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Legal Forms Compilation

The document contains multiple affidavits including an Affidavit of Adjudication of Estate, an Affidavit of Self-Adjudication, an Affidavit of Birth by Two Disinterested Persons, an Affidavit of Consent for Travel of a Minor Abroad, and an Affidavit of Desistance. Each affidavit outlines personal declarations regarding estate adjudications, birth verifications, travel consents, and legal desistances, all sworn before a notary public in Baguio City, Philippines. The affidavits are dated November 22, 2013, and include relevant details such as identities, property descriptions, and consent statements.

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0% found this document useful (0 votes)

1 views399 pages

Legal Forms Compilation

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kalinga.opad

We take content rights seriously. If you suspect this is your content, claim it here.

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AFFIDAVITS

AFFIDAVIT is a written, ex parte statement made or taken under oath

before an officer of the court or a notary public or other person who has
been duly authorized so to act.

1
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

AFFIDAVIT OF ADJUDICATION OF ESTATE OF DECEASED PERSON

I, ABIGAIL A. ALCANTARA, of legal age, Filipino citizen, single and

now residing at 1 Ledesma St., Aurora Hill, Baguio City, Philippines, after
having been duly sworn in accordance with law, do hereby depose and say:

1. That I am the only surviving daughter of one, named ALEJO A.

ALCANTARA who died intestate in Bakakeng, Baguio City, on October
13, 2013 as evidenced by Death Certificate issued by the Civil
Registrar of Baguio, hereto attached as ANNEX “A” and made an
integral part of this Affidavit;

2. That the said deceased left a deposit in the Bank of the Philippine
Islands, in the amount of FIVE HUNDRED THOUSAND PESOS
(P500,000.00);

3. That said deceased also left a 4-bedroom condominium unit, located

at 288, Twin Towers Condominium, Leonard Wood Road, Baguio City,
with an area of ONE HUNDRED (100) SQUARE METERS more or less,
covered by Condominium Certificate Title No. 188521 of the Register
of Deeds of Baguio City;

4. That the said deceased left no debts nor any LAST WILL AND
TESTAMENT;

5. That the net value of said estate is not more than TWO MILLION
PESOS (P2,000,000.00), subject to estate and inheritance taxes;

6. That pursuant to Rule 74, Sec. 1 of the Rules of Court, I hereby

adjudicate unto myself the above described real and personal
property by means of this Affidavit and hereby files the same with
the Register of Deed of Baguio City with the request that the said
adjudication be made effective without judicial proceeding as
prescribed by the aforementioned Rules of Court.

2
IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of
November, 2013, at Baguio City, Philippines.

ABIGAIL A. ALCANTARA
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 22nd day of November 2013 by ABIGAIL A. ALCANTARA
who exhibited to me her Passport No. CC957742, valid until February 14,
2017 as competent proof of her identity, and who is the same person who
personally signed before me the foregoing affidavit.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
PTR No. 1928374/Baguio City/01-04-13
Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-04-13
MCLE Compliance No. IV-90210/04-22-13
Commission Serial No. 01-NC-11 (R)

Doc. No. 1;
Page No. 1;
Book No. I;
Series of 2013

3
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

AFFIDAVIT OF SELF-ADJUDICATION

I, BENJAMIN B. BENITEZ, of legal age, Filipino, single and a resident

of 15 Maria Basa, Pacdal, Baguio City, Philippines, after having been duly
sworn in accordance with law, do hereby depose and say:

1. That I am the only son of BENITO B. BENITEZ who died intestate in

the City of Baguio, on September 4, 2013 as evidenced by Death
Certificate issued by the Civil Registrar of Baguio, 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

measuring ONE THOUSAND (1,000) SQUARE METERS, located at
Mary Hills Road, Loakan Proper, Baguio City covered by Transfer
Certificate Title No. CC-13579 of the Registry of Deeds of Baguio City;

3. That the said parcel of land is more particularly described as follows

to wit;

LOT 21 (LRC) CC-13579

“A parcel of land (Lot 21 of Subdivision plan LRC) CC-

13579 being a portion of the parcel of land described on TS-
V-789D, l\LRC Rec. No. TS sales Pat.) situated in Res. Sec.
City of Baguio, island of Luzon, Philippines. Bounded on the
N.E point 5 to 7 y Subdivision Road (1, 000 m. Wide); on the
SW., points 5 to 1 by Lot 2, of the Subdivision Plan; and on
the NW., points 1 to 2 by Lot 9, Block 2. Beginning at point
marked “I” on plan, being N 43 deg 21 deg’ E, 321.70 m.
from the main gate.

thence N 25 deg. 00’E, 40.00 m to point 2;

thence E 23 deg. 00’E, 32.00 m to point 3;
thence N 52 deg. 13’E, 11.00 m to point 4;
thence S 75 deg. 00’E, 456.00 m to point 5;
thence N 53 deg. 00’E, 13.00 m to point of beginning;

containing an area of ONE THOUSAND 1000 SQUARE

METERS, more or less. All points referred to are indicated
4
on the Plan and marked on the ground as follows; Points 1
to 4 by OLD points and the rest by PS cyl conc. Mons. 100 x
213 cm; bearings true; date of Original Survey, April 1, 1982
and that of Subdivision Survey executed by Gilberto G.
Ginnawan, a Geodetic Engineer on April 13, 1990.

4. That the said deceased left no debts nor any LAST WILL AND
TESTAMENT;

5. 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 the judicial proceeding as prescribed by the aforementioned
Rules of Court.

IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of

November 2013 at Baguio City, Philippines.

BENJAMIN B. BENITEZ
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 22nd day of November 2013, by BENJAMIN B. BENITEZ,
personally known to me, who is the same person who personally signed
before me the foregoing affidavit.

JUAN DE LA CRUZ JR.

Doc. No. 2;
Page No. 1;
Book No. I;
Series of 2013

5
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

AFFIDAVIT OF BIRTH BY TWO DISINTERESTED PERSONS

We, CRISANTO C. CARUNUNGAN and CATALINA C. CANONIZADO,

both Filipinos, of legal ages, both married, and presently residing at 45
Burgundy Lane, Rainbow Hills Subdivision, Fairview, Baguio City and at 62
La Cheza Rd., Irisan, Baguio City, respectively, both after having been duly
sworn in accordance with law, do hereby depose and say:

1. That we personally know CATHERINE CAGAYAN COMPOSTELA of 79

Badihoy St., Guisad, Baguio City, the daughter of CARMELO C.
COMPOSTELA and CRISTINA CAGAYAN COMPOSTELA, being our
acquaintance for a long period of time;

2. That she is a PAG-IBIG Fund member with an application for

Provident Benefits with the Fund;

3. That the said application is required to be accompanied by a copy of

the applicant’s birth certificate, however, no record can be obtained,
as shown by the attached Certification of Non-Availability of Birth
Record from the National Statistics Office (NSO);

4. That we certify that she was born at Baguio General Hospital, Baguio
City Philippines, on the 29th day of FEBRUARY in the year 1984;

5. That she has been using the said birth date in all her documents and
transactions, including her education and employment records;

6. That we are not related by affinity or consanguinity to the above

mentioned person; and

7. That we are executing this Affidavit to attest to the truth of the

foregoing statements that CATHERINE CAGAYAN COMPOSTELA was
born on FEBRUARY 29, 1984 explaining that the fact of her birth was
not registered and establishing the fact that her true and real birth
date is FEBRUARY 29, 1984 and for all legal purposes and intents it
may deem serve.

6
IN WITNESS WHEREOF, we have hereunto set our hands this 22 nd day
of November 2013, at Baguio City, Philippines.

CRISANTO C. CARUNUNGAN CATALINA C. CANONIZADO

Affiant Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 22nd day of November 2013, by CRISANTO C.
CARUNUNGAN and CATALINA C. CANONIZADO, who have satisfactorily
proven their identities through:

CRISANTO C. CARUNUNGAN, with Passport No. BB5693286, valid until

September 21, 2015.

CATALINA C. CANONIZADO, with Passport No. SS4543120, valid until

April 15, 2016.

who personally know the principal, to be the same persons who executed
and personally signed the foregoing affidavit before me.

JUAN DE LA CRUZ JR.

Doc. No. 3;
Page No. 1;
Book No. I;
Series of 2013

7
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

AFFIDAVIT OF CONSENT FOR TRAVEL OF A MINOR ABROAD

We, DANIEL D. DEFENSOR and DINAH D. DEFENSOR, married to each

other, of legal ages, Filipinos, with residence and postal address at 21
Baltazar, Gibraltar, Mines View, Baguio City, Philippines, after having been
duly sworn in accordance with law, do hereby depose and state:

1. That we are the parents of DANIELLEAH DIEDRE D. DEFENSOR, who

is 16 years old, and a citizen of the Republic of the Philippines;

2. That our above-named daughter is scheduled to leave for New York,

USA on November 30, 2013 for about a week;

3. That we are giving our full consent freely and voluntarily to our
above-named daughter to travel abroad or specifically to New York,
USA;

4. That for this purpose, we have sufficient and adequate financial

capacity to support the said travel and do hereby undertake to
finance her trip abroad from the application fees, airline tickets,
board and lodging, pocket money and such other expenses that she
may incur so that she would neither be a burden to the state nor at
the place of destination at any time during her trip abroad;

5. That we guarantee that she will not be a public charge and will
comply with all the laws and rules and regulations imposed upon
transient visitors in New York, USA;

6. That further, DANIELLEAH DIEDRE D. DEFENSOR will be accompanied

or escorted by her doctor, Dr. DESIREE D. DELFIN in her travel
abroad;

7. That we are hereby giving our full consent to said Dr. DESIREE D.
DELFIN to accompany or escort DANIELLEAH DIEDRE D. DEFENSOR in
her travel abroad; and

8. That we are executing this Affidavit to declare the truth of the

foregoing facts and for the purpose of giving our parental consent to
our daughter on account of her trip to New York, USA.
8
IN WITNESS WHEREOF, we have hereunto set our hands this 22nd day
of November 2013, in the City of Baguio, Philippines.

DANIEL D. DEFENSOR DINAH D. DEFENSOR

Affiant Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 22nd day of November 2013, by affiants, who have
satisfactorily proven their identity through DAVID D. DINARE, who is
personally known to me and who personally knows the principal, that they
are the same persons who executed and personally signed the foregoing
affidavit before me.

JUAN DE LA CRUZ JR.

Doc. No. 4;
Page No. 1;
Book No. I;
Series of 2013

9
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

AFFIDAVIT OF DESISTANCE

I, EDWARD E. ENGRACIA, single, of legal age, Filipino citizen, with

residence and postal address at 65 Cabinet Hill, Baguio City, after having
been duly sworn in accordance with law, do hereby depose and state:

1. That I am the Private Complainant in Criminal Case No. 35646-R for

violation of B.P. Blg. 22 otherwise known as the Bouncing Checks Law
now pending before the Municipal Trial Court in Cities, Baguio City,
Branch 3;

2. That the accused ENRIQUIETTA E. ELEFANTE has settled her

obligations with me to my full satisfaction;

3. That due to the aforementioned reason, I freely and voluntarily pray

for the FINAL DISMISSAL of the case against ENRIQUIETTA E.
ELEFANTE;

4. That I am no longer interested to pursue the case against said

ENRIQUIETTA E. ELEFANTE;

5. That I am now requesting the Office of the City Prosecutor of Baguio

City and the Honorable Court, Municipal Trial Court in Cities, Branch
3 of Baguio City to have the case withdrawn against ENRIQUIETTA E.
ELEFANTE;

6. That I am executing this Affidavit of Desistance to attest to the truth

of all the foregoing facts, as well as to withdraw my complaint
against ENRIQUIETTA E. ELEFANTE, and ultimately have the case
against her be dismissed.

10
IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of
November 2013, in the City of Baguio, Philippines.

EDWARD E. ENGRACIA
Affiant / Private Complainant

CERTIFICATION

This is to certify that I have personally examined the affiant and I am

convinced that he voluntarily executed his statement and understood the
contents thereof.

EMILY E. ELISEO
Public Prosecutor

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 22nd day of November 2013, by EDWARD E. ENGRACIA,
personally known to me, who is the same person who personally signed
before me the foregoing affidavit.

JUAN DE LA CRUZ JR.

