Professional Documents
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-versusCITY OF MUNTINLUPA,
Defendant,
x------------------------------------------------x
MEMORANDUM
PLAINTIFFS, through undersigned counsel, respectfully
submits this memorandum to wit:
Statement of the Case
This is an action for damages filed by the plaintiffs
based on Article 2176 of Civil Code, Quasi-Delict. Plaintiffs
allege that defendants negligence was the proximate cause
of the death of the deceased as represented by the plaintiffs.
The negligence, as the plaintiffs aver, was the failure of the
defendant to re-empty the septic tank of Muntinlupa Public
Market.
Defendant, on the other hand, argues otherwise.
Statement of Facts
1. On November 7, 2014, Sonveric Coquit, market master
of Muntinlupa Public market, filed a requisition request
with the Chief of Property of the City Treasurers Office
for the re emptying of the septic tank in Muntinlupa.
Yes.
Twice a week.
No.
Yes.
PPLM Chapter
Roll No. 09876
VERICSON D. QUITCO
PTR No. 0987654 01.03.12
Muntinlupa City
IBP No. 223344 01.29.12
PPLM Chapter
Roll No. 03456
VERICSON D. QUITCO
PTR No. 0987654 01.03.12
Muntinlupa City
IBP No. 223344 01.29.12
PPLM Chapter
Roll No. 03456