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REPUBLIC OF THE PHILIPPINES

National Capital Judicial Region


Regional Trial Court
Valenzuela City
Branch 14

IN THE MATTER OF THE APPLICATION FOR APPOINTMENT AS


NOTARY PUBLIC
Case No.: 18-309872

JOHN LENNON,
Petitioner.

x------------------------------------------------x

PETITION

Undersigned Petitioner and unto this Honorable Court, most


respectfully states that:

1. Petitioner is a Filipino citizen, over twenty-one years of age,


and a resident in the Philippines since birth and with office
address at Sage House Bldg., 1969 Abbey Road, Brgy.
Karuhatan, Valenzuela City;
2. Petitioner was admitted to the Philippine Bar on April 21, 2020
with Roll of Attorneys No. 102727. A photocopy of Petitioner’s
Certificate of Membership in the Philippine Bar issued by the
Office of the Bar Confidant is attached as Annex “A” of this
petition;
3. Petitioner is a lawyer in good standing with clearances from the
Office of the Bar Confidant of the Supreme Court and the
Integrated Bar of the Philippines, attached as Annexes “B” and
“C”;
4. Petitioner has not been convicted in the first instance of any
crime involving moral turpitude, nor charged in any
administrative case in connection with his present profession;
5. Petitioner has not yet applied nor been commissioned as Notary
Public in any other jurisdiction;
6. Petitioner is a registered member of the Integrated Bar of the
Philippines as supported by a photocopy of the Official Receipt
of yearly dues as of May 2020, attached as Annex “D”;
7. Petitioner has paid his Professional Tax Receipt for the year
2020 under Official Receipt No. 0808277 dated May 28, 2020 at
the City of Valenzuela, attached as Annex “E”;
8. Petitioner will submit all his notarial books and acknowledged
documents after the expiration of his notarial commission as
provided for by law;
9. Petitioner possesses all the qualifications and none of the
disqualifications for the office of Notary Public and have read,
understood and is willing to abide with the 2004 Rules on
Notarial Practice;
10. Petitioner is attaching as Annex “F”, a facsimile of his
notarial seal prepared in accordance with Section 2, Rule VII of
the 2004 Rules on Notarial Practice for approval of this
Honorable Court, together with three (3) specimens of his
official signature;
11. Also submitted are petitioner’s three (3) passport sized
colored photographs with light background, taken not more
than 30 days prior to the filing of this petition;

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of


this Honorable Court that:

1. The Petition for Commission as Notary Public filed by the


undersigned be acted favorably; and

2. Petitioner be commissioned as a Notary Public in the City of Manila.

July 21, 2020, City of Valenzuela.

JOHN LENNON
Petitioner

VERIFICATION AND CERTIFICATION OF NON-FORUM


SHOPPING

REPUBLIC OF THE PHILIPPINES)


CITY OF VALENZUELA ) S.S.

I, JOHN LENNON, Filipino, of legal age, residing at 1969 Abbey Road,


Brgy. Karuhatan, Valenzuela City, after being sworn to in accordance
with law, deposes and says that:

1. I am the Petitioner in the above-entitled petitioner;


2. The facts stated in the above complaint are true and correct to the
best of my knowledge and authentic records;
3. I have not commenced any action or filed any claim involving the
same issues in any court, tribunal or quasi-judicial agency and, to
the best of my knowledge, no such other action or claim is pending
in them; and
4. If I should learn that the same or similar action or claim has been
filed or is pending after its filing, I shall report that fact within
five (5) days from notice to the court or where the complaint or
initiatory pleading has been filed.

July 21, 2020, Valenzuela City, Philippines.

JOHN LENNON
Affiant

SUBSCRIBED AND SWORN TO before me this 26th day of July


2020 in Valenzuela City, Philippines, affiant exhibiting to me his
competent evidence of identity by way of Passport with number
XX0739639, issued at Manila, Philippines on March 14, 2014.

NOTARY PUBLIC

Doc. No.
Page No.
Book No.
Series of 2020.
LENNON MCCARTNEY AND ASSOCIATES LAW OFFICE
214 Penny Lane St., Brgy. Malinta, Valenzuela City
Tel. No.: 727-8446; Fax No.: 727-8448

27 June 2018

MS. YOKO ONO


Unit 2106-B Renaissance 3000 Condominium
Meralco Avenue
Ortigas Center, Pasig City

Dear Ms. Ono,

We write on behalf of our client, MR. ERIC CLAPTON, landlord


and owner of the condominium unit located at Unit 2106-B Renaissance
3000 Condominium, Meralco Avenue, Ortigas Center, Pasig City.

It has been THIRTY (30) DAYS since you received our letter dated
26 May 2018 and still, you have failed to pay and still refuses to pay
your rental arrears for THREE (3) MONTHS, which have now
amounted to NINETY-SIX THOUSAND PESOS (Php 96,000.00).

Please be reminded that our client has sent you several letters of
demand for you to pay your back rentals and to vacate the premises but
the same letters have been left unanswered. Consider this then, as our
client’s FINAL DEMAND for you to PAY YOUR ACCOUNT within
FIVE (5) DAYS from receipt and to VACATE THE UNIT and surrender
the said property, including the appurtenant keys, within FIFTEEN
(15) DAYS from receipt of this notice. Otherwise, our client shall be
constrained to commence suit to protect his interests.

Truly yours,

ATTY. GEORGE HARRISON


Lawyer for Client
REPUBLIC OF THE PHILIPPINES)
CITY OF SAN JUAN ) S.S.

AFFIDAVIT OF LOSS

I, LEBRON JAMES, of legal age, Filipino, single, and a resident of


23 Cleveland St., Greenhills San Juan City, Philippines, after having
been duly sworn in accordance with law, hereby depose and state that:

1. I am a duly-licensed driver in accordance with pertinent


Land Transportation laws, rules and regulations, and was issued a
corresponding Non-Professional Driver’s License with number N26-11-
007924 which is valid until April 21, 2025;
2. Sometime on May 19, 2018, said driver’s license was
misplaced and got lost;
3. Despite diligent search and efforts to locate the said driver’s
license, I could not find the same such that I believe that it is now lost
beyond recovery;

As such, I am executing this Affidavit of Loss to attest to the truth


of the foregoing and to support my application for the issuance of a new
Non-Professional Driver’s License, in lieu of the one that was lost.

IN WITNESS WHEREOF, I have hereunto set my hand this 28th


day of June 2018 in Manila, Philippines.

LEBRON JAMES
Affiant

SUBSCRIBED AND SWORN TO before me this 29th day of June


2018 in Manila, Philippines, affiant exhibiting to me his competent
evidence of identity by way of Passport with number XX0739639, issued
at Manila, Philippines on March 14, 2014.

NOTARY PUBLIC

Doc. No.
Page No.
Book No.
Series of 2018.
REPUBLIC OF THE PHILIPPINES)
CITY OF MANILA ) S.S.

AFFIDAVIT OF LOSS

I, KALYE IRVING, of legal age, Filipino, single, and a resident of


663 Firmeza St., Sampaloc, Manila, Philippines, after having been duly
sworn in accordance with law, hereby depose and state that:

1. On March 14, 2014, I was issued a Philippine Passport by


the Department of Foreign Affairs in Manila;
2. Sometime on May 26, 2018, said passport was misplaced and
got lost;
3. Recently, I had tried to look for the said passport but the
same could not be found;
4. Despite diligent search and efforts to locate the said
passport, I could not find the same such that I believe that it is now lost
beyond recovery;

As such, I am executing this Affidavit of Loss to attest to the truth


of the foregoing and to support my application for the issuance of a new
Philippine Passport, in lieu of the one that was lost.