Doc. No. 5;
Page No. 1;
Book No. I;
Series of 2013

11
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

AFFIDAVIT OF DISCREPANCY

I, FLEURDELUNE F. FRANZIA, of legal age, single, Filipino citizen, and

a resident of 23 St. Theresa St., Mirador Hill, Baguio City, Philippines, having
been duly sworn in accordance with law, do hereby depose and state:

1. That in my Certificate of Live Birth as recorded in the Office of the

Civil Registrar of Baguio City, Philippines and Secondary Student
Permanent Record at Baguio City National High School, it is stated
that I was born on 1 November 1990 at Notre Dame de Chartres
Hospital, Baguio City, Philippines;

2. That my relatives, acting on the honest belief that I was born on 1

November 1991, had used 1 November 1991 as my birth date in all
pertinent school records when they processed my enrollment at
University of the Cordilleras in Baguio City;

3. That when I filled up my voter’s registration record required by the

Commission on Election last October 16, 2013, I had inadvertently
and erroneously written the date of my birth as 1 November 1991
instead of 1 November 1990;

4. That I am executing this Affidavit of Discrepancy to attest to the truth

of the foregoing facts and to explain the discrepancy in my
Certificates of Live Birth, Secondary Student Permanent Record,
Transcript of Records and Voter Registration Form with regard to my
date of birth;

5. Further, I am declaring that from this date hereon I would be using

my true and correct date of birth of 1 November 1990 in all my
papers, records and other documents; and

6. That I am executing this Affidavit to attest to the truth of the

foregoing facts for record and reference purposes.
12
IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of
November 2013, in the City of Baguio, Philippines.

FLEURDELUNE F. FRANZIA
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 22nd day of November 2013 by FLEURDELUNE F. FRANZIA
who exhibited to me her Postal ID with number 529649, valid until August
15, 2015 as competent proof of her identity, who is the same person who
personally signed before me the foregoing affidavit.

JUAN DE LA CRUZ JR.

Doc. No. 6;
Page No. 2;
Book No. I;
Series of 2013

13
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

AFFIDAVIT OF DISCREPANCY

I, GREGORY GENE G. GONZALES, of legal age, Filipino citizen, single,

and a resident of 7 Upper Kitma, Baguio City, Philippines having been duly
sworn in accordance with law, do hereby depose and state:

1. That I was born to the spouses GREGORIO G. GONZALES and

GENOVEVA G. GONZALES on October 28, 1989 at Baguio General
Hospital, Baguio City Philippines as evidenced by the Certificate of
Live Birth issued by the Civil Registrar of Baguio City;

2. That however, in the said Certificate of Live Birth, the date of

marriage of my parents was erroneously written as “May 8, 1988”
instead of the true and correct date “May 28, 1988” as evidenced by
the Certificate of Marriage of my parents issued by the Civil Registrar
of Baguio City, hereto attached as Annex "A";

3. That said discrepancy in my Certificate of Live Birth was an error

done inadvertently;

4. That I execute this Affidavit of Discrepancy to attest to the truth of

the foregoing facts.

IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of

November 2013, in the City of Baguio, Philippines.

GREGORY GENE G. GONZALES

Affiant

14
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 22nd day of November 2013, by GREGORY GENE G.
GONZALES who presented to me his Social Security System Card No. 378-
404-815 as competent proof of his identity, and who is the same person
who personally signed before me the foregoing affidavit.

JUAN DE LA CRUZ JR.

Doc. No. 7;
Page No. 2;
Book No. I;
Series of 2013

15
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

AFFIDAVIT OF DISCREPANCY

I, HARRY HONTIVEROS HERNANDEZ, of legal age, Filipino citizen,

single, and a resident of 25 Leonor Rivera St., Guisad, Baguio City,
Philippines, having been duly sworn in accordance with law, do hereby
depose and state:

1. That I am the child of spouses HAROLD H. HERNANDEZ and

HENRIETTA HONTIVEROS HERNANDEZ;

2. That in my Certificate of Live Birth as recorded in the Office of the

Civil Registrar of Baguio City, Philippines, my middle name was
erroneously written as “HONTIVERROS” instead of my true and
correct middle name of “HONTIVEROS”;

3. That my true middle name is “HONTIVEROS”, as appearing in the

same Certificate of Live Birth as the maiden name of my mother;

4. That in all pertinent documents which I had used, to include that of

my scholastic records (transcript of records), I used my true and
correct middle name of “HONTIVEROS”

5. That I am executing this Affidavit of Discrepancy to attest to the truth

of the foregoing facts and to explain the discrepancy in my
Certificates of Live Birth, with regard to my true middle name; and

6. That I am further executing this Affidavit for all legal intents it may
serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of

November 2013, in the City of Baguio, Philippines.

HARRY HONTIVEROS HERNANDEZ

Affiant

16
SUBSCRIBED AND SWORN to before me in the City of Baguio,
Philippines, this 22nd day of November 2013, by HARRY HONTIVEROS
HERNANDEZ, personally known to me, who is the same person who
personally signed before me the foregoing affidavit.

JUAN DE LA CRUZ JR.

Doc. No. 8;
Page No. 2;
Book No. I;
Series of 2013

17
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

AFFIDAVIT OF DISCREPANCY

I, ISAAC I. IÑIGO, of legal age, married, Filipino and a resident of 95

Silver St., Tacay, Quezon Hill, Baguio City, Philippines having been duly
sworn in accordance with law, do hereby depose and state:

1. That on October 24, 2008, I was issued a Philippine Passport with

passport number MM8875341 in which my true surname “IÑIGO”
was stated;

2. That before the expiration of the aforementioned passport on

October 24, 2013, I had applied with the Philippine Embassy in
Manila for the issuance of a new passport and on November 4, 2013,
I was issued a new Philippine passport with Passport No.
MM8976589;

3. However, in the said new passport my surname had been

erroneously misspelled as “INIGO” instead of “IÑIGO”;

4. That I execute this Affidavit of Discrepancy to attest to the truth of

the foregoing facts and to explain the discrepancy in my Philippine
Passport with regard to my surname.

IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of

November 2013, at Baguio City, Philippines.

ISAAC I. IÑIGO
Affiant

18
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 22nd day of November 2013, by ISAAC I. IÑIGO who
exhibited to me his Postal ID No. 4288341, valid until September 11, 2015
as competent proof of his identity, and who is the same person who
personally signed before me the foregoing affidavit.

JUAN DE LA CRUZ JR.

Doc. No. 9;
Page No. 2;
Book No. I;
Series of 2013

19
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

AFFIDAVIT OF GUARDIANSHIP

I, JEREMIAH J. JARAMILLA, of legal age, Filipino citizen, widow and

presently residing at 10 City Camp Alley Extension, Baguio City, Philippines,
having been duly sworn to in accordance with law, do hereby depose and
say:

1. That I am the father of the minor JOHN JOEL J. JARAMILLA, who was
born on June 18, 2008, and who has an interest in the PAG-IBIG
Provident Benefits of my late wife JENNY J. JARAMILLA payable by
the PAG-IBIG Fund;

2. That by reason of the death of my above-named wife, I henceforth

became the guardian of the above-named minor;

3. That the said minor is under my sole care and custody;

4. That I am competent to receive in behalf of the said minor any

amounts due him;

5. That I am not an imbecile, insane, a vagrant or a vicious person or a

habitual drunkard or a habitual criminal, and have not abandoned,
neglected or refused to support said minor or caused him to commit
offenses against the law; and

6. That I am executing this Affidavit in order to attest to the truth of the

foregoing circumstances and for the purpose of securing the PAG-
IBIG Provident Benefits for my said son in my capacity as his
guardian.

IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of

November, 2013, at Baguio City, Philippines.

JEREMIAH J. JARAMILLA
Affiant

20
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 22nd day of November 2013, by JEREMIAH J. JARAMILLA,
who has satisfactorily proven his identity to me through his Tax
Identification Number (TIN) Card 312-383-408, that he is the same person
who personally signed the foregoing affidavit before me.

JUAN DELA CRUZ JR.

Doc. No. 10;

Page No. 2;
Book No. I;
Series of 2013

21
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

AFFIDAVIT OF ILLEGITIMACY

I, KATRINA K. KALAYAG, single, of legal age, Filipino citizen, with

residence and postal address at 18 Everlasting St., Upper Q.M., Baguio City,
Philippines, having been duly sworn in accordance with law, do hereby
depose and say:

1. That I am the biological mother of KATRINA KAYE K. KALAYAG, who

was born on March 23, 2008, at Lorma Medical Center, San Fernando
City, La Union, as evidenced by the Certificate of Live Birth issued by
the Civil Registrar of San Fernando, La Union hereto attached as
ANNEX “A” and made an integral part of this Affidavit;

2. That as appearing in the Certificate of Live Birth of the above-

mentioned child, her father is KARLO K. KATIKLAN, who is a Filipino
citizen;

3. That I hereby affirm and attest to the truth of the fact that the father
of the above-mentioned child is indeed KARLO K. KATIKLAN.

4. That at the time my child was born, I was not legally married to her
biological father, nor am I legally married to the said father now as
evidenced by the Certificate of No Marriage issued by the National
Statistics Office hereto attached as ANNEX “B” and made an integral
part of this Affidavit; and

5. That I execute this Affidavit to attest to the truth of the foregoing

facts and for whatever purpose it may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day

November 2013, in the City of Baguio, Philippines.

KATRINA K. KALAYAG
Affiant

22
SUBSCRIBED AND SWORN to before me in the City of Baguio,
Philippines, this 22nd day of November 2013, by KATRINA K. KALAYAG, who
has satisfactorily proven her identity to me through her Non-Professional
Driver’s License No. 18414185 valid until August 30, 2015, and that she is
the same person who personally signed the foregoing affidavit before me.

JUAN DE LA CRUZ JR.

Doc. No. 11;

Page No. 3;
Book No. I;
Series of 2013

23
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

AFFIDAVIT OF LEGITIMATION

We, the spouses LEONILO L. LEGARDA and LAVINIA L. LEDEZMA-

LEGARDA, both of legal age, Filipinos, with residence and postal address at
48 Quisumbing St., Trancoville, Baguio City, Philippines, having been duly
sworn in accordance with law, do hereby depose and say:

1. That we were in an intimate relationship since December of 2008

with no impediments barring us in marrying each other but without
the benefit of marriage, we started cohabiting as husband and wife in
2010 at Honeymoon, Baguio City;

2. That out of our relationship was born a son on August 25, 2009
whom we named LORD LEOVINE as evidenced by his Certificate of
Live Birth hereto attached as ANNEX “A” and made an integral part of
this Affidavit;

3. That since our son was born out of wedlock, he bears the family
name of his mother which is LEDEZMA;

4. That we subsequently got married on August 25, 2013 at St. Joseph

Parish Church in Pacdal, Baguio City as evidenced by our Certificate
of Marriage hereto attached as ANNEX “B” and made an integral part
of this Affidavit;

5. That at the time of the birth of our child LORD LEOVINE we possessed
all the qualifications and none of the disqualifications to marry each
other;

6. That we hereby recognize LORD LEOVINE, our biological son, as our

legitimate child; and

7. That we execute this Affidavit to attest to the truth of the foregoing

statements and for the purpose of causing the legitimation of the
status of our child, LORD LEOVINE and for all legal intents and
purposes this may well serve.

24
IN WITNESS WHEREOF, we hereunto set our hands this 22 nd day of
November, 2013 in the City of Baguio, Philippines.

LEONILO L. LEGARDA LAVINIA L. LEDEZMA-LEGARDA

Affiant Affiant
Passport No. JJ8822089 Passport No. QQ7644120
Valid until December 23, 2016 Valid until November 30, 2017

SUBSCRIBED AND SWORN to before me this 22nd day of November,

2013 at Baguio City, Philippines, the affiants personally appearing and
exhibiting to me their Passport Numbers indicated below their names as
proof of their identities, and that they are the same persons who
personally signed the foregoing affidavit before me.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
PTR No. 1928374/Baguio City/01-04-13
Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-04-13
MCLE Compliance No. IV-90210/04-22-13
Commission Serial No. 01-NC-11 (R)

Doc. No. 12;

Page No. 3;
Book No. I;
Series of 2013

25
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

AFFIDAVIT OF LOSS

I, MARCO M. MONTINOLA, of legal age, Filipino citizen, single and

with residence and postal address at 81 Outlook Drive, Baguio City, having
been duly sworn in accordance with law, do hereby depose and state:

1. That I was issued a PHILIPPINE PASSPORT by the Department of

Foreign Affairs sometime in 2010 which shall expire in 2015;

2. That I have always kept the same at the topmost part of my bedside
table drawer;

3. That when I looked for it on November 15, 2013 as I intend to spend

the upcoming Christmas holidays in Reykjavic, Iceland, I could not
find it;

4. That diligent efforts were exerted to find the said passport but the
same proved futile and fruitless;

5. That the said passport was lost in the manner stated above and was
not confiscated nor cancelled by the issuing agency or other agencies
for violation of any of its terms and conditions, laws, rules and
regulations;

6. That I am now executing this Affidavit to attest to the veracity of the

foregoing narration for securing a replacement of the said lost
passport and for all legal intents and purposes it may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day

November 2013, in the City of Baguio, Philippines.

