Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 69,
Quezon City

CAPTAIN AMERICA,
Plaintiff,

-versus-
Civil Case No. R-QZN-17-08383-
CV
For: Partition of Co-Ownership,
Recovery of Properties.

IRON MAN,
Defendant.
x-----------------------------------------x

MANIFESTATION

Plaintiff, CAPTAIN AMERICA, through counsel and unto this

Honorable Court, most respectfully states:

1. In support of the allegations made by the plaintiff Captain

America in his Judicial Affidavit that defendant Iron Man indeed
employed fraudulent schemes in running the businesses she and
plaintiff jointly owned, the plaintiff on 06 February 2019 made an
ocular inspection to the service bay/depot site (“site”) of their
transport business Pinetree located in Commonwealth, Quezon City.
To plaintiff’s surprise, he saw three (3) men in the act of dismantling
and wrecking the buses commonly known as “kinakahoy” in the
transport business parlance found within the perimeter of the said site
while the other one was outside the perimeter. When plaintiff asked
for their names and the reason for their actions considering the
subject buses are under litigation, the men replied they were just
following the orders of a certain “Bossman” but failed to disclose their
names.

2. The plaintiff being fully aware that he has no colour of

authority to prevent the men in finishing their tasks; the plaintiff went
to the Barangay Hall to report the incident. A copy of the Blotter
Report is herein attached as Annex “A”. Since the Barangay
Captain was absent when the plaintiff reported the said incident on 06
February 2019, the latter went to a nearby police station to request
assistance to accompany him to the site to stop the alleged men from
fully accomplishing their task. Plaintiff was able to secure the
assistance of the police authorities and went to the site. Upon arrival,
the plaintiff entered the premises while the members of the police
remained outside the perimeter. Once inside, the plaintiff introduced
himself to the alleged men as part-owner of Pinetree transport and
requested the men to stop whatever they are doing since the subject
buses are under litigation. Although the men heed the request of the
plaintiff, there were already two (2) buses inside the site that were
fully dismantled. A copy of the pictures taken by the plaintiff showing
the dismantled buses are herein attached as Annex “B”.

3. It is worth noting that in spite of the pending litigation

between the plaintiff and defendant over their joint businesses in
question, the defendant in blatant disregard to the authority and
process of the Court continues to commit such fraudulent acts to the
detriment and prejudice of the plaintiff.

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed that the Honorable Court duly NOTES this Manifestation.

Other measures of relief, just and equitable under the

circumstances, are likewise prayed for.

Pasig City for Quezon City, 18 February 2019.

MAT & JESS

Attorneys-at-law
Counsel for the Plaintiff
Captain America
Unit 69-A Strata 2000 Building
Emerald Avenue, Ortigas Center,
Pasig City 1600
Tel. No. (632) 633-8673
Telefax No. (632) 633-7501 loc. 143

By:

STEVEN HARVEY
PTR No. 2512777; 01/04/17; Pasig City
IBP No. 11055720; 01/04/17; Pasig City
Roll of Attorneys No. 29573
MCLE Compliance No. V-0016978;
03/16/16