IN WITNESS WHEREOF, I have hereunto set my hand this 28th


day of June 2018 in Manila, Philippines.

KALYE IRVING
Affiant

SUBSCRIBED AND SWORN TO before me this 29th day of June


2018 in Manila, Philippines, affiant exhibiting to me his competent
evidence of identity by way of SSS ID with number 33-8521644-7,
issued at Quezon City, Philippines on May 23, 2017.

NOTARY PUBLIC

Doc. No.
Page No.
Book No.
Series of 2018.
REPUBLIC OF THE PHILIPPINES)
CITY OF MANILA ) S.S.

AFFIDAVIT OF LOSS

I, REY PIÑOCO, of legal age, Filipino, single, and a resident of


666 Kalentong St., Mandaluyong City, Philippines, after having been
duly sworn in accordance with law, hereby depose and state that:

1. Sometime on May 26, 2018, I pawned my Rolex watch with


Cebuana Lhullier Pawnshop located at Shaw Boulevard, Mandaluyong
City and for which I was issued Receipt No. A257563631;
2. I kept the said pawnshop receipt in my wallet for
safekeeping but unfortunately my wallet got lost;
3. Despite diligent search and efforts to locate the said wallet
and pawnshop receipt, I could not find the same such that I believe that
they are lost beyond recovery;

As such, I am executing this Affidavit of Loss to attest to the truth


of the foregoing and to secure a duplicate or substitute copy of the
receipt and/or redeem the above described item which I pawned.

IN WITNESS WHEREOF, I have hereunto set my hand this 28th


day of June 2018 in Manila, Philippines.

REY PIÑOCO
Affiant

SUBSCRIBED AND SWORN TO before me this 29th day of June


2018 in Manila, Philippines, affiant exhibiting to me his competent
evidence of identity by way of SSS ID with number 33-8521644-7,
issued at Quezon City, Philippines on May 23, 2017.

NOTARY PUBLIC

Doc. No.
Page No.
Book No.
Series of 2018.
DEED OF ABSOLUTE SALE

KNOW ALL MEN BY THESE PRESENTS:

RYAN JAMES S. EDQUILAG, Filipino, single, of legal age, and


with residence and post-office address at 154-C Int. 1, Loreto St.,
Sampaloc, Manila, for and in consideration of the sum of TWO
MILLION FIVE HUNDRED THOUSAND PESOS (Php 2,500,000.00),
Philippine Currency, to him in hand paid by MA. ASUNCION S.
HERNANDEZ, Filipino, of legal age, with residence and post-office
address at Unit 1130, Studio Zen, 1811 Taft Avenue, Brgy. San Isidro,
Pasay City, DOES HEREBY SELL, TRANSFER, AND CONVEY unto
the said

MA. ASUNCION S. HERNANDEZ, her heirs and assigns, that


certain parcel of land, together with all the buildings and improvements
thereon belonging to the vendor and in present possession of RYAN
JAMES S. EDQUILAG, situated in Barangay Balatong, Laoag City,
Ilocos Norte, and more particularly described as follows:

“A parcel of land designated as Lot No. 711 covered by Tax


Declaration No. 2878; bounded on the North by Demetrio Solis
property; on the South by Philip John Padlan property; on the West by
Simon Antonio property; and on the East by Hospital site containing an
area of two thousand five hundred square meters (2,500 sq. m.) more or
less.”

That the land is assessed for the current year at TWO MILLION
PESOS (Php 2,000,000.00) as per Tax Declaration No. 2878, and the
buildings and/or improvements, at FIVE HUNDRED THOUSAND
PESOS (Php 500,000.00) as per Tax Declaration No. 3018, of the City
Assessor of Laoag;

The above-described real estate, not having been registered under


Act No. 496, nor under the Spanish Mortgage Law, the parties hereto
have agreed to register this instrument under the provisions of Section
194 of the Revised Administrative Code, as amended by Act No. 3344.

IN WITNESS WHEREOF, the parties hereto have signed this


deed of transfer this 4th day of July 2018, in the city of Manila,
Philippines.
RYAN JAMES S. EDQUILAG MA. ASUNCION S.
Vendor HERNANDEZ
Vendee

SIGNED IN THE PRESENCE OF:

______________________

______________________
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES)


CITY OF MANILA ) S.S.

BEFORE ME, this 5th day of July 2018 in the city of Manila,
personally appeared:

Name Competent Evidence of Identity Place and Date of Issue

RYAN JAMES S.
EDQUILAG ______________ ____________
MA. ASUNCION S.
HERNANDEZ ______________ ____________

known to me to be the same persons who executed the foregoing


instrument, and acknowledged that the same are their free act and
deed.

This instrument, consisting of three (3) pages, including the page


on which this acknowledgment is written, has been signed on the left
margin of each and every page thereof by the concerned parties and
their witnesses, and sealed with my notarial seal.

IN WITNESS WHEREOF, I have hereunto set my hand on the


date and place above written.

NOTARY PUBLIC
Doc. No. ____
Page No. ____
Book No. ____
Series of 2018.
DEED OF ABSOLUTE SALE

KNOW ALL MEN BY THESE PRESENTS:

RYAN JAMES S. EDQUILAG, Filipino, single, of legal age, and


with residence and post-office address at 154-C Int. 1, Loreto St.,
Sampaloc, Manila for and in consideration of the sum of THREE
MILLION PESOS (Php 3,000,000.00), Philippine Currency, to him in
hand paid by NIKKI LUZ C. FERNANDO, Filipino, of legal age, with
residence and post-office address at 2073 Gen. T. de Leon, Valenzuela
City, DOES HEREBY SELL, TRANSFER, AND CONVEY, absolutely
and unconditionally unto the said

NIKKI LUZ C. FERNANDO, her heirs and assigns, that certain


parcel of land, together with all the buildings and improvements
thereon belonging to the vendor and in present possession of RYAN
JAMES S. EDQUILAG, situated in BF Homes, Barangay Moonwalk,
Parañaque City, and more particularly described as follows:

“A parcel of land designated as Lot No. 37 covered by Transfer


Certificate of Title No. T-013492; bounded on the North by Cecilio de
Leon property; on the South by Cesar Castro property; on the West by
Juan Iñigo Suarez property; and on the East by the basketball court
containing an area of two thousand square meters (2,000 sq. m.) more
or less.”

of which I am the registered owner in fee simple in accordance with the


Property Registration Decree, my title thereto being evidenced by
Transfer Certificate of Title No. T-013492 issued by the Register of
Deeds of Parañaque City.

It is hereby mutually agreed that the vendee shall bear all the
expenses for the execution and registration of this deed of sale.
IN WITNESS WHEREOF, the parties hereto have signed this
deed of transfer this 4th day of July 2018, in the city of Parañaque,
Philippines.

RYAN JAMES S. EDQUILAG NIKKI LUZ C. FERNANDO


Vendor Vendee

SIGNED IN THE PRESENCE OF:

______________________

______________________
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES)


CITY OF PARAÑAQUE ) S.S.