MARCO M. MONTINOLA
Affiant

26
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 22nd day of November 2013, by MARCO M. MONTINOLA,
who has satisfactorily proven his identity to me through his Professional
Driver’s License No. 81522751 valid until December 25, 2015, and that he is
the same person who personally signed the foregoing affidavit before me.

JUAN DE LA CRUZ JR.

Doc. No. 13;

Page No. 3;
Book No. I;
Series of 2013

27
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

AFFIDAVIT OF LOSS

I, NATASHA N. NATHANIEL, of legal age, Filipino Citizen, married and

currently residing at 13 Balacbac Rd., Sto. Tomas Proper, Baguio City,
Philippines, having been duly sworn in accordance with law, do hereby
depose and state:

1. That I availed of a CREDIT CARD from Hong Kong and Shanghai

Banking Corporation (HSBC) Quezon City Branch last April 30, 2013;

2. That I have always kept said HSBC CREDIT CARD in my purse and that
I bring my purse wherever I go;

3. That last October 15, 2013 when I travelled from Baguio to Manila,
my purse was misplaced, and consequently, I lost my HSBC CREDIT
CARD among other things;

4. That diligent efforts were exerted to recover the said HSBC CREDIT
CARD but the same proved futile and fruitless;

5. That the said HSBC CREDIT CARD was lost in the manner stated above
and was not confiscated nor cancelled by the issuing bank for
violation of any of its terms and conditions, laws, rules and
regulations;

6. That I am now executing this Affidavit to attest to the veracity of the

foregoing narration for securing a replacement of the said lost HSBC
CREDIT CARD and for all legal intents and purposes it may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of

November 2013, in the City of Baguio, Philippines.

NATASHA N. NATHANIEL
Affiant

28
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 22nd day of November 2013, Affiant personally appeared
and exhibited to me her Community Tax Certificate bearing the No.
22256675 issued on January 4, 2013 at Baguio City, Philippines, and who
has satisfactorily proven her identity through NICODEMUS N. NAVARRO,
who is personally known to me and who personally knows the principal,
that she is the same person who executed and personally signed the
foregoing affidavit before me.

JUAN DE LA CRUZ JR.

Doc. No. 14;

Page No. 3;
Book No. I;
Series of 2013

29
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

AFFIDAVIT OF NON-OPERATION OF BUSINESS

I, ONESIMUS O. ORDINARIO, single, of legal age, Filipino citizen, and

a resident of 88 Lower Brookside, Baguio City, Philippines, after having
been duly sworn to in accordance with law, do hereby depose and state:

1. That I am the President and Chief Executive Officer of XTRORDINAIRE

REAL ESTATE PLANNING AND DEVELOPMENT, INC., a corporation
duly organized and existing under the laws of the Philippines, with
principal office at Unit 4A, Originaux Bldg., Session Rd., Baguio City,
Philippines;

2. That said corporation was incorporated on August 8, 2008 and

acquired by the undersigned with the purchase of its corporate
property in the above address sometime in August 2013 but has not
yet commenced its operations in view of the slump in the real estate
industry in the country;

3. That the stockholders and directors of the corporation are

contemplating on reviving its operations in the near future when the
opportune time comes;

4. That this Affidavit is being executed in order to attest to the truth of

the foregoing circumstances and for the purpose of complying with
the reportorial requirements of the Securities and Exchange
Commission.

IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of

November 2013, in the City of Baguio, Philippines.

ONESIMUS O. ORDINARIO
Affiant

30
SUBSCRIBED AND SWORN to before me, in the City of Baguio this
nd
22 day of November 2013, by ONESIMUS O. ORDINARIO, who has
satisfactorily proven his identity through OSCAR O. OANDASAN, who is
personally known to me and who personally knows the principal, that he is
the same person who executed and personally signed the foregoing
affidavit before me.

JUAN DE LA CRUZ JR.

Doc. No. 15;

Page No. 3;
Book No. I;
Series of 2013

31
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

AFFIDAVIT OF NON-TENANCY

I, PACITA P. PEREGRINO, married to PETER PAUL P. PEREGRINO, of

legal age, Filipino citizen, and with residence and postal address at 136 Km.
5, Balili, La Trinidad, Benguet, under oath hereby depose and state:

1. That I am the registered owner of a Real Property with Katibayan ng

Orihinal na Titulo P-8760 located at Buhaw, Puguis, La Trinidad,
Benguet with an area of 1,061 square meters and more particularly
described as follows:

Lot No. 7189, Case 14, Cad 743-D, La Trinidad Cadastre

Beginning at the point marked “1” of lot no.

7189, Cad 743-D, La Trinidad Cadastre being S. 60-
02 E., 7,466.42 m. from BLLM NO. 1, Cad 743-D, La
Trinidad Cadastre, La Trinidad, Benguet thence:

S. 11-05 W., 45.47 m. to point 2;

S. 39-08 W., 90.79 m. to point 3;
N. 32-50 W., 138.32 m. to point 4;
S. 89-04 E., 110.66 m. to point 5;
N. 88-51 E., 30.39 m. to point 1; point of beginning

Containing an area of ONE THOUSAND AND

SIXTY ONE (1,061) square meters.
All points are marked on the ground by P.S.
Cyl. Conc. Mons. 15x60cm.

2. That I have been planting vegetables in this land area since the
1980’s and have devoted all portions of it for Agricultural purposes;

3. That this land is not tenanted as I personally operate the land; and

4. That I am executing this Affidavit to attest to the truth of the

foregoing, to satisfy the requirements of the proper government
agencies and private institutions, and for all legal intents and
purposes that it may serve.

32
IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of
November 2013, in the City of Baguio, Philippines.

PACITA P. PEREGRINO
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio this

nd
22 day of November 2013, by PACITA P. PEREGRINO, who has
satisfactorily proven her identity to me through her Non-Professional
Driver’s License No. M19-13843 valid until July 31, 2015, that she is the
same person who personally signed the foregoing affidavit before me.

JUAN DE LA CRUZ JR.

Doc. No. 16;

Page No. 4;
Book No. I;
Series of 2013

REPUBLIC OF THE PHILIPPINES}

33
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

AFFIDAVIT OF TRANSFEREE

I, QUEENNIE Q. QUIABANG, single, of legal age, Filipino citizen and a

resident of 21 Green Valley Village, Baguio City, Philippines, after having
been sworn to in accordance with law, do hereby depose and state:

1. That my total aggregate landholdings, including the parcel of land

containing a land area of ONE HUNDRED TWENTY (120) SQUARE
METERS, located at Buhaw, Puguis, La Trinidad, Benguet, that I
acquired from QUIRINO Q. QUINTANA, thru a Deed of Absolute Sale
of a Registered Land covered by Doc. No. 18; Page No. 4; Book No. I;
Series of 2013 of the Notarial Registry of Atty. HONORIO G. BUCCAT
JR. of Baguio City, Philippines, dated August 25, 2013, does not
exceed FIVE (5) hectares; and

2. That I am executing this Affidavit in compliance with Department of

Agrarian Reforms Administrative Order No. 1-89, as well as to show
proof that my total aggregate land holdings, including the portion of
land I acquired from QUIRINO Q. QUINTANA does not exceed five (5)
hectares.

IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of

November 2013, in the City of Baguio, Philippines.

QUEENNIE Q. QUIABANG
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio this

nd
22 day of November 2013, by QUEENNIE Q. QUIABANG, who has
34
satisfactorily proven her identity to me through her Professional Driver’s
License No. B22-072204 valid until June 23, 2015, that she is the same
person who personally signed the foregoing affidavit before me.

JUAN DE LA CRUZ JR.

Doc. No. 17;

Page No. 4;
Book No. I;
Series of 2013

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

35
x ------------------------------------------ x

AFFIDAVIT OF TRANSFEROR

I, RONALDO R. RODRIGUEZ, single, of legal age, Filipino citizen and a

resident of 78 Guisad, Surong Ext., Baguio City, Philippines, after having
been sworn to in accordance with law, do hereby depose and state:

1. That my total aggregate landholdings, including that parcel of land

containing a land area of ONE HUNDRED (100) SQUARE METERS,
located at Tuding, Itogon, Benguet, that I sold to RANIELLA R.
ROMERO, thru a Deed of Absolute Sale of a Registered Land covered
by Doc. No. 12; Page No. 2; Book No. I; Series of 2013 of the Notarial
Registry of Atty. LAIRD DIONEL N. URBANOZO of Baguio City,
Philippines, dated April 21, 2013, does not exceed FIVE (5) hectares;
and

2. That I am executing this Affidavit in compliance with Department of

Agrarian Reforms Administrative Order no. 1-89, as well as to show
proof that my total aggregate land holdings, including the portion of
land I sold to RANIELLA R. ROMERO does not exceed five (5) hectares.

IN WITNESS WHEREOF, I have hereunto set my hands this 22 nd day of

November 2013, in the City of Baguio, Philippines.

RONALDO R. RODRIGUEZ
Affiant
TIN: 868-347-971

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 22nd day of November 2013, by RONALDO R. RODRIGUEZ,
who has satisfactorily proven his identity through:

36
REGINO R. RAYMUNDO, with Passport No. DD5353221, valid until
February 14, 2017.

RACHEL REIGN R. REALIZO, with Passport No. KK8889878, valid until

April 18, 2014.

who personally know the principal, to be the same person who executed
and personally signed the foregoing affidavit before me and acknowledged
that he executed the same.

JUAN DE LA CRUZ JR.

Doc. No. 18;

Page No. 4;
Book No. I;
Series of 2013

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.
x ------------------------------------------ x

37
AFFIDAVIT OF OWNERSHIP WITH UNDERTAKING

I, SIMONE S. SALVACION, of legal age, Filipino, single and a

resident of 34 Ciudad Grande, Bakakeng, Baguio City, Philippines, after
having been duly sworn to in accordance with law, do hereby depose and
say that:

1. I am the absolute and legal owner of a GSM handset described as

follows:

Make/Model: iPhone 5s Black

International Mobile Equipment Identification (IMEI):
4754711148287792

2. On October 20, 2013, I executed an Affidavit of Ownership and Loss

with Undertaking and filed the same with the National
Telecommunications Commission to authorize said commission and
all CMTS to block the said GSM handset for the reason that said
cellphone was stolen from me by unidentified person/s during a trip
to Bongao, Tawi-Tawi;

3. However, on November 15, 2013, I was able to retrieve said GSM

handset through a common friend;

4. I hereby request/authorize the National Telecommunications

Commission and all CMTS carriers to unblock the said GSM Handset;

5. I hereby undertake to hold free from any responsibility or shall not

hold NTC and the above-mentioned carriers liable for whatever
claims, loss or damages or any party may institute by reason of NTC’s
action to unblock the aforementioned unit;

6. In support of this request and as proof of my ownership of said

cellphone unit, I attached hereto a photocopy of the following
documents:

A. Social Security System Identification Card Number 3388357891

B. Non-Professional Driver’s License No. AD-8085923142
C. Employment Identification Card No. SMC-02-1578
D. Police Report No. M-23845 (October 20, 2013)
E. Receipt No. SM-890975

38
7. I am executing this Affidavit to attest to the truth of the foregoing
facts and for whatever legal intents and purposes it may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of

November 2013 in the City of Baguio, Philippines.

SIMONE S. SALVACION
Affiant
Passport No. NN1645699

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 22nd day of November 2013, by SIMONE S. SALVACION,
personally known to me, who is the same person who personally signed
before me the foregoing affidavit.

JUAN DE LA CRUZ JR.

Doc. No. 19;

Page No. 4;
Book No. I;
Series of 2013

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.
x ------------------------------------------ x
39
AFFIDAVIT OF OWNERSHIP OF PERSONAL PROPERTIES
FOR CONTRACT OF PLEDGE

I, THEODORE T. TEODORO, of legal age, Filipino, single, and a

resident of 43 Pias, Camp 7, Baguio City, Philippines, after having been duly
sworn to in accordance with law, do hereby depose and state:

1. That I am the true and absolute owner of the following personal

properties, to wit:

MOTOR VEHICLE
MAKE/TYPE ………….…….. Toyota Hi-lux Pick-up
MOTOR NO…………………. 5L52-BHND5337
CHASSIS NO………………… NNCKSLC919E112997
PLATE NO……………………. CDY-114

PERSONAL COMPUTER
MAKE/TYPE ………………… Acer emachines Netbook
Specifications:
LED LCD ……………..………. 10.1”
CPU ……………………..…….. Intel Atom N455
DDR3 Memory ..…….…… 2 GB
HDD ……………………….….. 500 GB
Li-ion Battery ……………… 8-cell

2. That I intend to deliver the said personal properties as a collateral to

secure the loan that I am applying for from Starting Anew Lending
Corporation;

3. That I hereby warrant title and ownership over the above-mentioned

personal properties and I will defend the possession of the Pledge
from eviction;

4. That I execute this Affidavit of Ownership to attest to the truth of the

aforementioned facts and in support of my application for a loan and
for any other legal purposes that this Affidavit could serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of

November 2013, at Baguio City, Philippines.

