No.

1(a)
REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
BRANCH _____,
METRO MANILA
ALEXANDER SISON
Plaintiff,
Civil Case No. _____________
- versus JUAN MARO,
Defendant,
x----------------x

FOR: Collection of Sum of Money

With Damages

COMPLAINT
PLAINTIFF, through the undersigned counsel and to this Honorable
Court, respectfully avers that:
1. Plaintiff ALEXANDER SISON is of legal age, Filipino, married, and
a resident of 111 Libertad St., Sampaloc, Manila. For purposes of this
action, plaintiff may be served with all orders, notices, and other
processes of this Honorable Court through the office address of the
undersigned counsel indicated below;
2. Defendant JUAN MARO is of legal age, Filipino, single, and may be
served with summons and other process of this Honorable Court at his
residence address at #222 Juan Luna St., Tondo, Manila;
3. Sometime on January 3, 2008, Defendant obtained from and was
granted a loan accommodation by the Plaintiff in the principal amount
of ONE MILLION PESOS (Php 1,000,000.00), Philippine
Currency. A true and faithful machine reproduction of the Promissory
Note made by the Defendant on the said date is hereto attached as
Annex A and made an integral part hereof;
4. As shown in the attached promissory note, Defendant promised to pay
the said loan on or before January 3, 2009 or one (1) year from the
date of the note plus an interest rate of Twelve percent (12%) per
annum . However, Defendant failed to pay it on such time and as of

February 28, 2015, Defendant still has an Outstanding Balance to

Plaintiff amounting to ONE MILLION PESOS (PhP 1,000, 000.00)
plus One Hundred Twenty Thousand Pesos (Php 120,000.00)
representing the total annual interest.
5. Despite Plaintiff's repeated demands, both written and verbal,
Defendant failed, neglected and refused, and continues to fail and
refuse to pay and to settle the said Outstanding Balance, without just
and valid grounds, to the continued damage and prejudice of Plaintiff.
A true and faithful machine reproduction of the Plaintiff's demand
letter to Defendant hereto attached as Annex B and made an
integral part hereof;
6. Plaintiff likewise initiated proceedings before the Lupong
Tagapamayapa of Juan Luna St., Tondo, Manila, however, defendant
failed to appear during the scheduled mediation proceeding despite
proper notice, prompting the Lupong Tagapamayapa to issue
Certificate to File Action. A copy of Notice of Hearing and
Certification to File Action are hereto attached as Annex C and
D and made an integral part hereof;
7. Consequently, Plaintiff was constrained to engage the services of
counsel to whom she obligated herself to pay as Attorney's Fees the
amount equivalent to ONE HUNDRED THOUSAND PESOS (PhP
100, 000.00), ten percent (10%) of the total amount due from
Defendant to Plaintiff.

PRAYER
WHEREFORE, premises considered, after due notice and hearing,
Plaintiff respectfully prays that judgment be rendered against the Defendant
as follows:
1. Ordering the Defendant to pay Plaintiff the sums of:
a. The amount of ONE MILLION PESOS (Php 1,000,
000.00), representing Defendant's Outstanding Balance,
plus One Hundred Twenty Thousand Pesos representing the
total annual interest at twelve percent (12%) per annum as
stipulated upon in the Promissory Note;
b. ONE HUNDRED THOUSAND PESOS (PhP 100,
000.00), twelve percent (10%) of the total amount due as

Attorney's Fees plus Appearance Fee at the rate of PhP 3,

000.00 per court hearing / conference;
c. Five percent (5 %) of the total amount due as Collection
Charges / Liquidated Damages;
d. The costs of suit.
2. Plaintiff likewise prays for such other reliefs as may be just and
equitable in the premises.
City of Manila, Philippines, April 1, 2015.

ATTY. CECILIA L. OCHAVO-SAYCON

Counsel for Complainant
#87-C E. Lopez Street, Jaro, Metro Manila
Roll of Attorney No. 55123
PTR No. 27027, City of Manila, January 10, 2014
IBP No. 22427, City of Manila, January 4, 2014
MCLE Compliance No. IV-000927

REPUBLIC OF THE PHILIPPINES)

PROVINCE OF ILOILO
) SS.
x----------------------------x
VERIFICATION AND CERTIFICATION
I, ALEXANDER SISON of legal age, Filipino, married, and a
resident of 111 Libertad St., Sampaloc, Manila, after being sworn in
accordance with law, hereby depose and say:
That I am the Plaintiff in the above-entitled case; That I have caused
the preparation of the above Complaint and I have read the same and
understood the contents thereof; That the allegations contained therein are
true and correct of my own personal knowledge and based on authentic
records.
That I further certify that: (a) I have not theretofore commenced any
other action or proceeding or filed any claim involving the same issues or
matter in any court, tribunal, or quasi-judicial agency and, to the best of my
knowledge, no such action or proceeding is pending therein; (c) if I should
thereafter learn that the same or similar action or proceeding has been filed or
is pending before the Supreme Court, the Court of Appeals, or any other
tribunal or quasi-judicial agency, I undertake to report such fact within five (5)
days therefrom to the court or agency wherein the original pleading and sworn
certification contemplated herein have been filed.
IN WITNESS WHEREOF, I have hereunto set my hand this 1st day
of April 2015 at the City of Manila, Philippines.

