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QUITCLAIM

KNOW ALL MEN BY THESE PRESENTS:

That I, Ferdinand Kupong, Filipino, of legal age, a resident of Jalandoni


Street. Barangay San Agustin, and formerly employed with Andoks Lechon, do
by these presents acknowledge receipt of the sum of 80,000.00, Philippine
Currency, from Andoks Lechon Inc. in full payment and final settlement of the
(financial assistance or separation pay, overtime pay, salary or salaries, wage or
wages, commutable sick and vacation leaves, gratuities or any kind of
compensation or emoluments) due to me or which may be due to me from
Andoks Lechon Inc. under the law or under any existing agreement with respect
thereto, as well as any and all claims of whatever kind and nature which I have
or may have against the company, arising from my employment with (and the
termination of my employment with Andoks Lechon Inc.

In consideration of said payment, I do hereby quitclaim, release,


discharge and waive any and all actions of whatever nature, expected, real or
apparent, which I may have against Andoks Lechon Inc., its directors, officers,
employees, agents and clients by reason of or arising from my employment with
the company. I will institute no action, whether civil, criminal, labor or
administrative against Andoks Lechon Inc., its directors, officers, employees,
agents and clients. Any and all actions which I may have commenced either
solely in my name or jointly with others before any office, board, bureau, court,
or tribunal against Andoks Lechon Inc., its directors, officers, employees, agents
and clients are hereby deemed and considered voluntary withdrawn by me and I
will no longer testify or continue to prosecute said action(s).

I declare that I have read this document and have fully understood its
contents. I further declare that I voluntarily and willingly executed this Release,
Waiver and Quitclaim with full knowledge of my rights under the law.
IN WITNESS WHEREOF, I have hereunto set my hand at, this 10 day of
February, 2019.

_______________________

Affiant

SIGNED IN THE PRESENCE OF

_______________________ ______________________

__________________
Re: Balance Due

Dear Sir/Madam:

Our firm is represented by Atty. Marcus Paguda. We have been retained by


Mrs. Lerona De Silva to collect your account which is seriously delinquent in
the amount of Php 100,000.00. As you know, you initially paid Php 30,000.00
for the services rendered on, December 2018 by check number 1234, after
signing a Statement of Satisfaction, but subsequently stopped payment on the
check. Copies of the Statement of Satisfaction and check number are
attached for your convenience. We know of no legitimate basis for you
stopping payment other than an attempt by to avoid paying a just
indebtedness.

We will give you an opportunity to pay the amount due before suit is filed;
however, payment must be made in strict accordance with the terms of this
letter. To avoid legal proceedings, full payment of the total amount due must
be received in our office within thirty (30) days after receipt of this letter.
Payment must be made in cash or certified funds. No partial payments will be
accepted. Other than this letter, no additional demands will be made upon
you to pay prior to suit being filed.

THIS IS AND ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION


OBTAINED WILL BE USED FOR THAT PURPOSE. Unless you contest the
validity of this indebtedness in writing, we will assume that the debt is valid.

If the total amount due is not paid to our office within thirty (30) days after
receipt this letter, suit may be filed. If litigation is necessary your company
may be liable for our attorney’s fees and all cost of court.

This is a serious matter which requires your immediate attention. We look


forward to receiving your prompt payment.

Sincerely,

Republic of the Philippines


National Capital Judicial Region
REGIONAL TRIAL COURT
Branch 1, Iloilo

PEOPLE OF THE PHILIPPINES,


Plaintiff,

-versus-

Crim Case No. 34569


Violation of City Ordinance
No. 5

Julio Man-Yak,
Defendant.

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

MOTION TO QUASH

Accused, by his undersigned attorney, respectfully moves to quash


the information filed against him on the ground that:

THIS HONORABLE COURT HAS NO JURISDICTION OF THE CASE.

ARGUMENTS

City Ordinance No. 5 imposes a maximum penalty of six (6) moths


imprisonment and Php 1,000.00 fine which is within the exclusive
jurisdiction of the City Court of Manila. Hence, this Court has no
jurisdiction over the instant case.

WHEREFORE, it is respectfully prayed that the information filed


against the accused be dismissed.
Other just and equitable reliefs are also prayed for.

Iloilo, 18 February 2019

Atty. Christie Joi C. Navallasca


Counsel for the Accused
IBP No. 81090; 2/18/19, Iloilo
Roll of Attorneys No: 9998