40
THEODORE T. TEODORO
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 28th day of November 2012, by THEODORE T. TEODORO
who exhibited to me his Professional Driver’s License No. NC-9675742, valid
until June 2, 2015 as competent proof of his identity, and who is the same
person who personally signed before me the foregoing affidavit.

JUAN DE LA CRUZ JR.

Doc. No. 20;

Page No. 4;
Book No. I;
Series of 2013

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.
x ------------------------------------------ x

41
AFFIDAVIT OF PUBLICATION

I, URIEL U. URDUJA, single, of legal age, Filipino citizen, with

residence and postal address at 75 Lower Liwanag, Loakan, Baguio City,
Philippines, after having been duly sworn in accordance with law, do
hereby depose and say:

1. That I am the Classified Ads Manager and authorized representative

of the Uphill Times, a newspaper of general circulation which is
published weekly in English, with editorial and business address at 67
Gov. Pack Road, Baguio City, Philippines;

2. That the Notice of Judicial Settlement of the Estate of Ulpindo U.

Untalan was published in the regular issues of the Uphill Times which
was distributed to its subscribers;

3. That the Notice was published on September 29, October 6 and 13,
2013;

4. That the fee charged in publishing the Notice in the amount of Php
3,000.00 has been paid in full; and

5. That I execute this Affidavit of Publication to attest to the truth of the

aforementioned facts and for any other legal purpose that this
Affidavit could serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of

November 2013, in the City of Baguio, Philippines.

URIEL U. URDUJA
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 22nd day of November 2013, by URIEL U. URDUJA, who
exhibited to me her SSS ID No. 33-7745321-9, as competent proof of her

42
identity, who is the same person who personally signed before me the
foregoing affidavit.

JUAN DE LA CRUZ JR.

Doc. No. 21;

Page No. 5;
Book No. I;
Series of 2013

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.
x ------------------------------------------ x

43
AFFIDAVIT OF SUPPORT

I, VICTOR V. VALENTINE, married to VANESSA V. VALENTINE, of legal

age, American citizen, with permanent address at 65 Lexington Avenue,
New York, USA and temporary Philippine address at 28 Quezon Hill, Baguio
City, Philippines, after having been sworn to in accordance with law, do
hereby depose and state that:

1. I am the brother of VIVIAN V. VALENTINE, with pending application

for Student Visa with the Department of Immigration and Citizenship
of Canada;

2. I am willing to extend my whole hearted support for her studies in

Canada, I being her brother and have the financial capability to
provide all her needs during the period of her studies;

3. At present, I am maintaining a bank account with BDO Banking

Corporation located in Session Road Branch in Baguio City,
Philippines under passbook savings account number 18-14-57937-4
and Time Deposit Account Number COD 789981 with an amount of
Two Million Five Hundred Twenty One Thousand Seven Hundred
Fifty Pesos and Twenty-eight centavos (Php2,521,750.28) where I
can source out all needed expenses that my sister may use during her
studies should her application be granted;

4. In relation to the support, I have authorized VIVIAN V. VALENTINE to

withdraw any amount from my bank account which she needs during
the period of her studies. Attached to this affidavit is a copy of the
said authorization marked as ANNEX “A” to form an integral part
hereof;

5. Aside from my savings mentioned in paragraph 3 of this Affidavit, my

other source of income where I can source out additional financial
support for VIVIAN V. VALENTINE are from my salaries and earnings
in the United States;

6. I shall provide any other support that she may need other than
money should it be necessary or as maybe further required by the
Canadian Government during the period of her studies in said
country;

44
7. I am executing this Affidavit to attest the truth of the foregoing facts
and to support the application of VIVIAN V. VALENTINE, my sister, for
the issuance of her student visa and for all legal intents this Affidavit
may lawfully serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 22 nd day of

November 2013, in Baguio City, Philippines.

VICTOR V. VALENTINE
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 22nd day of November 2013, by VICTOR V. VALENTINE who
exhibited to me his US Passport No. DD1478998, valid until February 14,
2017, as competent proof of his identity, and who is the same person who
personally signed before me the foregoing affidavit.

JUAN DE LA CRUZ JR.

Doc. No. 22;

Page No. 5;
Book No. I;
Series of 2013

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.
x ------------------------------------------ x
45
AFFIDAVIT OF TRANSFER

We, WENDY W. WAGAYEN, single, of legal age, Filipino citizen, and

with residence and postal address at 21 Monterrazas Village, Itogon,
Benguet and WARREN W. WILSON, single, of legal age, Filipino citizen, and
with residence and postal address at 95 PNB Village, Marcos Highway,
Baguio City, after having been duly sworn in accordance with law, do
hereby depose and state that:

1. The land I, WENDY W. WAGAYEN, sold in favor of WARREN W.

WILSON, with an area of ONE HUNDRED FORTY (140) SQUARE
METERS more or less, located at West Buyagan, La Trinidad, Benguet
by virtue of that Absolute Deed of Sale of Registered Land entered as
Doc. No. 10; Page No. 2; Book No. I; Series of 2013, of the Notarial
Registry of Atty. HONORIO G. BUCCAT JR. of Baguio City, Philippines,
dated April 21, 2013 is my retention area of not more than five (5)
hectares;

2. I, WARREN W. WILSON, own an aggregate landholding, including the

land area of ONE HUNDRED FORTY (140) SQUARE METERS that I am
acquiring from WENDY W. WAGAYEN, which is not more than five (5)
hectares; and

3. This affidavit is executed in compliance with the DAR Administrative

Order No. 01, Series of 1989 as well as to show proof that the land
subject of the above-mentioned transaction is a retention area or
portion of a retention area not exceeding five (5) hectares.

IN WITNESS WHEREOF, we have hereunto set our hands this 22 nd day

of November 2013, in the City of Baguio, Philippines.

WENDY W. WAGAYEN WARREN W. WILSON

Affiant Affiant
SUBSCRIBED AND SWORN to before me, in the City of Baguio this
nd
22 day of November 2013, by WENDY W. WAGAYEN and WARREN W.
WILSON, who has satisfactorily proven their identities through:
46
WENDY W. WAGAYEN, with Passport No. WW441245, valid until June 2,
2015.

WARREN W. WILSON, with Non-Professional Driver’s License No. GH-

778942, valid until April 18, 2015.

and who are the same persons who personally signed before me the
foregoing affidavit.

JUAN DE LA CRUZ JR.

Doc. No. 23;

Page No. 5;
Book No. I;
Series of 2013

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.
x ------------------------------------------ x

47
AFFIDAVIT OF WARRANTY

I, XAVIER Y. YORO, Filipino citizen, of legal age, single, and a resident

of 43 St. Patrick Subd., San Carlos Heights, Baguio City, Philippines, after
having been duly sworn in accordance with law, do hereby depose and say:

1. That I am the actual buyer of that motor vehicle which is specifically

described as follows:

Motor Vehicle
MAKE/TYPE ………………… Honda Civic
MOTOR NO…………………. 27M89-MMND7213
CHASSIS NO……………..…. KLMDBCW721D121253
COLOR ………………………… Black
PLATE NO …….…………….. CDY-114

2. That the fact of purchase is evidenced by a Deed of Sale of Motor

Vehicle dated August 21, 2013 whereby YALENA Y. YESAN is the
vendor and I am the vendee as entered in the notarial register of
Atty. LAIRD DIONEL N. URBANOZO as Doc. No. 14, Page No. 3, Book
No. I , and Series of 2013, a copy of said Deed of Sale is hereto
attached for reference;

3. That I hereby attest to the authenticity of said Deed of Sale and the
genuineness of the transaction and in furtherance thereof, I hereby
release the officers and staff of the Land Transportation Office from
any liability which may occur in the event that there is any flaw or
legal infirmities in said transaction; and

4. That I am executing this Affidavit in order to attest to the veracity of

the foregoing circumstances and as a warranty on the authenticity
and genuineness of the above mentioned transaction.

IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of

November 2013, in Baguio City, Philippines.

48
XAVIER Y. YORO
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 22nd day of November 2013, by XAVIER Y. YORO, who has
satisfactorily proven his identity to me through his Non-Professional
Driver’s License No. 9877442, that he is the same person who personally
signed the foregoing affidavit before me.

JUAN DE LA CRUZ JR.

Doc. No. 24;

Page No. 5;
Book No. I;
Series of 2013

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.
x ------------------------------------------ x

49
AFFIDAVIT OF WITHDRAWAL

I, ZECHARIAH Z. ZINAMPAN, of legal age, Filipino, single and a

resident of 36 City Camp, Baguio City, Philippines, having been duly sworn
in accordance with law, hereby depose and state:

1. That I filed my candidacy for Kagawad in our barangay for this

coming Barangay Election to be held on December 28, 2013;

2. That my Certificate of Candidacy was duly admitted by the

Commission on Elections, Baguio City;

3. That since I had changed my plan and not to run as Barangay

Kagawad due to the constant tension and stress it had caused me
and my family, I am now withdrawing my candidacy for Barangay
Kagawad;

4. That I am executing this Affidavit of Withdrawal for the purpose of

signifying my intention of withdrawing from the position I am
running for and for all legal intents it may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day of

November 2013, in Baguio City, Philippines.

ZECHARIAH Z. ZINAMPAN
Affiant

SUBSCRIBED AND SWORN to before me in the City of Baguio this

nd
22 day of November 2013, by ZECHARIAH Z. ZINAMPAN, who has
satisfactorily proven his identity to me through his Non-Professional
Driver’s License No. 9657512 that he is the same person who personally
signed the foregoing affidavit before me.

50
JUAN DE LA CRUZ JR.
Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
PTR No. 1928374/Baguio City/01-04-13
Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-04-13
MCLE Compliance No. IV-90210/04-22-13
Commission Serial No. 01-NC-11 (R)

Doc. No. 25;

Page No. 5;
Book No. I;
Series of 2013

51
DEEDS and
CONTRACTS
DEED is an instrument in writing which conveys an interest in land from the
grantor to the grantee; instrument used to effect a transfer of realty; main
function is to pass a title to land

UNILATERAL DEED/CONTRACT
-vendee assumes no obligation
- no need for the vendee or the other party to sign the
deed/contract nor the acknowledgment therefore

BILATERAL DEED/CONTRACT
- vendee obliged to do something
- vendee or the other party must sign both the deed and the
acknowledgment

Note: In a DEED, a person disposes of his property or right in favor of

another

PARTS OF A TYPICAL DEED

1. Title
2. Announcement
3. Party One
4. Consideration
5. Act or Conveyance
6. Party Two
7. Signature
8. Acknowledgment

52
DEED OF ABSOLUTE SALE OF A REGISTERED LAND

KNOW ALL MEN BY THESE PRESENTS:

This DEED OF SALE OF A REGISTERED LAND, made and executed by

and between:

ANNE B. CORTEZ, single, of legal age, Filipino Citizen, with residence

and postal address at 35 Cabinet Hill, Baguio City, Philippines hereinafter
referred to as the VENDOR;

-and-

AMELIA B. CAMANAVA, single, of legal age, Filipino Citizen, with

residence and postal address at 149 Pias St., Barangay Camp 7, Baguio City,
Philippines, hereinafter referred to as the VENDEE;

W I T N E S S E T H T H A T:

1. The VENDOR is the exclusive/absolute owner and possessor of that

certain registered parcel of land situated in Pico, La Trinidad,
Benguet, Philippines covered by TRANSFER CERTIFICATE OF TITLE
No. T-73163 issued by the Register of Deeds of Benguet and more
specifically described as follows, to wit:

TCT No. T-12345

A parcel of land (Lot 98-B, Psd-1-008521, being a

portion of Lot 98 (LRC) Psd-44205, LRC REC. No. 35)
situated at Bo. Alapang, Mun. of La Trinidad, Province of
Benguet, Island of Luzon. Bounded on the SE.,& SW.,
along lines 1-2-3-4 by Lot 107 (LRC) Psd-44205 (Road)
xxx

xxx containing an area of TWO HUNDRED SIXTY FIVE

(265) SQUARE METERS, more or less. xxx

53
2. The VENDOR agreed to sell and the VENDEE is willing to buy the
above-described parcel of registered land including all its
improvements;

3. For and in consideration of the total sum of NINETY THOUSAND

EIGHT HUNDRED PESOS (Php 90,800.00), PHILIPPINE CURRENCY,
receipt of said total purchase price is hereto acknowledged by the
VENDOR, paid by the VENDEE to the VENDOR, the VENDOR by these
present hereby SELL, TRANSFER and CONVEY, unto the said VENDEE,
their heirs and assigns the above-described parcel of REGISTERED
LAND including all improvements;

4. It is hereby declared that the boundaries of the foregoing land are

visible by means of natural and man-made boundaries as shown in
the survey plan of the above-described parcel of land;

5. The VENDOR hereby warrants that the above-described parcel of

land is free from liens and encumbrances and further warrants the
peaceful possession by the VENDEE of the hereto sold property;

6. FURTHER, that the requirements under the provisions of ARTICLE

1623 OF THE NEW CIVIL CODE have been complied with.

IN WITNESS WHEREOF, the parties have hereunto set their hands

this 29th day of November 2013, in the City of Baguio, Philippines.

