Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Third Judicial Region
Branch 2
City of San Fernando, Pampanga
mtcc1sfp002@judiciary.gov.ph
Tel. No. (045) 404-3219

Sps. ANTONIO B. ACEJO, Jr. and

ANNA MARIE LUZ CHERYL M. ACEJO,
Plaintiffs,

-versus- Civil Case No. 10622

For: Rescission of “Deed of Waiver
and
Transfer of Rights,” with Damages

Sps. GERVACIO C. ESPIRITU

and MILAGROS G. ESPIRITU,
Defendants.
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MANIFESTATION AND MOTION

(with attached Amended Complaint)
Plaintiffs, by counsel, to this Honorable Court, most respectfully state:

1. On 22 November 2022, undersigned counsel for Plaintiffs received an Order

in this case 27 October 2022, directing Plaintiffs to amend the Complaint within 5
days from receipt in order to comply with the requirements of Sec. 6, Rule 7 of the
2019 Amendments to the Revised Rules of Civil Procedure.

2. In compliance with the aforesaid Order of the Honorable Court, Plaintiffs

amended their Complaint, and respectfully submits the Amended Complaint by way
of attachment to this Manifestation and Motion.

3. Plaintiffs additionally manifest that:

3.1. The amendments to the Complaint are underlined to indicate the

specific portions of the Complaint that have been amended, to conform to the
provisions and requirements of Rule 10 of the 2019 Amendments to the 1997
Rules of Civil Procedure.[1]

1 A.M. No. 19-10-20-SC; Rule 10, Sec. 7 states that “a new copy of the entire pleading, incorporating the
amendments… shall be indicated by appropriate marks.”
 -Page 2 of 2-

3.2. All the Annexes, Judicial Affidavits and Documentary Exhibits,

attached to the original complaint are hereby adopted as the Amended
Complaint’s attachments, to form part of the Amended Complaint.

PRAYER

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

1. Plaintiffs be deemed to have complied with the Order of the Honorable Court
dated 27 October 2022;

2. The attached Amended Complaint be admitted to form part of the records of

the case; and

3. All the Annexes, Judicial Affidavits and Documentary Exhibits, attached to

the original complaint be considered and admitted as the attachments to the Amended
Complaint herein submitted.

Other reliefs just and equitable under the premises are likewise prayed for.

City of San Fernando, Pampanga, 24 November 2022.

VICTOR B. ROQUE
Counsel for Plaintiffs
Roll of Attorney No. 35650
PTR No: SF 3908929 Jan. 3, 2022
IBP No.: 170606 Dec. 16, 2021
City of San Fernando, Pampanga
MCLE Compliance No. VIII-0000411
(valid until 14 April 2028)
Issued 02 September 2022 / Pasig City

Postal Address: Contact Information:

Roque & Roque Law Office Landline No. (045) 963-5773
12 Immaculate Conception St. Mobile No. 0920-963-1206
Dolores Homesite Ext. 2, Dolores Email: roque_law@yahoo.com
City of San Fernando, Pampanga