, the plaintiff SORIANO and defendant ROXAS have instituted

several actions against each other in the past;

WHEREAS, the plaintiff SORIANO instituted the present action for

reconveyance of real property, annulment of deed of sale and accounting of income
of property;

WHEREAS, the parties desire to buy peace and wish to avoid a protracted
litigation in this case.

NOW THEREFORE, in consideration of the foregoing and the further

covenants hereinafter set forth, the parties agree as follows:

1. Plaintiff shall be paid the sum of FOUR MILLION PESOS (P4,000,000.00)

in accordance with the following schedule:

a. Initial payment - TWO MILLION PESOS (P2,000,000.00) shall be paid

to the plaintiff by defendant ROXAS upon the signing and due execution
of this Compromise Agreement, Provided, however, that the initial
payment by defendant ROXAS shall be delivered into the custody and
possession of a third party, Atty. Mercedes Domingo, who shall act as
escrow-trustee of the parties and who shall only deliver the said initial
payment to the plaintiff through plaintiff’s counsel upon the filing in
Court of this Compromise Agreement.

b. The balance of TWO MILLION PESOS (P1,000,000.00) shall be paid by

defendant ROXAS as follows:

Second payment – ONE MILLION PESOS (P1,000,000.00) within sixty

(60) days after the date of the first payment.

Third payment – ONE MILLION PESOS (P1,000,000.00) within forty-

five (45) days after the date of the second payment.
 2. The initial payment by defendant ROXAS shall be made in cash. The two
payments on the balance shall be covered by post-dated checks drawn by
defendant KABISOTE as payable to ATTY. JUAN DELA CRUZ who shall
hold and account for said payments in trust for plaintiff SORIANO.

3. This Compromise Agreement shall not affect nor prejudice any case or cases
between the parties not specifically referred to herein.

4. Upon delivery of the initial payment made by defendant ROXAS and

delivered to the escrow-trustee of the parties, the parties shall seek Court
approval of this Compromise Agreement and the cancellation or lifting of
the notice of lis pendens issued by the Court over the property subject of the
action.

5. The signatories to this Agreement hereby represent and warrant that they are
duly authorized to execute this Agreement.

6. The parties or their assigns hereby waive, renounce and forever quitclaim all
their respective claims and counterclaims subject of the instant action as well
as those that may arise therefrom, in connection therewith or in relation
thereto.

7. The foregoing covenants are not contrary to law, morals, or public policy
and the parties bind themselves to comply strictly with their undertakings.

IN WITNESS WHEREOF, the parties hereto have hereunto set their hands
this 15th day of October 2022, in Quezon City, Philippines.

KURT SORIANO DAGUL ROXAS

Plaintiff Defendant

Signed in the presence of:

WITNESS

________________________ __________________________
REPUBLIC OF THE PHILIPPINES )
QUEZON CITY ) S. S.

ACKNOWLEDGMENT

BEFORE ME, this 15th day of October 2022 at Quezon City, Metro Manila,
Philippines, personally appeared the following persons above together with other
two (2) instrumental witnesses with their aforementioned competent evidence of
identity,

NAME ID PLACE DATE

KURT SORIANO CTC No. 789456 QUEZON CITY 01/01/22
DAGUL ROXAS CTC No. 456123 QUEZON CITY 01/02/22

who are known to me to be the same persons who executed the foregoing
instrument and acknowledged that the same is their free will and voluntary act.

This Compromise Agreement consists of three (3) pages including this page
in which the acknowledgment is written duly signed by the parties and
instrumental witnesses at the left hand margin hereof.

WITNESS MY HAND and notarial seal at the date and place above written.

ATTY. CALIXTO E. SANTIAGO

Notary Public, Commission until 31 December 2022
Notary Public for the City of Quezon, Metro Manila
Per Notarial Commission Sp. Proc. No.
169(10)
IBP O.R. No. 49293, 05 January 2022, QC Chapter
Roll No. 75731, 31 May 2029
MCLE Compliance No. V-0018491, 12 March 2016

Doc. No. 51;

Page No. 16;
Book No. 14;
Series of 2022