ANNE B. CORTEZ AMELIA B. CAMANAVA

Vendor Vendee
CTC No. 83517465 CTC No. 73521906
Issued on 01/17/2013 Issued on 01/11/2013
Issued at Baguio City Issued at Baguio City

SIGNED IN THE PRESENCE OF:

ANTHONY B. CADAYONA ANDREA B. CANTORNA

54
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, ANNE B. CORTEZ and AMELIA B. CAMANAVA
personally appeared, who have satisfactorily proven to me their identity
through their Passport No. SS8264518 valid until December 25, 2014 and
Professional Driver’s License No. AO836278, respectively, that they are the
same persons who executed and voluntarily signed the foregoing Deed of
Absolute Sale of Registered Land which they acknowledged before me as
their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 26;

Page No. 6;
Book No. I;
Series of 2013

55
DEED OF ABSOLUTE SALE OF A MOTOR VEHICLE

KNOW ALL MEN BY THESE PRESENTS:

This DEED OF SALE OF A MOTOR VEHICLE, made and executed by

and between:

BRYAN C. DE GUZMAN, single, of legal age, Filipino Citizen, with

residence and postal address at 75 Gibraltar, Baguio City, Philippines
hereinafter referred to as the VENDOR;

-and-

BERNARD C. DONATO, single, of legal age, Filipino Citizen, with

residenceand postal address at 327 Victoria Village, Quezon Hill, Baguio
City, Philippines, hereinafter referred to as the VENDEE;

W I T N E S S E T H T H A T:

The VENDOR is the owner a motor vehicle, hereinafter referred to as

“Personalty” which is particularly described hereunder, to wit:

ONE (1) UNIT MOTOR VEHICLE

Make: Isuzu
Plate Number: UV AYT 736
MV File Number: 1749-8462547
Motor Number: 735185639839
Serial/ Chassis Number: VCD 9361437
Official Receipt Number: 83543638463
Certificate of Registration Number: 83524963849

The VENDOR agreed to sell and the VENDEE is willing to buy the
above-described personalty;

For and in consideration of the total sum of ONE HUNDRED

THOUSAND TWO HUNDRED FIFTY PESOS (Php 100,250.00), PHILIPPINE
CURRENCY, receipt of said total purchase price is hereto acknowledged by
the VENDOR, paid by the VENDEE to the VENDOR, the VENDOR by these
present hereby does SELL, TRANSFER and CONVEY, unto the said VENDEE,
her heirs and assigns the above-described motor vehicle;

The VENDOR hereby warrants that the above-described personalty is

free from liens and encumbrances.
56
IN WITNESS WHEREOF, the parties have hereunto set their hands
this 29th day of November 2013, in the City of Baguio, Philippines.

BRYAN C. DE GUZMAN BERNARD C. DONATO

Vendor Vendee
Passport No. SS 8572454 Professional Driver’s License
valid until December 20, 2014 No. AO64427498
valid until Sept. 3. 2016

SIGNED IN THE PRESENCE OF:

BEN C. DOMONDON BARRY C. DOMINICANO

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared BRYAN C. DE GUZMAN and
BERNARD C. DONATO who exhibited to me their respective identification
documents as indicted below their respective names and signatures, known
to me as the same persons who executed and voluntarily signed the
foregoing Deed of Absolute Sale of a Motor Vehicle which they
acknowledged before me as their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
PTR No. 1928374/Baguio City/01-04-13
Doc. No. 27; Roll of Atty. No. 67548/05-18-10
Page No. 6; IBP OR No. 739281/Baguio-Benguet/01-04-13
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2013 Commission Serial No. 01-NC-11 (R)
57
DEED OF ABSOLUTE SALE OF AN UNREGISTERED LAND

KNOW ALL MEN BY THESE PRESENTS:

This DEED OF SALE OF AN UNREGISTERED LAND, made and executed

by and between:

CATALINO D. ENGRANDE, single, of legal age, Filipino Citizen, and

with residence address at 47 New Lucban, Baguio City, Philippines
hereinafter referred to as the VENDOR;

-and-

CASPER D. EMISARIO, single, of legal age, Filipino Citizen, with

residence address at 732 Tacay Road, Baguio City, Philippines, hereinafter
referred to as the VENDEE;

W I T N E S S E T H T H A T:

The VENDOR is the owner of a certain unregistered parcel of land

situated at Sabkil, Loacan, Itogon, Benguet, Philippines and more
specifically described as follows, to wit:

ASSESSMENT OF REAL PROPERTY NO. 99-005-01234

BOUNDARIES:
NORTH: Lot 2 SOUTH: Lot 2052
EAST : Lot 1 WEST : Lot 4
KIND : Camotal land
AREA : 4.6351 ha.
MARKET VALUE : Php 48,500.00
ASSESSED VALUE : Php 15,300.00

The VENDOR decides to sell the entire area of the above-described

unregistered land including all the improvements therein to herein
VENDEE;

For and in consideration of the total sum of ONE HUNDRED FORTY

THOUSAND PESOS (Php 140,000.00) ONLY, PHILIPPINE CURRENCY, paid by
58
the VENDEE to the VENDOR, the VENDOR by these present hereby SELL,
TRANSFER and CONVEY, unto the said VENDEE, his heirs and assigns the
above described portion of property;

It is hereby declared that the boundaries of the foregoing land are

visible by means of natural and man-made boundaries;

The Vendor hereby warrants that the above-described portion of

unregistered land is free from all liens and encumbrances;

The above-described real estate property, 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 Sec. 194 of
the Revised Administrative Code, as amended by Act No. 3344.

IN WITNESS WHEREOF, the parties have hereunto set their hands

this 29th day of November 2013, in the City of Baguio, Philippines.

CATALINO D. ENGRANDE CASPER D. EMISARIO

Vendor Vendee
CTC No. 63153968 CTC No. 53184750
Issued on 01/08/2013 Issued on 01/10/2013
Issued at Baguio City Issued at Baguio City

SIGNED IN THE PRESENCE OF:

CESARIO D. EVIDENTE CAMILLA D. ESTEVES

ACKNOWLEDGMENT

59
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared CATALINO D. ENGRANDE and
CASPER D. EMISARIO who have satisfactorily proven to me their identity
through their Taxpayer Identification Number 362-953-714 and
Professional Driver’s License No. AO734184, respectively, that they are the
same persons who executed and voluntarily signed the foregoing Deed of
Absolute Sale of an Unregistered Land which they acknowledged before
me as their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 28;

Page No. 6;
Book No. I;
Series of 2013

DEED OF CONDITIONAL SALE OF A

PORTION OF AN UNREGISTERED LAND
60
KNOW ALL MEN BY THESE PRESENTS:

This DEED OF CONDITIONAL SALE OF A PORTION OF AN

UNREGISTERED LAND, made and executed by and between:

DOMINADOR E. FRESNEDI, single, of legal age, Filipino Citizen, and

with residence address at 89 Caguiao St., Baguio City, Philippines
hereinafter referred to as the VENDOR;

-and-

DIMITRI E. FERNANDEZ, single, of legal age, Filipino Citizen, with

residence address at 859 Honeymoon, Baguio City, Philippines, hereinafter
referred to as the VENDEE;

W I T N E S S E T H T H A T:

The VENDOR is the owner of a certain unregistered parcel of land

situated at Sabkil, Loacan, Itogon, Benguet, Philippines and more
specifically described as follows, to wit:

ASSESSMENT OF REAL PROPERTY NO. 99-005-01234

BOUNDARIES:
NORTH: Lot 2 SOUTH: Lot 2052
EAST : Lot 1 WEST : Lot 4
KIND : Camotal land
AREA : 4.6351 ha.
MARKET VALUE : Php 48,500.00
ASSESSED VALUE : Php 15,300.00

The VENDOR decides to sell a portion of the above-described

unregistered land including all the improvements therein to herein
VENDEE;

For and in consideration of the total sum of ONE HUNDRED SIXTY

THOUSAND PESOS (Php 160,000.00) ONLY, PHILIPPINE CURRENCY, paid by
the VENDEE to the VENDOR, the VENDOR by these present hereby SELL,
TRANSFER and CONVEY, unto the said VENDEE, his heirs and assigns the
above described portion of property;

Now, therefore, for and in consideration of the foregoing, they do

hereby agree as follows:

61
1. That upon signing of this Deed of Conditional Sale, the VENDEE shall
pay SIXTY THOUSAND PESOS (Php 60,000.00), as downpayment;

2. That the balance of ONE HUNDRED THOUSAND PESOS

(Php100,000.00) shall be paid through Metrobank and Trust
Company, Session Road Branch on or before sixty (60) days, or until
January 29, 2014, from the execution of this Deed of Conditional
Sale;

3. That upon receipt of the Bank Guarantee in favor of the VENDOR,

the latter shall execute an Deed of Absolute Sale in favor of the
VENDEE;

4. That failure to pay the balance shall cause the automatic rescission of
this Contract with damages in the amount of FIFTY THOUSAND
PESOS (Php 50,000.00);

5. That the realty taxes and special assessments on the subject property
on or before the date of sale, cost of operation of the documents of
sale, and notarial fees shall be for the account of the VENDOR; while
those realty taxes that shall accrue after the date of this Deed of
Conditional Sale, capital gains tax, documentary stamps, costs of
registration, transfer tax, and all incidental expenses for the issuance
of the new title shall be for the account of the VENDEE.

IN WITNESS WHEREOF, the parties have hereunto set their hands

this 29th day of November 2013, in the City of Baguio, Philippines.

DOMINADOR E. FRESNEDI DIMITRI E. FERNANDEZ

Vendor Vendee
CTC No. 47314869 CTC No. 85185043

Issued on 01/15/2013 Issued on 01/16/2013

Issued at Baguio City Issued at Baguio City

SIGNED IN THE PRESENCE OF :

DONATO E. FAROLAN DANIELLA E. FERGUSON

62
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared DOMINADOR E. FRESNEDI
and DIMITRI E. FERNANDEZ who have satisfactorily proven to me their
identity through their Taxpayer Identification Number 835-869-976 and SSS
No. 96-7497296-1, respectively, that they are the same persons who
executed and voluntarily signed the foregoing Deed of Conditional Sale of
a Portion of an Unregistered Land which they acknowledged before me as
their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 29;

Page No. 6;
Book No. I;
Series of 2013

63
DEED OF CONDITIONAL SALE OF A REGISTERED LAND

KNOW ALL MEN BY THESE PRESENTS:

This DEED OF CONDITIONAL SALE OF A REGISTERED LAND, made

and entered into by and between:

ELMER F. GAMUEDA, married to ELSA F. GAMUEDA, of legal age,

Filipino Citizen, with residence and postal address at 41 Upper Aurora Hill,
Baguio City, Philippines, hereinafter referred to as the VENDOR;

-and-

ELIZABETH F. GAMBOA, single, of legal age, Filipino Citizen, with

residence and postal address at 15 West Bayan Park, Aurora Hill, Baguio
City, hereinafter referred to as the VENDEE;

W I T N E S S E T H:

WHEREAS, the VENDOR is the absolute owner, in fee simple of that

certain parcel of land located in Bakakeng, Baguio City, covered by Transfer
Certificate of Title No. T-734175, more particularly described as follows:

A parcel of land (Lot 2-A-6-C, of the subdivision plan,

(LRC) Psd-47132, being a portion of Lot 2-A-6, described on
plan, (LRC) Psd-11998, LRC (GLRO) Rec.No. Civil Res. No. 211),
situated in the Barrio of Res. Sec. “J”, City of Baguio, Bounded
on the N., points 2 to 3, by Lot 2-A-5, (LRC) Psd-11998; on the
E., points 3 to 4, by Lot 2-A-7, Psd-11998; on the SE., points 4 to
1, by Lot 2-A-6-A of the subdivision plan; and on the W; points
1 to 2, by Lot 2-A-6-B, of the subdivision plan. Beginning at a
point marked “1” on plan, being N. 68 deg. 38’ E., 715.59 m.
from Triangulation Station, Worcester, Baguio Townsite xxx.