ALEXANDER SISON
Affiant
TIN 909-808-707; City of Manila

SUBSCRIBED AND SWORN to before me, this 1st day of April

2015, affiant exhibiting to me his Tax Identification Card as shown above
below his name as competent evidence of his identity.

ATTY. CECILIA L. OCHAVO-SAYCON

Notary Public for and in the
City of Manila and the National Capital Region
Commission Serial. No. 1019
Valid until December 31, 2015
#87-C E. Lopez Street, Jaro, Metro Manila
Roll of Attorney No. 55123
PTR No. 27027, City of Manila, January 10, 2014
IBP No. 22427, City of Manila, January 4, 2014
MCLE Compliance No. IV-000927

Doc. No. ______;

Page No. ______;
Book No. ______;
Series of 201_.

No.1(b)
SPECIAL POWER OF ATTORNEY
KNOW ALL MEN BY THESE PRESENTS
I, CARLO ENRIQUEZ, of legal age, single, Filipino, and a resident of Lopez Jaena St.,
Jaro, Iloilo City, do hereby name, constitute and appoint MERLYN FRANCISCO, of
legal age, single, Filipino, and a resident of D.B. Ledesma St., Jaro, Iloilo City, to be my
true and lawful attorney-in-fact, for me and in my name, place and stead, and in my
behalf for my own benefit, to do and perform the following things and acts, to wit:
1.
To sell, transfer and convey at whatever price, terms and conditions that he/she
may deem proper and fit, to whosoever may buy or purchase our property consisting of a
piece of land located at Lot 2 Block 3 Forbes Park, Makati City, Metro Manila City
covered by TCT No. 14-13435325;
2.
To accept and collect full payment in her name and/or in our joint names, the
proceeds of sale of the afore described property and sign for the receipt thereof;
3.
To sign and execute any and all documents of sale, transfer or conveyance of the
aforementioned property;
4.
To pay any and all unpaid or accrued property taxes including such capital gains
and documentary stamp taxes necessary to effect the registration of the sale and the
transfer of title of the said property to the buyer or purchaser of the same;
5.
To engage the services of a reputable real estate broker, a lawyer, a tax
professional and such other professional real estate practitioner, if necessary, to ensure the
expeditious and smooth sale of the property and to pay their respective fees and/or
commissions from out of the proceeds of sale of the same;
6.
To do and perform any and all other lawful act and deeds necessary to undertake
the execution and finalization of sale, transfer or conveyance of the said property.
HEREBY GIVING AND GRANTING unto the said attorney full power and authority to
do whatsoever requisite or necessary or proper to be done in or about the premises, as
fully to all intents and purpose as I might or could lawfully do if personally present, and
hereby ratifying and confirming all that the said attorney shall do or cause to be done
under and by virtue of these presents.
IN WITNESS WHEREOF, I have hereunto set our hands this 31st day of March 2015 at
Iloilo City, Philippines.

CARLO ENRIQUEZ
Affiant
SIGNED IN THE PRESENCE OF:
BEN CHAN TOS

PAOLO BENTANES

ACKNOWLEDGMENT
REPUBLIC OF THE PHILIPPINES )
CITY OF ILOILO
) S.S.
BEFORE ME, a Notary Public, for and in the City of Iloilo, this 31st day of
March 2015, in the City of Iloilo, Philippines, personally appeared, CARLO ENRIQUEZ,
with TIN 134-123-134, issued on March 23, 2005, at Iloilo city, Philippines, and
MERLYN FRANCISCO, with TIN 546-123-134, issued on March 2, 2005, at Iloilo city,
Philippines, known to me to be the same person who executed the foregoing document
and acknowledged tome as their own free and voluntary act and deed.
WITNESS MY HAND AND SEAL this 31st day of March 2015at Iloilo City,
Philippines.

ATTY. LAURENCE SUSAN P. ORTIZ

Notary Public for and in the
City and Province of Iloilo
Commission Serial. No. 1989
Valid until December 31, 2015
#03 Lopez, Jaena St., Jaro, Iloilo City
Roll of Attorney No. 44661
PTR No. 22334, Iloilo City, January 17, 2014
IBP No. 44556, Iloilo City, January 10, 2014
MCLE Compliance No. VI-010489
Doc. No. ____;
Page No. ____;
Book No. ____;
Series of 2015.

No. 3

Republic of the Philippines

REGIONAL TRIAL COURT
6h Judicial Region
Branch ___
Metro Manila
PEOPLE OF THE PHILIPPINES,
Plaintiff,
-versus-

CRIM. CASE NO.