BEFORE ME, this 5th day of July 2018 in the city of Parañaque,
personally appeared:

Name Competent Evidence of Identity Place and Date of Issue

RYAN JAMES S.
EDQUILAG ______________ ____________
NIKKI LUZ C.
FERNANDO ______________ ____________

known to me to be the same persons who executed the foregoing


instrument, and acknowledged that the same are their free act and
deed.

This instrument, consisting of three (3) pages, including the page


on which this acknowledgment is written, has been signed on the left
margin of each and every page thereof by the concerned parties and
their witnesses, and sealed with my notarial seal.

IN WITNESS WHEREOF, I have hereunto set my hand on the


date and place above written.

NOTARY PUBLIC
Doc. No. ____
Page No. ____
Book No. ____
Series of 2018.
DEED OF ABSOLUTE SALE

KNOW ALL MEN BY THESE PRESENTS:

RYAN JAMES S. EDQUILAG, Filipino, single, of legal age, and


with residence and post-office address at 154-C Int. 1, Loreto St.,
Sampaloc, Manila for and in consideration of the sum of FIVE
HUNDRED THOUSAND PESOS (Php 500,000.00), Philippine
Currency, HEREBY SELL, TRANSFER, AND CONVEY unto the said

BRENNIN MARK O. PEÑARANDA, his heirs and assigns, that


certain parcel of land, together with all the buildings and improvements
thereon, situated in Mambog II, Bacoor City, Cavite, and more
particularly described as follows:

“A parcel of land (Lot No. 1407-F, Psd-08-030924, being a portion


of Lot No. 1407, Bacoor City, Cavite), situated in the Rosal Street,
Bacoor City, Province of Cavite. Bounded on the SE, along line 1-2 by
Lot 1407-E, along line 2-3 by Lot 1407-D; on the SW, along line 3-4 by
Lot 1407-C; along line 4-5 by Lot 1407-B; along lines 5-6-7 by Lot 1407-
I, all of this subdivision survey; on the NW, along line 7-8 by Lot 1370;
on the NE, along 8-9 by Lot 1405, both Pls-1280-D, Bacoor City; along
lines 9-10-11 by Lot 1407-H; along line 13-14 by Lot 1405; on the SE,
along line 14-15 by Lot 1403, both Pls-1280-D, Bacoor City x x x
containing an area of five thousand five hundred square meters (5,500
sq. m.) more or less, covered by Transfer Certificate of Title No. T-18565
in the name of Ryan James S. Edquilag.”

The portion subject of this sale is described as follows:

“A portion of the above-described land, designated as Lot 1407-F-2


with an area of 250 square meters, more or less. Bounded on the North
by Lot 1407-F-3; on the South by Lot 1407-C; on the East by Lot 1407-
F-3 and on the West by Lot 1407-F-1; as per sketch plan prepared by
Geodetic Engr. Charles Andrew A. Genova which is made a part
thereof.”
of which parcel of land I am the lawful owner, free from all liens and
encumbrances;

That all legal redemptioners and pre-emptioners have been


notified of this sale but none is interested to buy;

That the above-described parcel of land is not tenanted and not


covered by Comprehensive Agrarian Reform Law;

This document may be registered in accordance with law.

IN WITNESS WHEREOF, the parties hereto have signed this


deed of transfer this 4th day of July 2018, in the city of Parañaque,
Philippines.

RYAN JAMES S. EDQUILAG BRENNIN MARK O.


Vendor PEÑARANDA
Vendee

SIGNED IN THE PRESENCE OF:

______________________

______________________
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES)


CITY OF PARAÑAQUE ) S.S.

BEFORE ME, this 5th day of July 2018 in the city of Parañaque,
personally appeared:

Name Competent Evidence of Identity Place and Date of Issue

RYAN JAMES S.
EDQUILAG ______________ ____________
BRENNIN MARK O.
PEÑARANDA ______________ ____________

known to me to be the same persons who executed the foregoing


instrument, and acknowledged that the same are their free act and
deed.

This instrument, consisting of three (3) pages, including the page


on which this acknowledgment is written, has been signed on the left
margin of each and every page thereof by the concerned parties and
their witnesses, and sealed with my notarial seal.

IN WITNESS WHEREOF, I have hereunto set my hand on the


date and place above written.

NOTARY PUBLIC
Doc. No. ____
Page No. ____
Book No. ____
Series of 2018.
CONTRACT TO SELL

KNOW ALL MEN BY THESE PRESENTS:

This Contract, made and executed on this 4th day of July 2018, at
Taguig City, Philippines, by and between:

GROVE STREET ENTERPRISES, INC., a corporation duly


organized and existing under and by virtue of Philippine laws, with
principal office at 315 Grove Street, Muñoz, Quezon City, Philippines,
herein represented by its President, CARL JOHNSON, and hereinafter
referred to as the “SELLER,”

-and-

GREGG POPOVICH, Filipino, of legal age, and with residence


and postal address at 1313 San Antonio St., Sampaloc, Manila,
hereinafter referred to as the “BUYER.”

WITNESSETH: THAT

WHEREAS, the SELLER is the absolute and registered owner of a


condominium unit consisting of TWO HUNDRED SQUARE METERS
(200 sq. m.), more or less, located at Unit 711 Renaissance 2000
Condominium, Meralco Avenue, Ortigas Center, Pasig City and covered
by Transfer Certificate of Title No. 15-002759741 issued by the Registry
of Deeds of Pasig City.

WHEREAS, the BUYER has offered to buy and the SELLER has
agreed to sell the above mentioned property under the terms and
conditions herein below set forth;

NOW THEREFORE, for and in consideration of the total sum of


FIVE MILLION PESOS (Php 5,000,000.00), Philippine currency, and of
the covenants, herein after set forth the SELLER agrees to sell and the
BUYER agrees to buy the aforesaid property subject to the following
terms and conditions:
1. The total consideration shall be FIVE MILLION PESOS
(Php 5,000,000.00), Philippine currency, payable as follows:

a) The amount of FOUR MILLION PESOS (Php 4,000,000.00),


representing earnest money shall be payable in cash by the
BUYER to the SELLER upon signing of this Contract to Sell;
b) The remaining balance of ONE MILLION PESOS (Php
1,000,000.00), shall be paid in cash on or before August 10,
2018.

2. Capital Gains Tax, Real Estate Tax, Association Dues, and


Broker’s Fees shall be for the account of the SELLER;

3. Documentary Stamps Tax, and all other miscellaneous fees


and expenses shall be to the account of the BUYER;

4. Possession to the subject property shall be delivered by the


SELLER to the BUYER upon full payment of the total consideration;

5. Upon full payment of the total price, the SELLER shall sign
and execute a DEED OF ABSOLUTE SALE in favor of the BUYER. The
SELLER shall likewise execute and/or deliver any and all documents,
including but not limited to the original copy of Transfer Certificate of
Title, Tax Declaration and all other documents necessary for the
transfer of ownership from SELLER to the BUYER.

IN WITNESS WHEREOF, the parties have hereunto affixed their


signatures, this 4th day of July 2018 at Taguig City, Philippines.

GROVE STREET ENTERPISES,


INC.
Seller

By:

CARL JOHNSON GREGG POPOVICH


President Buyer
TIN: 000-878-726 TIN: 000-789-913
SIGNED IN THE PRESENCE OF:

______________________

______________________
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES)


CITY OF MANILA ) S.S.