Containing an area of FIVE HUNDRED NINETY FOUR

(594) SQUARE METERS, more or less.

WHEREAS, the VENDOR has agreed to sell unto and in favor of the
VENDEE, and the VENDEE is willing and/or agreeable to buy from the
VENDOR, its ownership, rights and interest of the above-described land
with an area of FIVE HUNDRED NINETY FOUR (594) SQUARE METERS with a
total consideration of TWO MILLION FOUR HUNDRED EIGHTY THOUSAND
PESOS (Php 2,480,000.00), Philippine Currency, under the terms and
conditions provided hereunder;
64
Now, therefore, for and in consideration of the foregoing, they do
hereby agree as follows:

1. That upon signing of this Deed of Conditional Sale, the VENDEE shall
pay ONE MILLION THREE HUNDRED THOUSAND PESOS
(Php1,300,000.00), as downpayment;

2. That the balance of ONE MILLION ONE HUNDRED EIGHTY

THOUSAND PESOS (Php 1,180,000.00) shall be paid through
Metrobank and Trust Company, Session Road Branch on or before
sixty (60) days, or until January 29, 2013, from the execution of this
Conditional Deed of Sale;

3. That upon receipt of the Bank Guarantee in favor of the VENDOR,

the latter shall execute an Deed of Absolute Sale in favor of the
VENDEE;

4. That failure to pay the balance shall cause the automatic rescission of
this Contract with damages in the amount of ONE HUNDRED
THOUSAND PESOS (Php 100,000.00);

IN WITNESS WHEREOF, the parties have hereunto set their hands,

and affix their signatures, this 29th day of November 2013 in the City of
Baguio, Philippines.

ELMER F. GAMUEDA WITH MY MARITAL CONSENT:

Vendor
CTC No. 63216593 ELSA F. GAMUEDA
Issued on 01/2/2013 CTC No. 83624503

Issued at Baguio City Issued on 01/09/2013

Issued at Baguio City

65
ELIZABETH F. GAMBOA
Vendee
CTC No. 74532164
Issued on 01/25/2013
Issued at Baguio City

SIGNED IN THE PRESENCE OF:

ERNIE F. GASTON EDNA F. GANDER

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared ELMER F. GAMUEDA, ELSA F.
GAMUEDA, and ELIZABETH F. GAMBOA who have satisfactorily proven to
me their identity through their Professional Driver’s License No.
AO94631857 valid until December 1, 2015, Passport No. SS 7528573 valid
until December 18, 2014 and Postal ID No. 402544, respectively, that they
are the same persons who executed and voluntarily signed the foregoing
Deed of Conditional Sale of a Registered Land which they acknowledged
before me as their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
PTR No. 1928374/Baguio City/01-04-13
Doc. No. 30; Roll of Atty. No. 67548/05-18-10
Page No. 6; IBP OR No. 739281/Baguio-Benguet/01-04-13
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2013 Commission Serial No. 01-NC-11 (R)
66
DEED OF ASSIGNMENT

KNOW ALL MEN BY THESE PRESENTS:

This DEED OF ASSIGNMENT, made and executed by and between:

FLORA G. HADUCA, single, of legal age, Filipino citizen, with

residence and postal address at 12 Genesis Point Village, Irisan, Baguio City,
Philippines, hereinafter referred to as the ASSIGNOR;

-and-

FLERIDA G. HORTALEZA, single, of legal age, Filipino citizen, with

residence and postal address at 124 Banig, Tawang, La Trinidad, Benguet,
Philippines, hereinafter referred to as the ASSIGNEE.

W I T N E S S E T H:

That the ASSIGNOR is indebted to the ASSIGNEE in the sum of ONE

HUNDRED FIFTY THOUSAND PESOS (Php 150,000.00), Philippine Currency,
and in full payment and complete satisfaction thereof, the ASSIGNOR
hereby ASSIGN, TRANSFER, and CONVEY unto the ASSIGNEE that certain
real estate situated in Pico, La Trinidad, Benguet, and more particularly
described as follows:

“A parcel of land situated in Pico, La Trinidad, Benguet, xxx

Containing an area of FIVE HUNDRED (500) SQUARE METERS,
more or less. xxx ”

of which real estate the ASSIGNOR is the registered owner, her title being
evidenced by Transfer Certificate of Title No. 46295 issued by the Register
of Deeds of La Trinidad, Benguet, Philippines.

That the ASSIGNEE does hereby accept this assignment in full

payment of the above-mentioned debt of ONE HUNDRED FIFTY
THOUSAND PESOS (Php 150,000.00), Philippine Currency.

67
IN WITNESS WHEREOF, the parties hereto have hereunto set their
hands this 29th day of November 2013 in the City of Baguio, Philippines.

FLORA G. HADUCA FLERIDA G. HORTALEZA

Assignor Assignee
CTC No. 74528518 CTC No. 73557503
Issued on 01/12/2013 Issued on 01/9/2013
Issued at Baguio City Issued at La Trinidad, Benguet

SIGNED IN THE PRESENCE OF:

FRANCO G. HIRAM FATIMA G. HEMADY

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared FLORA G. HADUCA and
FLERIDA G. HORTALEZA, who have satisfactorily proven to me their identity
through their Passport No. SS 3721836 valid until December 20, 2016 and
Professional Driver’s License No. AO946284, respectively, that they are the
same persons who executed and voluntarily signed the foregoing Deed of
Assignment which they acknowledged before me as their free and
voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
PTR No. 1928374/Baguio City/01-04-13
Doc. No. 31; Roll of Atty. No. 67548/05-18-10
Page No. 7; IBP OR No. 739281/Baguio-Benguet/01-04-13
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2013 Commission Serial No. 01-NC-11 (R)

68
DEED OF CHATTEL MORTGAGE

KNOW ALL MEN BY THESE PRESENTS:

This DEED OF CHATTEL MORTAGE, made and executed by and

between:

GERTRUDE H. INTAL, single, of legal age, Filipino citizen, with

residence and postal address at 16 West Bayan Park, Aurora Hill, Baguio
City, Philippines, hereinafter referred to as the MORTGAGOR;

-and –

GIOVANNI H. ITALIANO, of legal age, Filipino citizen, with residence

and postal address at 62 Bonifacio St., Baguio City, Philippines, hereinafter
referred to as the MORTGAGEE;

W I T N E S S E T H:

That the MORTGAGOR is the owner a motor vehicle, which is

particularly described hereunder, to wit:

Make & Series : KIA BESTA

Engine No. : VN - 42176
Chassis No. : DJUXM9562851850
Plate No. : AOY746
MV File No. : 1738 – 000065937A
Type of Body : VAN

That for and in consideration of a LOAN obtained by the

MORTGAGOR from the MORTGAGEE in the sum of SIX HUNDRED
THOUSAND PESOS (Php 600,000.00), Philippine Currency, with an interest
of TWO PERCENT (2%) MONTHLY, and to secure the payment of the same,
the MORTGAGOR hereby freely and voluntarily CEDE, TRANSFER, and
CONVEY by way of mortgage unto the MORTGAGEE, his successors and
assigns, that motor vehicle above-described;

That the MORTGAGOR hereby warrants that the above-described

motor vehicle is free from any claim whatsoever, except that which appears
in the Certificate of Registration, if any;

That the MORTGAGEE with notice to the MORTGAGOR, reserves the

right to sell, cede, transfer, assign, or convey to any person or entity its

69
right and interest in and to this chattel mortgage so long as the same is
subsisting;

That for the purpose of extra-judicial foreclosure, the MORTGAGOR

hereby constitute and appoint the MORTGAGEE or his successors to sell the
property mortgaged, to sign all documents, receive, receipt for and accept
all monies or checks, and to perform any act requisite and necessary to
accomplish said purpose;

That this Chattel Mortgage shall be for a period of SIX (6) MONTHS to
be reckoned from the date of its execution and shall be renewable upon
the mutual consent of both parties.

IN WITNESS WHEREOF, the parties have hereunto affixed their

signatures this 29th day of November 2013 in the City of Baguio, Philippines.

GERTRUDE H. INTAL GIOVANNI H. ITALIANO

Mortgagor Mortgagee
CTC No. 84615947 CTC No. 63914037
Issued on 01/23/2013 Issued on 01/28/2013
Issued at Baguio City Issued at Baguio City

SIGNED IN THE PRESENCE OF:

GERMAYNE H. ILAYA GARY H. INDULGENCIA

AFFIDAVIT OF GOOD FAITH

We, GERTRUDE H. INTAL, Mortgagor, and GIOVANNI H. ITALIANO,

Mortgagee, under oath, do hereby swear that the foregoing mortgage is
made for purposes of security of the obligation specified in the promissory
note thereof and for no other and that the same is a just and valid
obligation and not one entered into for purposes of fraud.

GERTRUDE H. INTAL GIOVANNI H. ITALIANO

Mortgagor Mortgagee
70
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared GERTRUDE H. INTAL and
GIOVANNI H. ITALIANO, personally known to me to be the same persons
who voluntary executed the foregoing Deed of Chattel Mortgage which
they acknowledged before me as their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 32;

Page No. 7;
Book No. I;
Series of 2013

71
DEED OF CONDITIONAL SALE

KNOW ALL MEN BY THESE PRESENTS:

This DEED OF CONDITIONAL SALE, made and entered into by and

between:

HENRY I. JARDIN, married to HONEY I. JARDIN, of legal age, Filipino

citizen, with residence and postal address at 98 Upper Aurora Hill, Baguio
City, Philippines, hereinafter referred to as the VENDOR;

-and-

HUGH I. JORDAN, single, of legal age, Filipino citizen, with residence

and postal address at 98 East Bayan Park, Aurora Hill, Baguio City,
hereinafter referred to as the VENDEE;

W I T N E S S E T H:

WHEREAS, the VENDOR is the absolute owner, in fee simple of that

certain parcel of land located in Bakakeng, Baguio City, covered by Transfer
Certificate of Title No. T-862967, more particularly described as follows:

A parcel of land (Lot 2-A-6-C, of the subdivision plan,

Containing an area of FOUR HUNDRED SIXTY FIVE (465)

SQUARE METERS, more or less.

WHEREAS, the VENDOR has agreed to sell unto and in favor of the
VENDEE, and the VENDEE is willing and/or agreeable to buy from the
VENDOR, its ownership, rights and interest of the above-described land
with an area of FOUR HUNDRED SIXTY FIVE (465) SQUARE METERS with a
total consideration of ONE MILLION SEVEN HUNDRED THOUSAND PESOS
72
(Php 1,700,000.00), Philippine Currency, under the terms and conditions
provided hereunder;

Now, therefore, for and in consideration of the foregoing, they do

hereby agree as follows:

1. That upon signing of this Deed of Conditional Sale, the VENDEE shall
pay SEVEN HUNDRED THOUSAND PESOS (Php 700,000.00), as
downpayment;

2. That the balance of ONE MILLION ONE PESOS (Php 1,000,000.00)

shall be paid through Metrobank and Trust Company, Session Road
Branch on or before sixty (60) days, or until January 30, 2013, from
the execution of this Deed of Conditional Sale;

3. That upon receipt of the Bank Guarantee in favor of the VENDOR,

the latter shall execute an Deed of Absolute Sale in favor of the
VENDEE;

4. That failure to pay the balance shall cause the automatic rescission of
this Contract with damages in the amount of FIFTY THOUSAND
PESOS (Php 50,000.00);

IN WITNESS WHEREOF, the parties have hereunto set their hands,

and affix their signatures, this 29th day of November 2013 in the City of
Baguio, Philippines.