FOR: Robbery with Homicide

EDGAR BASTONERO, alias

Bugoy and CARLOS
TIRADOR, alias Pogi,
Accused.
x------------------------------------------x
INFORMATION
The undersigned Assistant City Prosecutor accuses Edgar Bastonero
alias Bugoy and Carlos Tirador alias Pogi of the crime of Robbery with
Homicide, defined and penalized under Article 295, paragraph 1 of the
Revised Penal Code, committed as follows:
That on September 13, 2009 at 6 oclock in the evening at the coner
of Dapitan and Castillas Sts., Sampaloc, Manila and within the
jurisdiction of the Honorable Court, the above-named accused
EDGAR BASTONERO, alias Bugoy and CARLOS TIRADOR,
alias Pogi, conspiring and confederating together and mutually
helping one another, by means of force and violence employed upon
the person of one JOHNNY ESCOLAR, in repeatedly stabbing with
sharp bladed instruments the latter on the chest, with intent of gain
and against the will and consent of said Johnny Escolar, did then and
there willfully, unlawfully and feloniously take, steal and rob from the
latter, his cellular phone and wrist watch more or less, to the damage
and prejudice of said Thelma Padua- Aruelo in the amount of
P15,200.00, and which cellular phone has never been recovered: that
also as a consequence of the force and violence employed by the
herein accused upon the person of Johnny Escolar, prompted by
deliberate intent to kill, the latter sustained mortal wounds which
caused his untimely death.
Contrary to law.

Metro Manila, January 19, 2010

ATTY. RIZALEE J. PEREZ

Assistant City Prosecutor
WITNESSES:
WILLIAM TAN

HENRY UY

CERTIFICATION
I hereby certify that a preliminary investigation was conducted in the
above-entitled case and there is prima facie evidence that the crime of
Robbery with Homicide has been committed and that the accused are
probably guilty thereof.

ATTY. RIZALEE J. PEREZ

Assistant City Prosecutor
Bail Recommended: None

No. 4

LEASE CONTRACT
KNOW ALL MEN BY THESE PRESENTS:

This CONTRACT OF LEASE is made and executed at the City of Iloilo, this 4th day of
April, 2015, by and between:
JOSE UY, of legal age, single, Filipino, and with residence and postal address at 3
352 Jayme St., Jaro, Iloilo, hereinafter referred to as the LESSOR.
-ANDJOHN PRATS, likewise of legal age, single, Filipino and with residence and postal
address a No. 39, Blk. 42, Puerto Real Subdivision, La Paz, Iloilo City, hereinafter
referred to as the LESSEE.
WITNESSETH; That
WHEREAS, the LESSOR is the owner of the Third Floor of Panaderia ni Pa-a
Building, hereinafter referred to as THE LEASED PREMISES, a commercial building,
situated at Jaro, Iloilo City;
WHEREAS, the LESSOR agrees to lease-out the said property to the LESSEE
and the LESSEE is willing to lease the same;
NOW THEREFORE, for and in consideration of the foregoing premises, the
LESSOR leases unto the LESSEE and the LESSEE hereby accepts from the LESSOR the
LEASED premises, subject to the following:
TERMS AND CONDITIONS
1. PURPOSES: That premises hereby leased shall be used exclusively by the
LESSEE for mandatory continuing education and review classes for the Bar
examinations purposes only and shall not be diverted to other uses. It is hereby expressly
agreed that if at any time the premises are used for other purposes, the LESSOR shall
have the right to rescind this contract without prejudice to its other rights under the law.
2. TERM: This term of lease is for ONE (1) YEAR from April 1, 2015 to April
1, 2016 inclusive. Upon its expiration, this lease may be renewed under such terms and
conditions as my be mutually agreed upon by both parties, written notice of intention to
renew the lease shall be served to the LESSOR not later than thirty (30) days prior to the
expiry date of the period herein agreed upon.
3. RENTAL RATE: The monthly rental rate for the leased premises shall be in
TWENTY FIVE THOUSAND PESOS (P 25,000.00), Philippine Currency. All rental
payments shall be payable to the LESSOR.