BEFORE ME, this 5th day of July 2018 in the city of Taguig,
personally appeared:

Name Competent Evidence of Identity Place and Date of Issue

CARL JOHNSON ______________ ____________


GREGG POPOVICH ______________ ____________

known to me to be the same persons who executed the foregoing


instrument, and acknowledged that the same are their free act and
deed.

This instrument, consisting of three (3) pages, including the page


on which this acknowledgment is written, has been signed on the left
margin of each and every page thereof by the concerned parties and
their witnesses, and sealed with my notarial seal.

IN WITNESS WHEREOF, I have hereunto set my hand on the


date and place above written.

NOTARY PUBLIC
Doc. No. ____
Page No. ____
Book No. ____
Series of 2018.
EASEMENT OF RIGHT OF WAY

KNOW ALL MEN BY THESE PRESENTS:

This AGREEMENT OF EASEMENT OF RIGHT OF WAY,


entered into this 6th day of July 2018, by and between RYAN JAMES S.
EDQUILAG, owner of the dominant estate, of legal age, single, and
resident of 154-C Int. 1, Loreto St., Sampaloc, Manila, and RICHARD
C. HEREDIA, owner of the servient estate, of legal age, married to
LARAMIE J. ESPADERO-HEREDIA, and resident of 2207 Moriones
St., Tondo, Manila.

WITNESSETH

That RYAN JAMES S. EDQUILAG is the owner of a parcel of


agricultural land located in the municipality of Gerona, province of
Tarlac, Philippines, and more particularly described as follows:

“A parcel of land located at Barangay Salapungan, Gerona, Tarlac.


Bounded in the north by the property of Manuel Siazon; in the east by
the property of Richard Heredia; in the south by the property of Carlos
Teodosio, Jr.; and in the west by the property of Luis Tria, with an area
of 620 square meters, more or less,”

which property is covered by TCT No. P-70737 of the Register of Deeds


of the province of Tarlac, which lot is adjacent to the property of the
abovementioned owner, and more particularly described as follows:

“A parcel of land located at Barangay Salapungan, Gerona, Tarlac.


Bounded in the north by the property of Manuel Siazon; in the east by
the property of Ramon Polangcos; in the south by the property of Delfin
Salamanca; and in the west by the property of Ryan James Edquilag,
with an area of 620 square meters, more or less,”

which property is covered by TCT No. P-70738 of the Register of Deeds


of the province of Tarlac;
That the owner of the dominant estate, in order to have an access
to and from, and to cultivate his above-mentioned land, and so as to
have an outlet to Gerona-Guimba Road, which is nearest public road
and least burdensome to the servient estate and to third persons, it
would be necessary for him to pass through the property of the owner of
the servient estate, and for this purpose, a path or passageway of not
less than two (2) meters wide through the whole length of the western
side of the latter’s property is necessary for the use of the former and for
all his needs in cultivating his estate;

That said path or passageway is particularly described in the


attached plan, Annex “A.”

WHEREFORE, for and in consideration of the sum of THREE


THOUSAND PESOS (Php 3,000.00), receipt whereof is hereby
acknowledged by RICHARD HEREDIA, the latter agrees and permits
RYAN JAMES EDQUILAG to have a permanent easement of right of
way over the abovementioned property of the former limited to not more
than two (2) meters wide throughout the whole length of the western
side of said property and as specifically indicated in the attached plan
which is made an integral part of this contract, as Annex “A.”

It is further agreed that the aforementioned owner of the servient


estate shall deliver unto the owner of the dominant estate all the
necessary papers, deeds, and titles in relation to the servient estate in
order to facilitate the registration of the abovementioned right of way,
in accordance with law.

This agreement shall be binding between the parties and upon all
their heirs, successors, and assigns.

IN WITNESS WHEREOF, the parties hereto have signed this


agreement the day and year first above written, in Tarlac City,
Philippines.

RYAN JAMES S. EDQUILAG RICHARD C. HEREDIA


SIGNED IN THE PRESENCE OF:

______________________

______________________
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES)


CITY OF TARLAC ) S.S.

BEFORE ME, this 9th day of July 2018 in the city of Tarlac,
personally appeared:

Name Competent Evidence of Identity Place and Date of Issue

RYAN JAMES S.
EDQUILAG ______________ ____________
RICHARD C. HEREDIA ______________ ____________

known to me to be the same persons who executed the foregoing


instrument, and acknowledged that the same are their free act and
deed.

This instrument, consisting of three (3) pages, including the page


on which this acknowledgment is written, has been signed on the left
margin of each and every page thereof by the concerned parties and
their witnesses, and sealed with my notarial seal.

IN WITNESS WHEREOF, I have hereunto set my hand on the


date and place above written.

NOTARY PUBLIC
Doc. No. ____
Page No. ____
Book No. ____
Series of 2018.
EXTRAJUDICIAL SETTLEMENT OF ESTATE

KNOW ALL MEN BY THESE PRESENTS:

This EXTRAJUDICIAL SETTLEMENT made and entered into by


and among:

JOHN PAUL GEORGE P. EDQUILAG, of legal age, married to


MARIA SHANELLE N. DEL CASTILLO, residing at Phase 1, Block 3,
Lot 17, Holiday Homes, Brgy. Biclatan, Gen. Trias City, Cavite;

RINGO P. EDQUILAG, of legal age, single, residing at 17


Springfield St., Governor’s Hills Subdivision, Brgy. Biclatan, Gen. Trias
City, Cavite;

JESSICA CAMILLE P. EDQUILAG, of legal age, single, residing


at 17 Springfield St., Governor’s Hills Subdivision, Brgy. Biclatan, Gen.
Trias City, Cavite; and

SAMANTHA MICHELLE P. EDQUILAG, of legal age, single,


residing at 17 Springfield St., Governor’s Hills Subdivision, Brgy.
Biclatan, Gen. Trias City, Cavite.

WITNESSETH

That the above-named parties, all of age, are the legitimate


children and sole heirs of RYAN JAMES S. EDQUILAG, who died in
the municipality of Capas, province of Tarlac, on 15 June 2018 without
any will;

That the said deceased, at the time of his death, left a certain real
property situated in Baguio City and more particularly described as
follows:

“A parcel of land located at Baguio-Bua-Itogon Road, Baguio City


with four (4) two-storey houses built herein. Bounded in the north is the
Outlook Drive South; in the east is the property of Lucia Cayabyab; in
the south is the Baguio-Bua-Itogon Road; and in the west is the Outlook
Drive South cor. Baguio-Bua-Itogon Road, with an area of 4,500 square
meters, more or less”

which real property is covered by Transfer Certificate of Title No. P-


37389 of the Register of Deeds of Baguio City;

That the said deceased, at the time of his death, left certain
personal properties, more particularly described as follows:
1. A golf cart with License Plate No. AAS 1073, located in
Baguio City;
2. A blue Mercedes Benz, Sedan E-class with License Plate No.
AJS 4977, located in Gen. Trias City, Cavite; and
3. A lime green Mini Hatch with License Plate No. AKA 5575,
located in Gen. Trias City, Cavite.

That to the best knowledge and information of the parties hereto,


the said deceased left no debts;

That a true copy of this extrajudicial settlement had been


published once a week for three consecutive weeks in Philippine Daily
Inquirer, a newspaper of general circulation in Makati City; as certified
by the said newspaper hereto attached as Annex “A”;

That the parties hereto being all of legal age and with full civil
capacity to contract, hereby by these presents, agree to divide and
adjudicate, as they hereby divide and adjudicate, among themselves,
the above-described real estate in the manner following:

To JOHN PAUL GEORGE P. EDQUILAG, 25 years of age, the


following:

1. The 1,000 square meter house located at the east portion of


the Baguio City property; and
2. A golf cart with License Plate No. AAS 1073, located in the
same city above-mentioned.

