COMPROMISE AGREEMENT

[With Waiver, Release and Quitclaim]

KNOW ALL MEN BY THESE PRESENTS:
This Memorandum of Undertaking [With Waiver, Release and Quitclaim], executed this ____ day of
February 1999 in Makati City, Metro Manila, by and among:
MARIA CARLOS TRINIDAD, JOSE LAURO TRINIDAD, SONIA CARLOS TRINIDAD, all of legal age,
married, with postal address at c/o CHAVEZ LAURETA & ASSOCIATES, Penthouse, Heart Tower, 108
Valero St., Salcedo Village, Makati City, Metro Manila, herein represented by JOSE LAURO TRINIDAD
by virtue of a Special Power of Attorney executed on 25 April 1994, and hereinafter referred to as the
FIRST PARTIES;
METROPOLITAN DOCTORS, INC., doing business under the name and style as METROPOLITAN
MEDICAL CENTER, a corporation duly organized and existing under Philippine laws, with business
address at c/o EDSA, Mandaluyong City, Metro Manila, Metro Manila, herein represented by its Medical
Director, CARLOS P. LOPEZ, M.D., hereinafter referred to as the SECOND PARTY; and
DRA. VISITACION V. LUNA, DRA. ANITA CARMEN-ROCES and DRA. MARIA LUISA ROBERTS, with
postal address at c/o METROPOLITAL MEDICAL CENTER, Mandaluyong City, Metro Manila, hereinafter
referred to as the THIRD PARTIES;
WITNESSETH: THAT
WHEREAS, the FIRST PARTIES are the plaintiffs in Civil Case No. 94-1602, entitled "MARIA CARLOS
TRINIDAD, et al.," versus "METROPOLITAN DOCTORS, INC., et al.," pending in the Regional Trial Court
of Makati City, Branch 65 (Civil Case No. 95-6503), hereinafter referred to as the "Pending Case";
WHEREAS the SECOND PARTY and THIRD PARTIES are the defendants in said Pending Case;
WHEREAS, all the parties are desirous of settling amicably the Pending Case, which as been pending for
almost five (5) years, and thereby put to rest a long and costly litigation;
NOW, THEREFORE, in consideration of the foregoing premises, the parties hereby undertake as follows:
1. The SECOND PARTY shall voluntarily undertake the following:
1.1. to make available to MARIA CARLOS TRINIDAD a private room at the Makati Medical Center which
is appropriate/adequate, considering her present medical condition, including the continued use of the
hospital bed she is now using and a sofa bed, all free of charge and for as long as she remains clinically
alive and in need of medical attention; and
1.2. provide MARIA CARLOS TRINIDAD, likewise free of charge, medicine, drugs, life-support systems,
medical equipment and other facilities, medical assistance, neurological treatment and other appropriate
medical services from competent nurses, doctors or specialists which may be advisable or necessary to
maintain her in her present condition, including treatment of complications or illnesses of whatever kind or
nature which may arise from said treatment or condition.
2. The THIRD PARTIES, individually, undertake to make available their expertise or services when and
as needed by MARIA CARLOS TRINIDAD, upon request by the FIRST PARTIES or the SECOND
PARTY: Provided, that, if for any reason whatsoever the THIRD PARTIES are unable to do so, they shall
exert their best efforts to make available the services of a substitute doctor or specialist, likewise free of
charge.
3. The parties agree to, and shall cause, the dismissal, with prejudice, of the Pending Case, including all
claims and counterclaims therein, and agree not to file any similar case, whether civil, administrative or
criminal, of any kind or nature whatsoever, arising from the same facts, incident, claim, cause or causes
of action.
4. Except as provided in paragraphs 1 and 2 hereof, the parties hereby mutually, irrevocably, freely and
voluntarily release and forever discharge one another, including the officers, directors, employees,
stockholders, successors-in-interest of the SECOND PARTY and the heirs and assigns of the THIRD
PARTIES, from any and all manner of action, causes of action, sum of money, damages, liability,
responsibility, obligation, claims and demands whatsoever in law or equity, which they had, now have, or
may have against each other, including, but not limited to, actual, moral, exemplary and all other
damages or causes of action provided for under the law, if any, arising, directly or indirectly, from the facts
and circumstances giving rise to, surrounding or arising from the complaint and/or counterclaims in the
Pending Case , all of which claims or causes of action by these presents the parties hereby abandon and
waive.
5. This agreement shall not in any way be construed as an admission on the part of any party of any fault,
negligence or liability, of whatever kind and nature, in connection with the Pending Case.
6. In case of material breach of the terms and conditions of this agreement, the innocent party is hereby
authorized to apply for a writ of execution in the Pending Case for the purpose of compelling compliance
with the terms and conditions of this agreement.

IN WITNESS WHEREOF, the partieshave hereunto set their hand this ____ day of November 1999 in
Makati City, Metro Manila.

JOSE LAURO TRINIDAD METROPOLITAN DOCTORS, INC.
For himself and in behalf of Second Party
MARIA CARLOS TRINIDAD
SONIA CARLOS TRINIDAD
First Parties By:
CARLOS P. LOPEZ, M.D.
Medical Director

The THIRD PARTIES:
DRA. VISITACION V. LUNA
DRA. ANITA CARMEN-ROCES
DRA. MARIA LUISA ROBERTS

Witnessed By:
__________________________ __________________________

ACKNOWLEDGEMENT

BEFORE ME, a Notary Public for and in the City of Makati, Metro Manila, personally appeared:

Name CTC No. Place Date

JOSE LAURO TRINIDAD
CARLOS P. LOPEZ
VISITCACION V. LUNA
ANITA CARMEN-ROCES
MARIA LUIS ROBERTS
GRACE LUNA
and they acknowledged to me that they are the same persons who executed the foregoing instrument,
consisting of four (4) pages, including this page; that Hideaki Tateishi and Raul G. Fores are both duly
authorized to appear in behalf of their respective principals; and that they executed the foregoing
instrument as their own free and voluntary act and deed, for themselves and/or in behalf of their
respective principals.
Doc. No. ____;
Page No. ____;
Book No. ____;