4. DEPOSIT: That the LESSEE shall deposit to the LESSOR upon signing of
this contract and prior to move-in an amount equivalent to the rent for THREE (3)
MONTHS or the sum of SEVENTY FIVE THOUSAND PESOS (P 75,000.00),
Philippine Currency, wherein the two (2) months deposit shall be applied as rent for the
11th and 12th months and the remaining one (1) month deposit shall answer partially for
damages and any other obligations, for utilities such as Water, Electricity, CATV,
Telephone, Association Dues or resulting from violation(s) of any of the provision of this
contract.
5. DEFAULT PAYMENT: In case of default by the LESSEE in the payment of
the rent, such as when the checks are dishonored, the LESSOR at its option may
terminate this contract and eject the LESSEE. The LESSOR has the right to padlock the
premises when the LESSEE is in default of payment for Two (2) months and may forfeit
whatever rental deposit or advances have been given by the LESSEE.
6. SUB-LEASE: The LESSEE shall not directly or indirectly sublet, allow or
permit the leased premises to be occupied in whole or in part by any person, form
or corporation, neither shall the LESSEE assign its rights hereunder to any other person
or entity and no right of interest thereto or therein shall be conferred on or vested in
anyone by the LESSEE without the LESSOR'S written approval.
7. PUBLIC UTILITIES: The LESSEE shall pay for its telephone, electric,
cable TV, water, Internet, association dues and other public services and utilities during
the duration of the lease.
8. FORCE MAJEURE: If whole or any part of the leased premises shall be
destroyed or damaged by fire, flood, lightning, typhoon, earthquake, storm, riot or any
other unforeseen disabling cause of acts of God, as to render the leased premises during
the term substantially unfit for use and occupation of the LESSEE, then this lease
contract may be terminated without compensation by the LESSOR or by the LESSEE by
notice in writing to the other.
9. LESSOR'S RIGHT OF ENTRY: The LESSOR or its authorized agent shall
after giving due notice to the LESSEE shall have the right to enter the premises in the
presence of the LESSEE or its representative at any reasonable hour to examine the same
or make repairs therein or for the operation and maintenance of the building or to exhibit
the leased premises to prospective LESSEE, or for any other lawful purposes which it
may deem necessary.
10. EXPIRATION OF LEASE: At the expiration of the term of this lease or
cancellation thereof, as herein provided, the LESSEE will promptly deliver to the
LESSOR all corresponding keys and in as good and tenable condition as the same is now,
ordinary wear and tear expected devoid of all occupants, movable furniture, articles and
effects of any kind. Non-compliance with the terms of this clause by the LESSEE will
give the LESSOR the right, at the latter's option, to refuse to accept the delivery of the
premises and compel the LESSEE to pay rent therefrom at the same rate plus Twenty
Five (25) % thereof as penalty until the LESSEE shall have complied with the terms
hereof. The same penalty shall be imposed in case the LESSEE fails to leave the
premises after the expiration of this Contract of Lease or termination for any reason
whatsoever.
11. JUDICIAL RELIEF: Should any one of the parties herein be compelled to
seek judicial relief against the other, the losing party shall pay an amount of One Hundred
(100) % of the amount clamed in the complaint as attorney's fees which shall in no case

be less than P30,000.00 pesos in addition to other cost and damages which the said party
may be entitled to under the law.
12. This CONTRACT OF LEASE shall be valid and binding between the
parties, their successors-in-interest and assigns.
IN WITNESS WHEREOF, parties herein affixed their signatures on the date
and place above written.

JOSE UY
LESSOR

JOHN PRATS
LESSEE

Signed in the presence of:

HENRICH P. LIM

CIBIL CODESA

ACKNOWLEDGEMENT
Republic of the Philippines)
City of Iloilo
) S.S
x--------------------------------x
BEFORE ME, personally appeared:
Name

CTC Number

JOSE UY

1920810

JOHN PRATS

0928490

Date/Place Issued
February 24, 2014 / Iloilo City
January 07, 2014 / Iloilo City

Known to me and to me known to be the same persons who executed the

foregoing instrument and acknowledged to me that the same is their free and voluntary
act and deed.
This instrument consisting of four (4) pages, including the page on which this
acknowledgement is written, has been signed on each and every page thereof by the
concerned parties and their witnesses, and sealed with my notarial seal.
WITNESS MY HAND AND SEAL, on the date and place first above written.

ATTY. LAURENCE SUSAN P. ORTIZ

Notary Public for and in the
City and Province of Iloilo
Commission Serial. No. 1989
Valid until December 31, 2015
#03 Lopez, Jaena St., Jaro, Iloilo City
Roll of Attorney No. 44661
PTR No. 22334, Iloilo City,
January 17, 2014
IBP No. 44556, Iloilo City,
January 10, 2014
MCLE Compliance No. VI-010489

Doc No. ______;

Page No. ______;
Book No. _____;
Series of 2015.

No.5
REPUBLIC OF THE PHILIPPINES)
CITY OF ILOILO
) S.S.
x-------------------------------------------------x

AFFIDAVIT OF LOSS
I, RIZALEE J. PEREZ, female, of legal age, single, Filipino, and a
resident of 210 Lopez Jaena St., Jaro, Iloilo City, after having been duly
sworn to in accordance with law hereby depose and state, that:
I am a licensed Certified Public Accountant (CPA);
I am the owner of a CPA professional license, with license no.
1596483672;
Some time on March 15, 2015, I discovered that the said license,
which is usually kept in my wallet, cannot anymore be found therein;
Despite diligent efforts to locate the said license, the same could no
longer be found and therefore is considered lost and beyond recovery;
I am executing this affidavit to attest to the truth of the foregoing
facts, for the purpose of requesting for the reissuance/renewal of said license
with the Professional Regulation Commission (PRC), and for any other
intent this may duly serve.
IN WITNESS WHEREOF, I have hereunto set my hand this 30 th day
of March, 2015 at Iloilo City, Philippines.

RIZALEE J. PEREZ
Affiant

SUBSCRIBED AND SWORN TO before me this 30th day of March

2015 at Iloilo City. Affiant exhibited to me his Tax Identification Card with
No.000-860-567 as competent proof of identity.

ATTY. CECILIA L. OCHAVO-SAYCON

Notary Public for and in the
City and Province of Iloilo
Commission Serial. No. 1019
Valid until December 31, 2015
#87-C E. Lopez Street, Jaro, Iloilo City
Roll of Attorney No. 55123
PTR No. 27027, Iloilo City, January 10, 2014
IBP No. 22427, Iloilo City, January 4, 2014
MCLE Compliance No. IV-000927

Doc. No. _________;

Page No. _________;
Book No. _________;
Series of 2015.