To RINGO P. EDQUILAG, 23 years of age, the following:

1. The 250 square meter house located at the west portion of


the Baguio City property.

To JESSICA CAMILLE P. EDQUILAG, 21 years of age, the


following:

1. The 500 square meter house located at the north portion of


the Baguio City property; and
2. The blue Mercedes-Benz Sedan E-class with License Plate
No. AJS 4977, located in Gen. Trias City, Cavite.

To SAMANTHA MICHELLE P. EDQUILAG, 21 years of age, the


following:

1. The 500 square meter house located at the north portion of


the Baguio City property; and
2. The blue Mercedes-Benz Sedan E-class with License Plate
No. AJS 4977, located in Gen. Trias City, Cavite.

IN WITNESS WHEREOF, the parties hereto have signed their


names unto this document this 6th day of July 2018 in Kawit, Cavite,
Philippines.

JOHN PAUL GEORGE P. JESSICA CAMILLE P.


EDQUILAG EDQUILAG

RINGO P. EDQUILAG SAMANTHA MICHELLE P.


EDQUILAG

SIGNED IN THE PRESENCE OF:

______________________

______________________
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES)


PROVINCE OF CAVITE ) S.S.
MUNICIPALITY OF KAWIT )

BEFORE ME, this 9th day of July 2018, in the municipality of


Kawit, province of Cavite, personally appeared:

Name Competent Evidence of Identity Place and Date of Issue

JOHN PAUL GEORGE P.


EDQUILAG ______________ ____________
RINGO P. EDQUILAG ______________ ____________
JESSICA CAMILLE P.
EDQUILAG ______________ ____________
SAMANTHA MICHELLE P.
EDQUILAG ______________ ____________

known to me to be the same persons who executed the foregoing


instrument, and acknowledged that the same are their free act and
deed.

This instrument, consisting of four (4) pages, including the page


on which this acknowledgment is written, has been signed on the left
margin of each and every page thereof by the concerned parties and
their witnesses, and sealed with my notarial seal.

IN WITNESS WHEREOF, I have hereunto set my hand on the


date and place above written.

NOTARY PUBLIC
Doc. No. ____
Page No. ____
Book No. ____
Series of 2018.
AFFIDAVIT

REPUBLIC OF THE PHILIPPINES)


CITY OF MUNTINLUPA ) S.S.

I, BARRY P. EDQUILAG, of legal age, single, and now residing at


Baguio-Bua-Itogon Road cor. Outlook Drive South, Baguio City,
Philippines, after having been sworn in accordance with law, depose
and say:

1. That I am the only surviving son of RINGO P. EDQUILAG,


who died intestate, in the municipality of Sagada, Mountain Province,
Philippines on 3 July 2018, as evidenced by Death Certificate issued by
the St. Theodore’s Hospital, Sagada, Mountain Province hereto attached
as Annex “A” and made an integral part of this Affidavit;
2. That said deceased left an estate consisting of a parcel of
land with a two-storey house measuring 250 square meters located in
the city of Baguio and evidenced by Transfer Certificate of Title No. P-
98262 of the Registry of Deeds of Baguio City;
3. That the said property is more particularly described as
follows:

“A parcel of land with a two-storey house located at Baguio-Bua-


Itogon Road cor. Outlook Drive South, Baguio City being a portion of
the consolidation of Lots 2516-A, 2516-B, 2516-C, and 2516-D (Lot No.
2516-C is the property described herein) (LRC) Psd-71723, Lot 2, Psd-
85922, Lot 4, Psd-107290, LRC Rec. Nos. N-56898, 82191, 49136, N-
41478, N-28755, 86144, and 92878. Bounded on the north by the
Outlook Drive South; on the east by the properties of Jessica Camille
Edquilag and Samantha Michelle Edquilag; on the south by the Baguio-
Bua-Itogon Road; and on the west by the Outlook Drive South, with an
area of 250 square meters, more or less.”

4. That said deceased left no debts;


5. That the net value of said estate is not more than three
thousand pesos (Php 3,000.00), and is therefore exempt from the estate
and inheritance taxes, as evidenced by a certificate of exemption issued
by the Bureau of Internal Revenue hereto attached as Annex “B” and
made an integral part of this affidavit;
6. That pursuant to Rule 74, Section 1 of the Rules of Court, I
hereby adjudicate unto myself the above described real estate by means
of this Affidavit and hereby files the same with the Register of Deeds of
Baguio City with the request that said adjudication be made effective
without judicial proceedings as prescribed by the aforementioned Rules
of Court.

IN WITNESS WHEREOF, I have hereunto set my hand this 6th


day of July 2018 in Manila, Philippines.

BARRY P. EDQUILAG
Affiant

SUBSCRIBED AND SWORN TO before me this 9th day of July


2018 in Manila, Philippines, affiant exhibiting to me his competent
evidence of identity by way of Passport with number XX0927156, issued
at Manila, Philippines on June 30, 2018.

NOTARY PUBLIC

Doc. No.
Page No.
Book No.
Series of 2018.
VERIFICATION AND CERTIFICATION OF NON-FORUM
SHOPPING

REPUBLIC OF THE PHILIPPINES)


CITY OF PASIG ) S.S.

I, RYAN JAMES S. EDQUILAG, Filipino, of legal age, residing at


154-C Int. 1, Loreto St., Sampaloc, Manila, after being sworn to in
accordance with law, deposes and says that:

1. I am the plaintiff in the above-entitled case;


2. The facts stated in the above complaint are true and correct
to the best of my knowledge and authentic records;
3. I have not commenced any action or filed any claim involving
the same issues in any court, tribunal or quasi-judicial agency and, to
the best of my knowledge, no such other action or claim is pending in
them; and
4. If I should learn that the same or similar action or claim has
been filed or is pending after its filing, I shall report that fact within
five (5) days from notice to the court or where the complaint or
initiatory pleading has been filed.

July 12, 2018, Pasig City, Philippines.

RYAN JAMES S. EDQUILAG


Affiant

SUBSCRIBED AND SWORN TO before me this 12th day of July


2018 in Pasig City, Philippines, affiant exhibiting to me his competent
evidence of identity by way of Passport with number XX0739639, issued
at Manila, Philippines on March 14, 2014.

NOTARY PUBLIC

Doc. No.
Page No.
Book No.
Series of 2018.
SPECIAL POWER OF ATTORNEY

KNOW ALL MEN BY THESE PRESENTS:

I, SWEET JOHNSON, of legal age, single, Filipino, with residence


at 426 Prudencio St., Sampaloc, Manila, do hereby appoint, name and
constitute NICO BELLIC, likewise of legal age, single, with postal
address at 927 Prudencio St., Sampaloc, Manila, as my true and legal
representative to act for and in my name and stead and to receive for
and in my behalf my salary from my employer GROVE STREET
ENTERPRISES, INC., represented by its President, CARL JOHNSON.

I hereby grant my representative full power and authority to


execute and perform every act necessary to render effective the power to
compromise as though I myself have so performed it and hereby
approving all that he may do by virtue of these presents.

IN WITNESS WHEREOF, I have hereunto affixed my signature


this 11th day of July, 2018 at Manila, Philippines.