HENRY I. JARDIN WITH MY MARITAL CONSENT:

Vendor
CTC No. 64197408
Issued on 01/2/2013 HONEY I. JARDIN

Issued at Baguio City CTC No. 74210967

Issued on 01/09/2013
Issued at Baguio City
73
HUGH I. JORDAN
Vendee
CTC No. 07432187
Issued on 01/25/2013
Issued at Baguio City

SIGNED IN THE PRESENCE OF:

HARVEY I. JARO HILDA I. JASMIN

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared HENRY I. JARDIN, HONEY I.
JARDIN, and HUGH I. JORDAN, who have satisfactorily proven to me their
identity through their Passport No. SS 9672584 valid until December 18,
2015, Passport No. SS 8973452 valid until December 20, 2015, and
Professional Driver’s License No. AO86749787, respectively, that they are
the same persons who executed and voluntarily signed the foregoing Deed
of Conditional Sale which they acknowledged before me as their free and
voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
PTR No. 1928374/Baguio City/01-04-13
Doc. No. 33; Roll of Atty. No. 67548/05-18-10
Page No. 7; IBP OR No. 739281/Baguio-Benguet/01-04-13
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2013 Commission Serial No. 01-NC-11 (R)

74
DEED OF DONATION
KNOW ALL MEN BY THESE PRESENTS:

This DEED OF DONATION OF PERSONAL PROPERTIES, made and

executed by and between:

IRENE J. KINTANAR, single, of legal age, Filipino citizen, with

residence and postal address at 89 Trancoville, Baguio City, hereinafter
referred to as the DONOR;

-in favor of-

INDIRA J. KINTANAR, single, of legal age, Filipino citizen, with

residence and postal address at 76 Ma. Basa, Pacdal, Baguio City,
hereinafter called the DONEE;

W I T N E S S E T H:

That the DONOR is the owner of a precious jewelries, more

particularly described as follows:

Pair of Amethyst Earrings

Gold Necklace with Sapphire Pendant
Silver Ring set with Aquamarine stone

That the DONEE is a cousin of the DONOR, who has lovingly

dedicated eight (8) years of her life as the latter's personal caregiver and
companion;

That FOR AND IN CONSIDERATION of the DONEE'S trust, devotion

and affection shown to the DONOR, and as an act of gratitude and liberality
on her part, the DONOR hereby voluntarily GIVES, TRANSFERS, and
CONVEYS by way of donation, unto the said DONEE, her heirs and assigns,
the above described personal properties, free from all liens and
encumbrances;

That the DONOR affirms that this donation is not made with intent to
deceive her creditors, and that she has reserved for herself sufficient funds
and property;

75
That the DONEE hereby ACCEPTS and RECEIVES this donation made
in her favor by the DONOR, and hereby manifests her gratefulness for the
latter's generosity.
IN WITNESS WHEREOF, both the DONOR and DONEE have
hereunder subscribed their names this 29 th day of November 2013, in the
City of Baguio, Philippines.

IRENE J. KINTANAR INDIRA J. KINTANAR

Donor Donee

SIGNED IN THE PRESENCE OF:

IVANNA J. KINTANAR IVANHOE J. KALAYAAN

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared IRENE J. KINTANAR and
INDIRA J. KINTANAR, who have satisfactorily proven to me their identities
through their Passport No. SS 2458413 valid until August 28, 2015 and
Professional Driver’s License No. AO41579360, respectively, that they are
the same persons who executed and voluntarily signed the foregoing Deed
of Donation which they acknowledged before me as their free and
voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
PTR No. 1928374/Baguio City/01-04-13
Doc. No. 34; Roll of Atty. No. 67548/05-18-10
Page No. 7;
Book No. I; 76
Series of 2013
IBP OR No. 739281/Baguio-Benguet/01-04-13
MCLE Compliance No. IV-90210/04-22-13
Commission Serial No. 01-NC-11 (R)
DEED OF DONATION OF A PORTION OF AN UNREGISTRED LAND

KNOW ALL MEN BY THESE PRESENTS:

This DEED OF DONATION OF A PORTION OF AN UNREGISTERED

LAND, is made and executed by and between:

JERRY K. LAMBERTO, married to JENNY K. LAMBERTO, of legal age,

Filipino citizen and with residence and postal address at 67 Liteng, Baguio
City, hereinafter referred to as the DONOR;

-in favor of-

JOEL K. LAMBERTO, single, of legal age, Filipino citizen and with

residence and postal address at 89 Everlasting St., Q.M. Subdivision, Baguio
City, hereinafter referred to as the DONEE;

W I T N E S S E T H:

That the DONOR is the owner in fee simple of that certain real
property situated in the City of Tabuk described as follows:

ASSESSMENT OF REAL PROPERTY NO.99-7537-86159

BOUNDARIES:
NORTH : Lot 5 SOUTH : Lot 7815
EAST : Lot 3 WEST : Lot 4
KIND : Camotal land
AREA : 6.8295 ha.
MARKET VALUE : Php 150,300.00
ASSESSED VALUE : Php 90,000.00

That the DONEE is the child of the DONOR, who has lovingly
dedicated his life as the latter's personal caregiver and companion;

That FOR and IN CONSIDERATION of the DONEE'S trust, devotion

and affection shown to the DONOR, and as an act of gratitude and liberality
77
on his part, the DONOR hereby voluntarily GIVES, TRANSFERS, and
CONVEYS by way of inter vivos donation, unto the said DONEE, his heirs
and assigns, one half (1/2) the above described property, together with all
the improvements found thereon, free from all liens and encumbrances;

That the DONOR affirms that this donation is not made with intent to
deceive her creditors, and that he has reserved for himself sufficient funds
and property;

That the DONEE hereby accepts and receives this donation made in
his favor by the DONOR, and hereby manifests his gratefulness for the
latter's generosity.

IN WITNESS WHEREOF, both the DONOR & DONEE have hereunder

subscribed their names this 29th day of November 2013, in the City of
Baguio, Philippines.

JERRY K. LAMBERTO WITH MY MARITAL CONSENT:

Donor
CTC No. 75185078 JENNY K. LAMBERTO
Issued on 01/15/2013 CTC No. 31759365
Issued at Baguio City Issued on 01/15/2013
Issued at Baguio City

JOEL K. LAMBERTO
Donee
CTC No. 75194629
Issued on 01/15/2013
Issued at Baguio City

SIGNED IN THE PRESENCE OF:

JEREMY K. LANUZA JENNIFER K. LERMA

78
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared JERRY K. LAMBERTO, JENNY
K. LAMBERTO, and JOEL K. LAMBERTO, who have satisfactorily proven to
me their identities through JENNIFER K. LERMA, who is personally known
to me and who personally knows the parties, that they are the same
persons who executed and voluntarily signed the foregoing Deed of
Donation of a Portion of an Unregistered Land which they acknowledged
before me as their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 35;

Page No. 7;
Book No. I;
Series of 2013

79
DEED OF EXCHANGE

KNOW ALL MEN BY THESE PRESENTS:

This DEED OF EXCHANGE, made and entered into by and between:

KATHERINE L. MOLINA, single, of legal age, Filipino Citizen, with

residence and postal address at 836 Mines View, Baguio City, Philippines,
hereinafter referred to as the FIRST PARTY;

-and-

KRISTINA L. MACEDA, single, of legal age, Filipino Citizen, with

residence and postal address at Pico, La Trinidad, Benguet, hereinafter
referred to as the SECOND PARTY.

W I T N E S S E T H:

WHEREAS, the FIRST PARTY is the owner and present possessor of a

parcel of land located at Pico, La Trinidad, Benguet with an area of FIVE
HUNDRED SIXTY (560) SQUARE METERS, more or less, covered by Tax
Declaration No. 05-421-75869, particularly described as follows:

“Bounded on the North by Section 09; on the south by

GLENDA L. LUNA; on the East by JERRY L. DAYAG; and on the
West by KLAIR L. ASKI; containing an area of Five Hundred Sixty
square meters located at Pico, La Trinidad, Benguet.”

WHEREAS, the SECOND PARTY is the owner and present possessor of

a certain parcel of land covered and embraced by Transfer Certificate of
Title No. T-84217 and more particularly described as follows:

“A parcel of land (lot 1, Psd-1-981298), situated in the

Bo.Ambiong, Mun. of La Trinidad, Province of Benguet, Island
of Luzon. Bounded on the NW. along line 1-2 by property of
Rhea Cachero; on the N. along line 2-3 by public land; on the E.
along line 3-4 by property of Shana Laurie Locano; on the S., &
SW., along lines 4-5-6-7-1 by Lot 2, Psd-1-981298. Beginning at
a point marked “1” on Lot 1, xxx
80
xxx containing an area of FIVE HUNDRED SIXTY (560) SQUARE
METERS. x xx”

WHEREAS, both PARTIES hereto have agreed to exchange their

respective properties covering an area of FIVE HUNDRED SIXTY (560)
SQUARE METERS from the above-described properties of both parties,
which are free from all liens and encumbrances of whatever kind and
nature;

WHEREAS, the FIRST PARTY thus hereby CEDE, TRANSFER, DELIVER

and CONVEY unto the SECOND PARTY its property located in Pico, La
Trinidad, Benguet as afore-described (A copy of the sketch plan of the
aforementioned property is hereto attached as ANNEX “A”). LIKEWISE, the
SECOND PARTY, hereby simultaneously CEDE, TRANSFER, DELIVER and
CONVEY unto the FIRST PARTY the aforementioned property;

WHEREAS, the PARTIES herein do hereby warrant that their

respective properties subject of this Deed of Exchange are free against any
claim from third person of whatever kind and nature;

WHEREAS, the provisions of Art. 1623 of the New Civil Code of the
Philippines has been complied with.

IN WITNESS WHEREOF, the PARTIES have hereunto affixed their

signatures this 29thday of November 2013, in the City of Baguio, Philippines.

KATHERINE L. MOLINA KRISTINA L. MACEDA

First Party Second Party

CTC No. 95721850 CTC No. 85721850

Issued on 02/17/2013 Issued on 01/28/2013
Issued at Baguio City Issued at La Trinidad, Benguet

SIGNED IN THE PRESENCE OF:

KARLO L. MIRALLES KENNETH L. MARAVILLA

ACKNOWLEDGMENT

81
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared KATHERINE L. MOLINA and
KRISTINA L. MACEDA, personally known to me to be the same persons who
voluntary executed the foregoing Deed of Exchange which they
acknowledged before me as their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 36;

Page No. 8;
Book No. I;
Series of 2013

DEED OF REAL ESTATE MORTGAGE OF A REGISTERED LAND

82
KNOW ALL MEN BY THESE PRESENTS:

This DEED OF REAL ESTATE MORTGAGE OF A REGISTERED LAND,

made and entered into by and between:

LAURA M. NAVARRO, single, of legal age, Filipino citizen, with

residence and postal address in 93 Brookside, Baguio City, hereinafter
referred to as the MORTGAGOR;

-and-

LEANDRO M. NISPEROS, married to LIZA M. NISPEROS, of legal age,

Filipino citizen and with residence and postal address at 10 Quezon Hill,
Baguio City, hereinafter referred to as the MORTGAGEE;

W I T N E S S E T H:

That the MORTGAGOR is indebted to the MORTGAGEE in the amount

of SIX HUNDRED THOUSAND PESOS (Php 600,000.00), Philippine Currency,
with THREE PERCENT (3%) monthly interest payable within a period of SIX
(6) MONTHS from and after the execution of this document or up to May
30, 2014;

That for and in consideration of the aforementioned debt of the

herein MORTGAGOR in the sum of SIX HUNDRED THOUSAND PESOS
(Php600,000.00), Philippine Currency, obtained from the MORTGAGEE, and
to secure the payment of the same and those others that the MORTGAGEE
may extend to the MORTGAGOR, including interest and expenses, and
other obligations owing by the MORTGAGOR to the MORTGAGEE, whether
direct or indirect, principal or secondary, the MORTGAGOR do hereby
transfer and convey by way of REAL ESTATE MORTGAGE unto the
MORTGAGEE, her successors and assigns, that PARCEL OF REGISTERED
LAND located along 28 Trancoville, Baguio City which is more particularly
described as follows, to wit:

TRANSFER CERTIFICATE OF TITLE

TECHNICAL DESCRIPTION

83
A parcel of Land (Lot 5, Blk. 11, Psd-1-014521, being a
portion of Lot 19, II-11894, L.R.C. Rec. No. ___), situated in the
Bo.Trancoville, City of Baguio, Island of Luzon. Bounded on the
SE., along line 6-1-2 by Lot 4, Blk. 11, on the SW., along line 2-3
by Alley Lot 5, on the NW., along line 3-4 by Lot 5, Blk. 11, on
the NE., along line 4-5-6 by Drainage I Lot 6, all of the Psd-1-
014521. Beginning at a point marked “1” of Lot 5 Blk. 11, on
plan being S. 4 deg. 13’W., 797.98 m. from B.L. No. 7, Baguio
Townsite, thence:

S. 86 deg. 16’W., 5.40 m. to point 2;

N. 51 deg. 24’W., 2.98 m. to point 3;
N. 3 deg. 44’W., 9.70 m. to point 4;

S. 83 deg. 29’E., 4.48 m. to point 5;

S. 51 deg. 08’E., 11.06 m. to point 6;
S. 51 deg. 41’W., 6.02 m. to point of beginning,

containing an area of ONE HUNDRED TWENTY (120) SQUARE

METERS, more or less. All points referred to are indicated on
the plan and are marked on the grounds as PS cyl. Conc. Mons.
15 x 60 cms., except, bearings true, date of original survey on
July 8-August 1916 date of subdivision survey on August 23,
1987 – July 15, 1988, executed by Engr. Lizardo Negro and
approved on Nov. 14, 1988.

including the residential house erected therein covered by ARP No.