No. 6
CHATTEL MORTGAGE

KNOW ALL MEN BY THESE PRESENTS:

This CHATTEL MORTGAGE, made and entered into by and betweenTESS BUZZ , of legal age, single, with postal address at Brgy. Sambag, Jaro,
Iloilo City, hereinafter known as the MORTGAGOR,
-and RIZAL COMMERCIAL BANKING INSTITUTION, a banking institution
duly organized under the laws of the Philippines, with principal office at 302 Roosevelt
Avenue, San Francisco Del Monte, Quezon City, Metro Manila, represented by its Jaro,
Iloilo City Branch Manager JOSIE C. DIZON, hereinafter known as the
MORTGAGEE
WITNESSETH
That the MORTGAGOR is indebted unto the MORTGAGEE in the sum
of EIGTH HUNDRED THOUSAND PESOS (PhP 800,000.00), Philippine Currency,
receipt of which is acknowledged by the MORTGAGOR upon the signing of
this instrument, payable within a period of three (3) years, with interest thereon at the
rate of 10 % per annum;
That for, and consideration of , this indebtedness, and to assure the performance of
said obligation to pay, the MORTGAGOR hereby conveys by way of CHATTEL
MORTGAGE unto the MORTGAGEE, his heirs and assigns, the following
personality now in the possession of said MORTGAGOR
MAKE
: Honda Civic
SERIES
: 67
TYPE OF BODY: Coupe
YEAR MODEL :2010

MOTOR NO.
SERIAL/CHASSIS NO.
PLATE NO.
FILE NO.

: 5467893
: 52479
: FEW 456
: 700034

That the condition of this obligation is that should the

MORTGAGOR perform the obligation to pay the hereinabove cited indebtedness of
EIGTH HUNDRED THOUSAND PESOS (PhP 800,000.00), Philippine Currency,
together with accrued interest thereon, this chattel mortgage shall at once become null and
void and of no effect whatsoever, otherwise, it shall remain in full force and effect.
IN WITNESS WHEREOF, the parties have hereunto set their hands, this 28th
day of March 2015 at Iloilo City, Philippines.

TESS BUZZ
MORTGAGOR

JOSIE C. DIZON
MORTGAGEE

IN THE PRESENCE OF:

JOAN BLAIRE V. SIO

ROSEMINDA A. VARONA

ACKNOWLEDGEMENT

REPUBLIC OF THE PHILIPPINES)

ILOILO CITY
) S.S
x------------------------------------------------x

BEFORE ME, personally appeared:

Name

TIN

Date/Place Issued

TESS BUZZ

3489302

January 5, 2009/ Iloilo City

JOSIE C. DIZON

2390294

May 3, 2010/ Iloilo City

Known to me and to me known to be the same persons who executed the foregoing
instrument and acknowledged to me that the same is their free and voluntary act and
deed.
WITNESS MY HAND AND SEAL this 31st day of March 2015 at Iloilo City,
Philippines.

ATTY. VINCENT ENRIQUE A. VARONA

Notary Public for and in the City and Province of Iloilo
My Commission No. is 58
Expires on December 31, 2015
Varona Law Office, Alta Tierra Village, Jaro, Iloilo City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/14, Iloilo City
IBP NO. 123456, 01/04/14, Iloilo City
MCLE Comp. No. IV-0009876,
01/02/14

Doc. No. ;
Page No. ;
Book No. ;
Series of 2015.

AFFIDAVIT OF GOOD FAITH

We, the undersigned MORTGAGOR AND MORTGAGEE hereby jointly and

severally swear that we executed the foregoing Chattel Mortgage in order to secure the
indebtedness therein and for no other purpose or purposes contrary to law.

TESS BUZZ
MORTGAGOR
TIN 3489302, 01/05/09, Iloilo City

JOSIE C. DIZON
MORTGAGEE
TIN 2390294, 05/03/10, Iloilo City

SUBSCRIBED AND SWORN to before me, this 31st day of March 2015,
affiants exhibiting to me their Tax Identification Card as shown above below their names
as competent evidence of their identities.

ATTY. VINCENT ENRIQUE A. VARONA

Notary Public for and in the City and Province of Iloilo
My Commission No. is 58
Expires on December 31, 2015
Varona Law Office, Alta Tierra Village, Jaro, Iloilo City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/14, Iloilo City
IBP NO. 123456, 01/04/14, Iloilo City
MCLE Comp. No. IV-0009876, 01/02/14

Doc. No. ;
Page No. ;
Book No. ;
Series of 2015;

No. 7(a)
GELITO LAW OFFICE
Room 5, 2nd Floor, Buencamino Building
No. 338-F Project 4, Quezon City
July 1, 2007
JUN MIRANDA
No. 9, West Aguila, Green Cross Subdivision
Quezon City, Philippines
Dear Mr. Miranda:
I wrote this letter in behalf of my client, IAN ALBA, on the matter of your
non-fulfillment of your obligation.
My clients records provide that you have an outstanding liability due to my
client in the aggregate amount of THREE HUNDRED THOUSAND PESOS
(P300,000.00) comprising of the monthly rental of FIFTY THOUSAND
PESOS (P50,000.00) from January 1, 2007 to June 30, 2007.
This serves as a FINAL DEMAND for you to settle the said amount within
FIVE (5) days from receipt of this letter and to vacate the premises after the
settlement of said liability. Otherwise, we will be constrained to file a
necessary legal action against you to protect the interest of our client.
We trust that you will give this matter your prompt and preferential attention
to avoid the expense and inconvenience of litigation.