SWEET JOHNSON
Principal

CONFORME:

NICO BELLIC
Attorney-in-Fact

SIGNED IN THE PRESENCE OF:

__________________ _________________

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES)


CITY OF MANILA ) S.S.
BEFORE ME, this 12th day of July 2018 in the city of Manila,
personally appeared:

Name Competent Evidence of Identity Place and Date of Issue

SWEET JOHNSON ______________ ____________


NICO BELLIC ______________ ____________

known to me to be the same persons who executed the foregoing


instrument, and acknowledged that the same are their free act and
deed.

This instrument, consisting of two (2) pages, including the page on


which this acknowledgment is written, has been signed on the left
margin of each and every page thereof by the concerned parties and
their witnesses, and sealed with my notarial seal.

IN WITNESS WHEREOF, I have hereunto set my hand on the


date and place above written.

NOTARY PUBLIC
Doc. No. ____
Page No. ____
Book No. ____
Series of 2018.
REPUBLIC OF THE PHILIPPINES
National Capital Judicial Region
Metropolitan Trial Court
Branch 12
Valenzuela City

PAUL MCCARTNEY,
Plaintiff,
-versus- Civil Case No. 18-318926
JIM MORRISON, For: Reconveyance of real
Defendant. property, Annulment of deed of
sale, and Accounting of income of
property with damages
x-----------------------------------x

MOTION FOR APPROVAL OF COMPROMISE


AGREEMENT

The parties respectfully allege that:

1. Plaintiff filed this claim against defendant for:

Php 3,000,000.00 Collection of sum of money


750,000.00 Damages
0.00 Civil aspect of criminal case
0.00 Enforcement of barangay agreement
1,500,000.00 Recovery of personal property

2. The parties have come to an amicable settlement and have


executed a compromise agreement with the following terms and
conditions:

a. Plaintiff shall be paid the sum of FOUR MILLION PESOS


(P4,000,000.00) in accordance with the following schedule:

1. Initial payment - TWO MILLION PESOS (P2,000,000.00)


shall be paid to the plaintiff by defendant AGDIPA upon the
signing and due execution of this Compromise Agreement,
Provided, however, that the initial payment
by defendant MORRISON shall be delivered into the custody
and possession of a third party, Atty. John Lennon, who
shall act as escrow-trustee of the parties and who shall only
deliver the said initial payment to the plaintiff through
plaintiff’s counsel upon the filing in Court of this
Compromise Agreement.

2. The balance of TWO MILLION PESOS (P1,000,000.00)


shall be paid by defendant MORRISON as follows:

Second payment - ONE MILLION PESOS


(P1,000,000.00) within sixty (60) days after the date of the
first payment.

Third payment - ONE MILLION PESOS (P1,000,000.00)


within forty-five (45) days after the date of the second
payment.

b. The initial payment by defendant MORRISON shall be made in


cash. The two payments on the balance shall be covered by post-
dated checks drawn by defendant MORRISON as payable to
ATTY. RINGO STARR who shall hold and account for said
payments in trust for plaintiff MCCARTNEY.

3. The parties agree that the approval of this agreement by the


Court shall put an end to this litigation, except for purposes of
execution in case of default.

WHEREFORE, premises considered, the parties respectfully pray


that the Court approve this agreement and render judgment on the
basis thereof.

PAUL MCCARTNEY
Plaintiff

JIM MORRISON
Defendant
REPUBLIC OF THE PHILIPPINES)
CITY OF MANDALUYONG ) S.S.

COMPLAINT-AFFIDAVIT

I, BRYAN ADAMS, of legal age, Filipino, and a resident of 69


Summer Lane, Brgy. Addition Hills, Mandaluyong City, after having
been sworn to in accordance with law hereby depose and state:

1. That I am accusing JUSTIN BIEBER, a resident of 327


Samal St., Mandaluyong City of THEFT;
2. That on June 30, 2018, at my residence, we are having a
thanksgiving party for my cousin who passed the entrance test at
Harvard University, in which JUSTIN BIEBER (Justin) and I were
present;
3. That on the same date, Justin asked me where the toilet was
and I gave him directions to go there;
4. That when I went to the toilet after Justin left, I realized
that my iPhone X cellular phone worth SEVENTY THOUSAND PESOS
(Php 70,000.00) which I left at the toilet cabinet was missing;
5. That in order to recover my phone, I asked Justin if he had
my phone with him, but he said the phone was not with him;
6. That on the next day, we met at the waiting shed in Shaw
Blvd., near Jose Rizal University when I saw Justin holding an iPhone
X cellular phone which is exactly similar with my missing phone;
7. That on that same day, I asked Justin to return the phone
but he insisted that the said phone is his which he bought two weeks
ago and he rarely used that;
8. That I referred the incident to the barangay for mediation
proceedings but Justin refused to obey the summons sent to him.
Hence, I was advised by the barangay secretary who happens to be a
lawyer to file a criminal action against Justin, after I was issued a
certificate to file action by the barangay;
9. In view of the foregoing, I am executing this Affidavit to
support the filing of a criminal case for theft against JUSTIN BIEBER.
IN WITNESS WHEREOF, I have hereunto set my hand this 16th
day of July 2018, in the city of Manila, Philippines.

BRYAN ADAMS
Affiant

SUBSCRIBED AND SWORN TO before me this 16th day of July


2018 in Mandaluyong City, Philippines. I hereby certify that I have
personally examined the affiant and I am satisfied that he fully
understood and voluntarily executed his complaint-affidavit.

ATTY. EMI NEM


Assistant City Prosecutor
REPUBLIC OF THE PHILIPPINES
National Capital Judicial Region
Metropolitan Trial Court
Branch 6
Mandaluyong City

PEOPLE OF THE PHILIPPINES,


Plaintiff,
-versus- Criminal Case No. 18-350127
JUSTIN BIEBER, For: Theft
Accused.
x-----------------------------------x

INFORMATION

The undersigned Prosecutor accuses JUSTIN BIEBER of the


crime of theft, committed as follows:

That on or about June 30, 2018 in the city of Mandaluyong,


Philippines, within the jurisdiction of this court, the said accused did
then and there willfully, unlawfully and feloniously, with intent to gain
and without consent of the owner thereof, take, steal, and carry away
the following personal property belonging to one, BRYAN ADAMS to
wit: an iPhone X cellular phone, of the total value of SEVENTY
THOUSAND PESOS (Php 70,000.00), Philippine currency.

CONTRARY TO LAW.

Manila, Philippines, July 17, 2018.

ATTY. EMI NEM


Assistant City Prosecutor

APPROVED:

ATTY. PEPE SMITH


City Prosecutor

I HEREBY CERTIFY that I have conducted a preliminary


investigation in this case in accordance with law; I have, or as shown by
the record, an authorized officer has personally examined complainant
and its witnesses; that on the basis of the sworn statements and other
evidence submitted before me there is reasonable ground to believe that
the crime has been committed and accused is probably guilty thereof;
that accused was informed of the complaint and of the evidence
submitted against him and was given the opportunity to submit
controverting evidence. I further certify that the filing of this
Information is upon prior written authority or approval of the City
Prosecutor.

ATTY. LENIN KING F. TOLENTINO


Assistant City Prosecutor

SUBSCRIBED AND SWORN TO before me this 17th day of July


2018 at Manila.

