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Republic of the Philippines

6th Judicial Region


Municipal Trial Court in Cities
Branch 4
Bacolod City
ROMEO C. CHIU, REPRESENTED BY
RICHARD CHIU
Plaintiff,
- versus -

Civil Case No. 33358


For: UNLAWFUL DETAINER
WITH DAMAGES

GREGORIO V. PARREO,
Defendant.
x--------------------------------------x
MOTION TO NULLIFY THE COMPROMISE AGREEMENT
COMES NOW the respondent to this Honorable Court, most
respectfully file this Motion to Nullify the Compromise Agreement
between respondent Gregorio Vasquez Parreo and complainant Romeo
Chiu represented by his son Richard Chiu dated October 14, 2015.
BACKGROUND/STATEMENT OF FACTS
During the court hearing on the above entitled case on October 14,
2015, respondent start to feel the numbness in his right extremities
accompanied with a severe headache while he was raising an argument
with the counsel of the complainant before the presiding judge of this
Honorable Court. He felt a sudden hot flash from his body going up to his
head and he noticed that he was stammering on his speech and at the
same time felt disoriented. On this condition, he was about to inform the
Presiding Judge of what was happening to him but did not because he was
not sure what it was.
To hasten the proceeding since he felt so very bad, disoriented, and a
feeling of heaviness all throughout his body, he just agree with every point
raised by the complainant and up to the point where the Compromise
Agreement was reached.

Comes Thursday and Friday, respondent felt so very bad due to


numbness on his right extremities accompanied with severe headache. He
was brought to Bacolod Adventist Medical Centre (BAMC for short) early in
the morning (3:00 AM) the following day by Jane Camaymayan Puro (See
affidavit mark as annex A) as a part and parcel of this motion.
Upon arrival at BAMC, respondent was given the necessary
treatment at the Emergency Section to save his life and did undergo
several tests. After the tests, he was advised not to go home for his case
started October 14, 2015 might be TRANSIENT ISCHEMIC ATTACK. As
per MEDICAL CERTIFICATE issued by BAMC and should form part and
parcel of this motion (See annex B), indeed respondent was suffering from
TRANSIENT

ISCHEMIC

ATTACK,

Hypercholesterotemia,

and

Hypertensive Cardiovascular Disease. For further evidence, the CLINICAL


ABSTRACT mark as annex C and should form part and parcel of this
motion reveal what treatment was applied to the respondent.
BASED on the above background, respondent hereby institute this
MOTION TO NULLIFY THE COMPROMISE AGREEMENT dated October
14, 2015 between respondent Gregorio Vasquez Parreo and complainant
Romeo Chiu represented by his son Richard Chiu on the following grounds:
1. That respondent sense of judgement on that particular date was
distorted because of his MEDICAL CONDITION as per medical
certificate and clinical abstract mark as annex B and C issued by
Bacolod Adventist Medical Centre (BAMC);
2. That the Judgement of this Honorable Court if rendered based on
the compromise agreement done on October 14, 2015 without a
lawyer assisting the respondent would run counter to the Principle
of Fairness and Equity since the respondent sense of Judgement
was Distorted due to his Medical Condition;
3. That the respondent would be denied to his RIGHT TO
SUBSTANTIVE DUE PROCESS on the ground that he was not

able to represent his side intelligently because of his condition


(See annex B and C). He was disoriented on October 14, 2015
and his sense of Judgement was impaired. Therefore, his act on
that particular date would be considered NULL and VOID.
WHEREFORE, it is most respectfully prayed that the instant petition
be considered by the Honorable Court and further grant the respondent
other relief as shall be deemed just and equitable in the premises.
Bacolod City, Philippines, October 21, 2015.

GREGORIO V. PARREO
#5 Jasper Street, City Heights
Subdivision, Brgy. Taculing
Bacolod City

Copy furnished:

Atty. Karol Joseph P. Chiu

EXPLANATION:

Personal service

GREGORIO V. PARREO
#5 Jasper Street, City Heights
Subdivision, Brgy. Taculing
Bacolod City

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