Sincerely,
Atty. Jose Judhil F. Gelito

No. 7(b)
REPUBLIC OF THE PHILIPPINES
METROPOLITAN TRIAL COURT
Branch ____
Quezon City
IAN ALBA,
Plaintiff,
CIVIL CASE No. _____
FOR: Unlawful Detainer

-versusJUN MIRANDA,
Defendant.
x-----------------------------------x
COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and

unto this Honorable Court, most respectfully avers:
1. That the plaintiff, IAN ALBA, is of legal age, Filipino citizen, with
residence and postal address at No. 9, West Aguila, Green Cross
Subdivision, Quezon City, Philippines where he may be served with
summons and other court processes;
2. That the defendant, JUN MIRANDA, is of legal age, Filipino citizen,
single, with residence and postal address at No. 9, West aguila, Green
Cross Subdivision, Quezon City, Philippines where he may be served
with summons and other court processes;
3. That the plaintiff is the owner of the subject property, a house and lot,
located at No. 9, West Aguila, Green Cross Subdivision, Quezon City,
Philippines;
4. That by virtue of a contract of lease, the plaintiff leased unto the
defendant the aforesaid house and lot for a consideration of FIFTY
THOUSAND PESOS (P50,000.00) for a term of two years starting
May 1, 2006;

5. That the defendant failed to pay the agreed rental for six months
starting January 1, 2007 to June 30, 2007or a total of THREE
HUNDRED THOUSAND PESOS (P300,000.00).
6. That on July 1, 2007, the plaintiff sent a letter of demand, requesting
the defendant to fulfill his obligation and to vacate the premises,
which was received by the defendant on July 2, 2007 as shown in the
registry return receipt hereto attached as Annex A;
7. That despite the said letter of demand, the defendant failed to pay his
liability and to vacate the premises;
8. That by reason of the failure of the defendant to pay the unpaid rentals
and to vacate the premises, the plaintiff was compelled to file this
complaint engaging the services of a counsel in the amount of
P25,000.00.
PRAYER

WHEREFORE, premises considered, it is most respectfully prayed

unto this Honorable Court that after hearing judgment be rendered ordering
the defendant:
1. To pay the amount of THREE HUNDRED THOUSAND PESOS
(P300,000.00);
2. To vacate the premises;
3. To pay the plaintiff the cost of the suit.
Quezon City, Philippines, July 8, 2007.

Atty. Jose Judhil F. Gelito

Counsel for the Plaintiff
Roll of Attorneys No. 41990
IBP Lifetime No. 367700

Republic of the Philippines )

City of Quezon
) S.S.
VERIFICATION/CERTIFICATION OF FORUM SHOPPING
I, IAN ALBA, of legal age, Filipino citizen, single and resident of No.
9, West Aguila, Green Cross Subdivision, Quezon City, Philippines, after
having been duly sworn to in accordance with law do hereby depose and
say:
1. That I am the plaintiff in the above-entitled case;
2. That I have caused the preparation of the foregoing complaint;
3. That I have read and understood the allegations contained therein and
the same are true and correct of my own knowledge and based on
authentic records;
4. That I have not heretofore commenced or filed any other action or
proceeding involving the same issues in any court, tribunal or quasijudicial agency; that to the best of my knowledge, no such other
action or claim is pending in any court, tribunal or agency; that if I
should learn thereafter that a similar action or proceeding has been
filed or is pending, I hereby undertake to inform this Honorable Court
such fact within five (5) days therefrom.

IN WITNESS WHEREOF, I have hereunto set my hand this 8th day of

July 2007, in the City of Quezon, Philippines.

IAN ALBA
Affiant
Drivers License No. 1234567
Valid until: December 15, 2007

SUBSCRIBED AND SWORN to before me this 8 th day of July 2007,

in the City of Quezon, Philippines, affiant having exhibited to me his
Drivers License No.: 1234567 issued on December 15, 2005 at Quezon
City.

Atty. Jose Judhil F. Gelito

Notary Public until December 31, 2008
Reg. No. 2013-040
PTR No. 4905269, Quezon City, January 5, 2007
Roll No. 41990
IBP Lifetime No. 367700
MCLE Compliance No. IV- 0007890

Doc. No. 5;
Page No. 2;
Book No. 1;
Series of 2007.