ATTY. JHOROLAR N. ANDRES


Senior Assistant City Prosecutor

Witnesses:
1. Bryan Adams – 69 Summer Lane, Brgy. Addition Hills,
Mandaluyong City.
2. Atty. John Legend – Barangay Secretary – Barangay Addition
Hills, Mandaluyong City.
3. And others.

BAIL RECOMMENDED: TWENTY-FIVE THOUSAND PESOS (Php


25,000.00)

Enclosure: Complaint-Affidavit of Bryan Adams


REPUBLIC OF THE PHILIPPINES
National Capital Judicial Region
Metropolitan Trial Court
Branch 6
Mandaluyong City

PEOPLE OF THE PHILIPPINES,


Plaintiff,
-versus- Criminal Case No. 18-350127
JIM MORRISON, For: Theft
Accused.
x-----------------------------------x

MOTION FOR REDUCTION OF BAIL

Accused JIM MORRISON, unto this Honorable Court respectfully


states that:

1. The accused has been charged with the crime of Theft before
this Honorable Court and the bail recommended for this provisional
liberty is Twenty-Five Thousand Pesos (Php 25,000.00);
2. Accused desires to post the required bail but due to financial
constraints considering that he is jobless and is only depending upon
his father, he can only raise the amount of Ten Thousand Pesos (Php
10,000.00).

WHEREFORE, in view of the foregoing, it is most respectfully


prayed that Accused be allowed to post his bail bond for the above case
at a reduced CASH BOND in the total amount of Ten Thousand Pesos
(Php 10,000.00).

Manila, Philippines, July 17, 2018.

JIM MORRISON
Accused

Copy furnished:

ATTY. PEPE SMITH


Office of the City Prosecutor
Mandaluyong City

BRYAN ADAMS
69 Summer Lane, Brgy. Addition Hills, Mandaluyong City.
REPUBLIC OF THE PHILIPPINES
First Judicial Region
Municipal Trial Court
Branch 5
Baguio City

JESSICA CAMILLE P. EDQUILAG,


Plaintiff,
-versus- Civil Case No. 18-042756
BRIAN V. SEGISMUNDO and, For: Forcible entry
BEA ROSE V. SEGISMUNDO,
Defendants.
x-----------------------------------x

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and


unto this Honorable Court, most respectfully avers that:

1. The plaintiff is of age and a resident of 4 Baguio-Bua-Itogon


Road cor. Outlook Drive South, Baguio City, Philippines;
2. Defendants are of age, Filipinos, with residence at 128
Tangerine St., Zenaida II Subdivision, Concepcion Uno, Marikina City,
where they may be served with summons and other court processes;
3. The plaintiff is the absolute owner of a fenced strawberry
farm located in 4 Baguio-Bua-Itogon Road cor. Outlook Drive South,
Baguio City;
4. Sometime in June 27, 2018, defendants, forcefully destroyed
the fence surrounding the said property, and cleared the property from
the seventy (70) strawberry shrubs planted therein to build their
shanties without any authorization nor consent from the plaintiff;
5. Despite repeated demands to vacate the premises,
defendants continued to occupy the subject property, thereby depriving
the plaintiff of lawful possession thereof; and
6. As a result of the defendants’ unlawful occupation of the
property, plaintiff suffered actual damages of ONE HUNDRED SIXTY
THOUSAND PESOS (Php 160,000.00), representing the value of the
fence and the strawberry shrubs. Receipts for the construction of the
fence, as well as the expenses incurred in maintaining and
rehabilitating the strawberry shrubs are here attached as Annexes “A”,
“B-1”, and “B-2”.
WHEREFORE, premises considered, it is respectfully prayed unto
this Honorable Court that, after due hearing, judgment be rendered in
favor of the plaintiff.

a. For the restitution of the abovementioned premises; and


b. For the payment of damages, attorney’s fees and costs of
suit.

Other reliefs just and equitable are likewise prayed for.

City of Baguio, Philippines, July 16, 2018

LENNON MCCARTNEY AND ASSOCIATES LAW OFFICE


Counsel for the Plaintiff
214 Penny Lane St., Brgy. Malinta, Valenzuela City

By:

JOHN LENNON
Roll of Attorneys No. 107136
IBP No. 795004/20 April 2018/Pasig City
PTR No. 2950426/24 April 2018/Manila
MCLE Compliance No. V-0014727/25 June 2018

VERIFICATION AND CERTIFICATION OF NON-FORUM


SHOPPING

REPUBLIC OF THE PHILIPPINES)


CITY OF PASIG ) S.S.

I, JESSICA CAMILLE P. EDQUILAG, Filipino, of legal age,


residing at 4 Baguio-Bua-Itogon Road cor. Outlook Drive South, Baguio
City, after being sworn to in accordance with law, deposes and says
that:

5. I am the plaintiff in the above-entitled case;


6. The facts stated in the above complaint are true and correct
to the best of my knowledge and authentic records;
7. I have not commenced any action or filed any claim involving
the same issues in any court, tribunal or quasi-judicial agency and, to
the best of my knowledge, no such other action or claim is pending in
them; and
8. If I should learn that the same or similar action or claim has
been filed or is pending after its filing, I shall report that fact within
five (5) days from notice to the court or where the complaint or
initiatory pleading has been filed.

July 16, 2018, Pasig City, Philippines.

JESSICA CAMILLE P. EDQUILAG


Affiant

SUBSCRIBED AND SWORN TO before me this 17th day of July


2018 in Pasig City, Philippines, affiant exhibiting to me his competent
evidence of identity by way of Passport with number XX0971748, issued
at Manila, Philippines on May 24, 2017.

NOTARY PUBLIC

Doc. No.
Page No.
Book No.
Series of 2018.
REPUBLIC OF THE PHILIPPINES
National Capital Judicial Region
Metropolitan Trial Court
Branch 4
Manila

RICHARD C. HEREDIA,
Plaintiff,
-versus- Civil Case No. 18-318926
MARK NIÑO I. SERRANO, For: Unlawful detainer
Defendant.
x-----------------------------------x

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and


unto this Honorable Court, most respectfully avers that:

7. The plaintiff is of age and a resident of 2207 Moriones St.,


Tondo, Manila while the defendant is also of age, with residence at 864
Pedro Gil St., Paco, Manila, where he may be served with summons and
other court processes;
8. The plaintiff is the absolute owner and lessor of a certain
building located at 1524 M. dela Fuente St., Sampaloc, Manila,
currently being leased and occupied by the defendant;
9. The defendant leases and occupies the said building under
the express obligation of paying a monthly rent of TWENTY
THOUSAND PESOS (Php 20,000.00). Payable within the first five (5)
days of each month;
10. The defendant has failed to pay the rents for the months of
May, June and July, which amounts to SIXTY THOUSAND PESOS
(Php 60,000,00);
11. Without any legal justification, defendant continuously
refuses to pay the said amount despite repeated oral and written
demands. A final demand letter was sent and received personally by
defendant on July 6, 2018, or more than five (5) days before the filing of
this complaint. A copy of the final demand letter to pay the arrears and
to vacate the premises is here attached as Annex “A”.

WHEREFORE, premises considered, it is respectfully prayed unto


this Honorable Court that, after due hearing, judgment be rendered in
favor of the plaintiff.

c. For the restitution of the abovementioned premises; and


d. For the payment of ONE HUNDRED THOUSAND PESOS
(Php 100,000.00), representing the arrears of rent now overdue, with
legal interest from the filing of this complaint, and costs of suit.