No. 8
DEED OF ABSOLUTE SALE
KNOW ALL MEN BY THESE PRESENTS:
That I, GERRY CRUZ, of legal age, single, Filipino and residents of No. 31, Blk.
78, Happy Villages , Sampaloc, Manila, Philippines, do hereby state and declare:

WITNESSETH:
That I am the registered owner of a parcel of land, hereunder particularly
described as follows:

TCT NO. 12345

A parcel of land (Lot No. 42, Block 6 of the subdivision plan Psd-77339,
being a portion of Lot 2399-F of plan Psd-50077, L.R.C. Record No.),
situated in the Brgy. Sampaloc, City of Manila. Bounded on the NW.,
along line 1-2 by Lot 41, Block 6 of the subdivision plan; on the NE.,
along line 2-3 by Lot 2399-B of Plan Psd-5077; on the SE, along line 3-4
Lot 43, Block 6; and on the SW., along line 4-1 by Road Lot 9, both of the
subdivision Plan. Containing an area of ONE THOUSAND (1,000) square
meters, more or less.
That for and in consideration of the sum of ONE MILLION PESOS
(P1,000,000.00), receipt of the said amount, we do hereby acknowledge to our full and
complete satisfaction from ANGELO SANTOS of legal age, Filipino, married to Angela
Reyes, and a resident of Democracia Street, Sampaloc, Manila, by these presents, do
hereby SELL, CEDE, TRANSFER and CONVEY, unto the said ANGELO SANTOS, his
heirs and assigns, a portion of the above-mentioned described parcel of land consisting an
area of One Thousand (1,000.00) square meters, more or less, free from all liens and
encumbrances.
That the above-described parcel of land is residential and is not covered by the
provisions of the Comprehensive Agrarian Reform Law.
IN WITNESS WHEREOF, I have hereunto set my hand this 26th day of September
2005, at Iloilo City, Philippines.

GERRY CRUZ

ANGELO SANTOS

Vendor
CTC No. 090810
Issued at Manila, Philippines
Issued on 1/1/2015

Vendee
CTC No. 123701
Issued at Manila, Philippines
Issued on 2/7/2015

SIGNED IN THE PRESENCE OF

________________________________

_________________________________

ACKNOWLEDGEMENT
REPUBLIC OF THE PHILIPPINES)
CITY OF ILOILO
) SS.
X-----------------------X
BEFORE ME, a Notary Public for and in the Province and City of Manila,
Philippines, this 26th day of September 2005, personally appeared the above-named
VENDORS, with their CTCs appearing below their respective names, all known to me to
be the same persons who executed the foregoing instrument and they acknowledged that
the same is their free and voluntary act and deed.
This instrument consists of two (2) pages, including this page wherein this
acknowledgement is written, refers to a Deed of Absolute Sale, signed by the VENDORS
and their instrumental witnesses on each and every page hereof.

WITNESS MY HAND AND SEAL, on the date and place above-written.

ATTY. JUAN DE LA CRUZ
Notary Public Within the Territorial
Jurisdiction of the City and Province of Iloilo
No. 20, Bonifacio Drive, Iloilo City
Notarial Commission Reg. No. 91
Valid until December 31, 2015
PTR No. 4816263, Iloilo City
January 6, 2014
IBP No. 596706, Iloilo City
January 3, 2014
Roll No. 75329
TIN: 244-535-544
MCLE Compliance No. IV-0002366

Doc. No. _________;

Page No. _________;
Book No. _________;
Series of 2015.

No. 9
Republic of the Philippines
6TH JUDICIAL REGION
Regional Trial Court
Branch 10
Iloilo City
JOHN LLOYD CRUZ,
Plaintiff,

CIVIL CASE NO. 2014-0123

FOR: Nullity of

Marriage
-versusSHAWIE CUNETA,
Defendant.
x------------------------------------x
MOTION TO WITHRAW AS COUNSEL
COMES NOW, Counsel of record for the defendant and to this
Honorable Court respectfully moves to withdraw as counsel of said
defendant without the express consent of said defendant, due to a recent
appointment as a clerk of court in the Regional Trial Court Branch 10.
That upon approval of this Honorable Court, all pleadings, notice and
papers in connection with this case be addressed to SHAWIE CUNETA with
address at Alta Tierra Village, Jaro, Iloilo City.
Jaro, Iloilo City, Philippines this 31st day of March, 2015.

ATTY. JUAN DE LA CRUZ

Counsel for the plaintiff
Copy furnished through personal service:
Atty. Pedro Penduko
Counsel for the Defendant
#03 Lopez, Jaena St.,
Jaro, Iloilo City

WITHDRAWAL OF APPEARANCE

THE BRANCH CLERK OF COURT

Regional Trial Court
Branch 10, Iloilo City
Please make of record the WITHDRAWAL of the undersigned as
counsel for plaintiff, JOHN LLOYD CRUZ, due to irreconcilable
professional differences with plaintiff, for which reason the express
conformity of plaintiff cannot be obtained. Henceforth kindly address all
pertinent notices to plaintiff at her address given in the Complaint.
RESPECTFULLY SUBMITTED.
Jaro, Iloilo City; 31st day of March 2015.

ATTY. JUAN DE LA CRUZ

Counsel for the plaintiff

No.10
Republic of the Philippines
6TH JUDICIAL REGION
Regional Trial Court
Branch 42
Iloilo City
MIA C. SANCHEZ,
Plaintiff,
- versus -

Civil Case No. 34857

FOR: COLLECTION OF A
SUM OF MONEY

PAOLO D. CRUZ,
Defendant.
x -----------------------x

NOTICE OF APPEAL
DEFENDANT, PAOLO D. CRUZ, by counsel, and unto this
Honorable Court, most respectfully gives notice that he is appealing to the
Regional Trial Court, both questions of fact and law, the Decision dated
January 23, 2015, a copy of which was received on January 26, 2015.
Respectfully submitted.
February 4, 2015, Iloilo City, Philippines.

ATTY. VINCENT ENRIQUE A. VARONA

Counsel for Defendant
Varona Law Office, Alta Tierra Village, Jaro, Iloilo City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/14, Iloilo City
IBP NO. 123456, 01/04/14, Iloilo City
MCLE Comp. No. IV-0009876, 01/02/14

COPY FURNISHED:
BY PERSONAL SERVICE
ATTY. MA. CASSIE JEAN D. DOLDUCO
Counsel for the Petitioner
Dolduco Law Office, Mission Extension Street, Lapaz, Iloilo City
Received on February 4, 2015

No. 11
DEED OF DONATION OF A PARCEL OF LAND
KNOW ALL MEN BY THESE PRESENTS:
This Deed of Donation, made and executed in the City of Iloilo, Philippines, by
VIVIEN GARCIA CRUZ of legal age, single, Filipino citizen and with residence and
postal address at 5006 Lacturan Dumangas, Iloilo, hereinafter called the DONOR.
-

IN FAVOR OF -

SHAUN GARCIA CRUZ, of legal age, single, Filipino citizen and with
residence and postal address at 5006 Bacay Dumangas, Iloilo, hereinafter called the
DONEE.
-

WITNESSETH

That the DONOR is the owner of a parcel of land situated in Lot 1 Block 3 Rica
Village, Tabuc Suba, Jaro, Iloilo City and more particularly described in Transfer
Certificate of Title No. 123456 of the Registry of Deeds of Iloilo City.
That for and in consideration of the love and affection which the DONOR has for
the DONEE, the said DONOR, by these presents, transfers and conveys, by way of
donation, unto said DONEE, his heirs and assigns, the above described real property, free
from all liens and encumbrances;
That the DONOR does hereby state, for the purpose of giving full effect to this
donation, that he has reserved for himself in full ownership sufficient property to support
him in a manner appropriate to his needs;
That the DONEE does hereby accept this donation of the above-described
property, and does hereby express gratitude for the kindness and liberality of the
DONOR.
IN WITNESS WHEREOF, the DONOR and the DONEE have signed this deed
on the 1st day of March 2015 at Iloilo City, Philippines.

VIVIEN GARCIA CRUZ

Donor

SHAUN GARCIA CRUZ

Donee

SIGNED IN THE PRESENCE OF:

MARIA LOPEZ MAKILING

JUAN GO TAMAD
Witness

Witness

ACKNOWLEDGEMENT

REPUBLIC OF THE PHILIPPINES)

ILOILO CITY
) S.S.
BEFORE ME, this 1st day of March 2015, personally appeared (1) VIVIEN
GARCIA CRUZ; (2) SHAUN GARCIA CRUZ; (3) MARIA LOPEZ MAKILING (4)
JUAN GO TAMAD, all Filipinos, of legal age, and residing at Dumangas, Iloilo, having
presented to me their respective competent evidence of identities as indicated below:

NAME

COMPETENT EVIDENCE
OF IDENTITY

DATE / PLACE ISSUED

VIVIEN GARCIA CRUZ

TIN 342-670-456

2/28/2015, Iloilo City

SHAUN GARCIA CRUZ

TIN 1234-456-789

2/14/2015, Iloilo City

MARIA LOPEZ MAKILING

TIN 987-654-321

2/26/2015, Iloilo City

JUAN GO TAMAD

TIN 234-564-089

2/23/2015, Iloilo City

To me known to be the persons who executed and accepted the foregoing

instrument of Deed of Donation over one (1) parcel of land including all the
improvements thereon, which instruments consist of two (2) pages including the page on
which this acknowledgement is written and signed at the left margin of each and every
page by the party executing this instrument and their witnesses and sealed with my
notarial seal and the acknowledge to me that the same is their free act and deed.
IN WITNESS WHEREOF, I have hereunto set my hand and seal this 1 st day of
March 2015.

Doc. No. ____;

Page No. ____;
Book No. ____;
Series of 2015.

ATTY. MA. CASSIE JEAN D. DOLDUCO

NOTARY PUBLIC
Commission Serial No. 72
Valid Until December 31, 2015
Dolduco Law Office,
Mission Extension Street, Lapaz, Iloilo City
ROLL OF ATTORNEYS NO. 34875

PTR NO. 1232389, 1/09/14, Iloilo City

IBP NO. 451266, 1/06/14, Iloilo City
MCLE Comp. No. IV-0007621, 3/10/14
No. 12

"Any dispute, controversy or claim arising out of or relating to this contract, or the
breach, termination or invalidity thereof shall be settled by arbitration in accordance with
the PDRCI Arbitration Rules as at present in force.
(a) The appointing authority shall be Mr. Sander Grande;
(b) The number of arbitrators shall be three;
(c) The place of arbitration shall be at Jaro, Iloilo City;
(d) The languages to be used in the arbitral proceedings shall be English or Filipino"