Other reliefs just and equitable are likewise prayed for.

City of Manila, Philippines, July 16, 2018

LENNON MCCARTNEY AND ASSOCIATES LAW OFFICE


Counsel for the Plaintiff
214 Penny Lane St., Brgy. Malinta, Valenzuela City

By:

PAUL MCCARTNEY
Roll of Attorneys No. 107137
IBP No. 792145/15 April 2018/Manila
PTR No. 292748/18 April 2018/Manila
MCLE Compliance No. V-0014726/25 June 2018

VERIFICATION AND CERTIFICATION OF NON-FORUM


SHOPPING

REPUBLIC OF THE PHILIPPINES)


CITY OF PASIG ) S.S.

I, RICHARD C. HEREDIA, Filipino, of legal age, residing at 2207


Moriones St., Tondo, Manila, after being sworn to in accordance with
law, deposes and says that:

9. I am the plaintiff in the above-entitled case;


10. The facts stated in the above complaint are true and correct
to the best of my knowledge and authentic records;
11. I have not commenced any action or filed any claim involving
the same issues in any court, tribunal or quasi-judicial agency and, to
the best of my knowledge, no such other action or claim is pending in
them; and
12. If I should learn that the same or similar action or claim has
been filed or is pending after its filing, I shall report that fact within
five (5) days from notice to the court or where the complaint or
initiatory pleading has been filed.

July 16, 2018, Pasig City, Philippines.


RICHARD C. HEREDIA
Affiant

SUBSCRIBED AND SWORN TO before me this 16th day of July


2018 in Pasig City, Philippines, affiant exhibiting to me his competent
evidence of identity by way of Passport with number XX0814975, issued
at Manila, Philippines on November 24, 2015.

NOTARY PUBLIC

Doc. No.
Page No.
Book No.
Series of 2018.
REPUBLIC OF THE PHILIPPINES
National Capital Judicial Region
Regional Trial Court
Branch 13
Pasay City

IN THE MATTER OF THE ADOPTION OF THE MINOR BILLIE


JEAN C. HERNANDEZ.

MA. ASUNCION S. HERNANDEZ, Special Proc. No. 18-029612


Petitioner. For: Adoption
x-----------------------------------------------x

JUDICIAL AFFIDAVIT OF
PETITIONER MA. ASUNCION S. HERNANDEZ

I, MA. ASUNCION S. HERNANDEZ, of legal age, living at Unit


1130 Studio Zen, Taft Avenue, Brgy. San Isidro, Pasay City, a petitioner
in this case, state under oath as follows:

PRELIMINARY STATEMENT

The person examining me is ATTY. RYAN JAMES S. EDQUILAG


with office address at Baysa, Ariston, Bawalan, and Edquilag (BABE)
Law Offices, Unit 106 Champagne Building 2, St. Josemaria Escriva
Drive, Pasig City. The examination is being held at the same address. I
am answering his questions fully conscious that I do so under oath and
may face criminal liability for false testimony and perjury.

PURPOSE: This Judicial Affidavit of the petitioner MA. ASUNCION


S. HERNANDEZ is being offered as evidence for the petitioner to prove
the following:

1. That the petitioner Ma. Asuncion S. Hernandez complied all the


requirements provided under the law, making her eligible for the
adoption of minor Billie Jean C. Hernandez.
2. All other related matters, facts and circumstances relevant and
material to this case.

1. Q: Do you know why you are here?

A: Yes. I am here to give a sworn statement by way of a


judicial affidavit, which constitutes as my direct testimony,
in the case for adoption.
2. Q: In what language do you want to be asked?

A: In English.

3. Q: State your name and personal circumstances.

A: My name is Ma. Asuncion S. Hernandez, I am 23 years


old, and residing at Unit 1130 Studio Zen, Taft Avenue,
Brgy. San Isidro, Pasay City.

4. Q: What is your civil status?

A: I am single.

5. Q: What is your occupation?

A: I am an owner and general manager of April Fool’s


Restaurant located at Gil Puyat Avenue cor. Dian St.,
Makati City.

6. Q: How much does your restaurant earn monthly?

A: About P40,000.00 to P65,000.00 a month.

7. Q: What is your relation to the adoptee Billie Jean C.


Hernandez?

A: I am her aunt. She is the only daughter of my elder


brother Arnulfo S. Hernandez.

8. Q: How old is Billie Jean C. Hernandez?

A: She is eleven (11) months old.

9. Q: What is her date of birth?

A: She was born on August 5, 2017.

10. Q: Where was the place of her birth?

A: At the Far Eastern University – Dr. Nicanor Reyes


Medical Foundation Hospital in Novaliches, Quezon City.
11. Q: Who are the biological parents of the adoptee Billie Jean
C. Hernandez?

A: Arnulfo S. Hernandez, my elder brother and Anabelle C.


Hernandez.

12. Q: Where are the biological parents of the adoptee Billie


Jean C. Hernandez?

A: They both died in a plane crash about seven (7) months


ago when she was about five (5) months old.

13. Q: Where did the plane crash occurred?

A: Along Perth, Australia.

14. Q: When did it happened?

A: On January 23, 2018, early in the evening, Philippine


time.

15. Q: Where was their last known residence before their


deaths?

A: In Batasan Hills, Quezon City.

16. Q: Are there any proceedings initiated within six (6) months
upon the death of the biological parents?

A: There are none.

17. Q: Why do you want to adopt Billie Jean C. Hernandez?

A: Because both her parents had already died and there


being no other relatives remaining, no one can take care of
her aside from me, being the only remaining relative she
have.

18. Q: Are you convicted of any crime involving moral turpitude?

A: No. Even there are no cases filed against me in any court.

No further questions.

IN WITNESS WHEREOF, I have hereunto set my hand this 25th day


of July 2018 here in the City of Pasay.
MA. ASUNCION S. HERNANDEZ
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in


and for the City of Pasay this 26th day of July 2018. Affiant personally
came and appeared with Passport Number XX0972167, bearing her
photograph and signature, known to me as the same person who
personally signed the foregoing instrument before me and avowed
under penalty of law to the whole truth of the contents of said
instrument.

NOTARY PUBLIC

Doc. No.
Page No.
Book No.
Series of 2018.

ATTESTATION

I, RYAN JAMES S. EDQUILAG, of legal age, Filipino, single, with


office address at Baysa, Ariston, Bawalan, and Edquilag (BABE) Law
Offices, Unit 106 Champagne Building 2, St. Josemaria Escriva Drive,
Pasig City, on oath depose and state that:

I was the lawyer who conducted the examination of the petitioner


MA. ASUNCION S. HERNANDEZ at my aforementioned office in Pasig
City;

I have faithfully recorded or caused to be recorded the questions I


asked and the corresponding answer that the witness gave;

I nor any other person then present or assisting her coached the
witness regarding her answers;

IN WITNESS WHEREOF, I have hereunto set my hand this 25th


day of July 2018 at the City of Pasay.

ATTY. RYAN JAMES S. EDQUILAG


SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in
and for the City of Pasay this 26th day of July 2018. Affiant personally
came and appeared with Passport Number XX0739639, bearing his
photograph and signature, known to me as the same person who
personally signed the foregoing instrument before me and avowed
under penalty of law to the whole truth of the contents of said
instrument.

NOTARY PUBLIC

Doc. No.
Page No.
Book No.
Series of 2018.

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