2009-89-051-85139 of the records of the Assessor’s Office of Baguio City;

That, of which parcel of land, the MORTGAGOR is the absolute owner

and present possessor as evidenced by TCT NO.T-73169 of the records of
Register of Deeds of Baguio City, under Assessment of Real Property ARP
No. 2009-89-051-85139 (land) and (ARP) No. 2009-829-085--84164
(building) of the records of the City Assessor’s Office and Register of Deeds
of Baguio City, free from all liens and encumbrances;

That in case the MORTGAGOR executes subsequent promissory note

or notes either as a renewal of the former note, as an extension thereof, or
as a new loan, this mortgage shall also stand as security for the payment of
the said promissory note or notes and/or accommodations as if they were
existing on the date thereof;

84
That this mortgage shall also stand as security for said obligations
and all other obligations of the MORTGAGOR to the MORTGAGEE of
whatever kind and nature whether such obligations have been contracted
before, during or after the constitution of this mortgage;

However, if the MORTGAGOR shall pay the MORTGAGEE, his

successors or assigns, the obligations secured by this mortgage, together
with the interest, cost and other expenses, on or before the date they are
due, and shall keep and perform, then this mortgage shall be null and void,
otherwise, it shall remain in full force and effect;

That this Mortgage is constituted subjected to the following

conditions:

1. Should the MORTGAGEE become involved in any litigation which may

have relation with any or all of the properties mortgaged by virtue of
this instrument, all expenses of the MORTGAGEE in such litigation,
including a reasonable amount of attorney’s fees to be determined
by the MORTGAGEE, shall be paid by the MORTGAGOR and this
mortgage shall stand as security thereof, and in the event of such
litigation, any and all obligations of the MORTGAGOR shall likewise
become immediately due, payable and defaulted;

2. The MORTGAGOR shall not make any alteration upon or demolish

any building or buildings herein mortgaged or encumber the same,
without the prior written consent of the MORTGAGEE;

3. The MORTGAGEE may be a bidder at the sale of the mortgaged

properties under foreclosure proceedings;

4. The MORTGAGOR shall execute such other documents as may be

required by the MORTGAGEE in connection with the loans secured by
this mortgage contract subject to the mutual agreement of both
parties;

5. Should the MORTGAGOR duly pay or cause to be paid unto the

MORTGAGEE and the latter’s heirs and assigns, his total
indebtedness of SIX HUNDRED THOUSAND PESOS (Php 600,000.00),
Philippine Currency including its THREE PERCENT (3%) monthly
interest on or before May 30, 2014, then this mortgage shall thereby
be discharged and rendered of no force and effect. Otherwise, the
85
MORTGAGOR does hereby agree that MORTGAGEE, may enforce his
rights herein without judicial proceedings by causing the above-
described real property to be sold at public auction in Baguio City
where the property is situated in accordance with Act No. 3135, as
amended by Act No. 4118;

6. Effective upon the breach of any condition or stipulation of this

mortgage, the MORTGAGEE is hereby appointed by the MORTGAGOR
as his attorney-in-fact to sell or dispose of said property according to
Act No. 3135, as amended by Act No. 4118;

7. Should the MORTGAGOR fail to pay his debt of SIX HUNDRED

THOUSAND PESOS (Php 600,000.00), Philippine Currency including
its THREE PERCENT (3%) monthly interest, on May 30, 2014, said
MORTGAGOR does hereby agree to pay a penalty of 1% thereof per
month of delay effective on May 30, 2014;

8. Should the MORTGAGOR pay his debt before May 30, 2014, he will
only pay the principal amount of SIX HUNDRED THOUSAND PESOS
(Php 600,000.00), Philippine Currency plus accrued interests as of
the date of payment; and

9. The parties hereto agreed to record this instrument under Act No.
496, as amended and likewise under Act No. 3344.

IN WITNESS WHEREOF, the parties have hereunto set their hands in

Baguio City, Philippines, on this 29th day of November 2013.

LAURA M. NAVARRO LEANDRO M. NISPEROS

Mortgagor Mortgagee

SIGNED IN THE PRESENCE OF:

LYDIA M. NAVALO LERMA M. NATANAEL

ACKNOWLEDGMENT

86
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared LAURA M. NAVARRO and
LEANDRO M. NISPEROS, who have satisfactorily proven to me their
identities through:

LYDIA M. NAVALO with Taxpayer Identification Number 632-854-738

LERMA M. NATANAEL, with Taxpayer Identification Number 745-217-937

both of whom personally know the parties, that they are the same persons
who executed and voluntarily signed the foregoing Deed of Real Estate
Mortgage of a Registered Land which they acknowledged before me as
their free and voluntary acts and deeds.

This instrument consisting of FIVE (5) 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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 37;

Page No. 8;
Book No. I;
Series of 2013

DEED OF REAL ESTATE MORTGAGE OF AN UNREGISTERED LAND

87
KNOW ALL MEN BY THESE PRESENTS:

This DEED OF REAL ESTATE MORTGAGE OF AN UNREGISTERED LAND

made and executed by and between:

MARTHA N. OANARI, of legal age, single, Filipino citizen, and with

residence and postal address at 25 Leonard Wood Road, Baguio City
hereinafter known as the MORTGAGOR.

-and-

MARCUS N. OANDASAN, of legal age, married to MARIELLA N.

OANDASAN, Filipino citizen, with residence and postal address at 71
Engineers Hill, Baguio City hereinafter known as the MORTGAGEE.

W I T N E S S E T H:

That the MORTGAGOR is the lawful, absolute and exclusive owner

and actual possessor of a property free from all liens and encumbrances
particularly described as follows:

“An orchard located at Lingsat, San Fernando, La Union

declared under Tax Declaration No. 52540 with an area of 300
square meters, more or less, bounded by monuments and no
permanent structure. Bounded on the North by Lot No. 1448-
B; on the East by Lot No. 4556; on the South by Gomez St; and
on the West by Lot No. 1337-A and B”.

That the MORTGAGOR, for and in consideration of the sum of SIX

HUNDRED THOUSAND PHILIPPINE PESOS (Php 600,000.00), received from
the MORTGAGEE, does hereby mortgage unto the said MORTGAGEE, his
heirs and assigns, the above-described real property including its
improvements;

That the herein parties have agreed that the above-mentioned loan
shall earn interest of EIGHT (8%) percent monthly for a period of TEN (10)
months from execution of this contract;

That advance payment of TEN (10%) percent for one (1) month shall
be paid upon execution of this contract with the subsequent interest to be

88
paid on the 30th day of every month thereafter up to the duration of this
contract;

That this Deed of Real Estate Mortgage of an Unregistered Land may

be renewed upon option of the parties under such terms and conditions
acceptable to them;

That during the enforcement/term of this contract, the

MORTGAGOR shall not enter into any contract that may encumber the
above-described property unless with the express and written consent of
the MORTGAGEE;

That in case of non-payment by the MORTGAGOR of the herein

amount and the MORTGAGEE is compelled to pursue foreclosure
proceedings, the MORTGAGOR does hereby agree that the said
MORTGAGEE may enforce his rights herein without judicial proceedings by
causing the above-described property in accordance with Act No. 3135 as
amended by Act No. 4118;

That the cost of publication, sale, collection, attorney’s fees, taxes

and charges in relation to the foreclosure sale shall be borne by the
MORTGAGOR; and

That the parties do hereby agree to register the Real Estate Mortgage
pursuant to the provisions of Act 3135 as amended by Act No. 4118.

IN WITNESS WHEREOF, we have hereunto signed this deed of sale,

this 29th day of November 2013, in Baguio City, Philippines.

MARTHA N. OANARI MARCUS N. OANDASAN

Mortgagor Mortgagee

SIGNED IN THE PRESENCE OF:

MATILDE N. ORIGINAL MACARIO N. ORDINARIO

ACKNOWLEDGMENT
89
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared MARTHA N. OANARI and
MARCUS N. OANDASAN, personally known to me to be the same persons
who voluntary executed the foregoing Deed of Real Estate Mortgage of an
Unregistered Land which they acknowledged before me as their free and
voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 38;

Page No. 8;
Book No. I;
Series of 2013

DEED OF SALE OF A SUBDIVIDED REGISTERED LAND

90
KNOW ALL MEN BY THESE PRESENTS:

This DEED OF SALE OF A SUBDIVIDED REGISTERED LAND, made and

executed by and between:

NANCY O. PACIS, of legal age, single, Filipino citizen, and with

residence and postal address at 46 Pacdal, Baguio City hereinafter known as
the VENDOR.

-and-

NICOLLO O. PASADENA, of legal age, married to NICOLLETE O.

PASADENA, Filipino citizen, with residence and postal address at 171
Engineers Hill, Baguio City hereinafter known as the VENDEE.

W I T N E S S E T H:

That the VENDOR is the absolute owner of a certain parcel of land

situated in Trancoville, Baguio City, covered by Transfer Certificate of Title
No. T-465836 issued by the Registry of Deeds of Baguio City, and more
particularly described as follows:

TRANSFER CERTIFICATE OF TITLE

TECHNICAL DESCRIPTION

A parcel of Land (Lot 5, Blk. 11, Psd-1-014521, being a

portion of Lot 19, II-11894, L.R.C. Rec. No. ___), situated in the
Bo.Trancoville, City of Baguio, Island of Luzon. Bounded on the
SE., along line 6-1-2 by Lot 4, Blk. 11, on the SW., along line 2-3
by Alley Lot 5, on the NW., along line 3-4 by Lot 5, Blk. 11, on
the NE., along line 4-5-6 by Drainage I Lot 6, all of the Psd-1-
014521. Beginning at a point marked “1” of Lot 5 Blk. 11, on
plan being S. 4 deg. 13’W., 797.98 m. from B.L. No. 7, Baguio
Townsite, thence:

S. 86 deg. 16’W., 5.40 m. to point 2;

N. 51 deg. 24’W., 2.98 m. to point 3;

91
N. 3 deg. 44’W., 9.70 m. to point 4;

S. 83 deg. 29’E., 4.48 m. to point 5;

S. 51 deg. 08’E., 11.06 m. to point 6;
S. 51 deg. 41’W., 6.02 m. to point of beginning,

containing an area of ONE HUNDRED TWENTY(120) SQUARE

That the VENDEE has offered to buy and the VENDOR has agreed to
sell a portion of the above described property, pending its subdivision in
accordance with law, for a price and under the terms and conditions herein
set forth;

Therefore, for and in consideration of the sum of SIX HUNDRED FIFTY

THOUSAND PESOS (Php 650,000.00), the receipt whereof is hereby
acknowledged from the VENDEE, the VENDOR does hereby sell, transfer
and convey in a manner absolute and irrevocable unto the VENDEE, his/her
heirs and assigns that certain portion of the land above;

That the VENDOR does hereby warrant valid title to and peaceful
possession of, the portion of land herein sold and conveyed, and will
defend the same unto the said VENDEE his/her heirs and assigns against
the claims of third persons whomsoever;

That the parties hereto hereby agree that within a period of SIXTY
(60) days from and after the execution of this instrument, the VENDOR shall
engage the services of a licensed geodetic engineer to undertake the
preparation of the necessary survey plan of subdivision, segregating the
definite portion object of this sale, and submit the same to the proper
government authorities for verification and approval in accordance with
law;

92
That pending approval of the subdivision plan, the parties hereto
have agreed to register this Deed of Sale in the Office of the Register of
Deeds concerned by way of memorandum: annotation on the
corresponding certificate of title as permitted under the provision of
Section 58 of Act 496, as amended with the understanding that upon the
final approval of said subdivision plan and the corresponding technical
description of the resulting lots, certified copy thereof shall forthwith be
filed with the Register of Deeds to enable him to effect the segregation
process by the issuance of a new certificate of title in the name of the
herein VENDEE for the portion of land sold and another certificate in the
name of the herein VENDOR for the portion remaining;

That the parties further agree that the expenses incident to the
survey of the land shall be deemed to be included in the consideration of
this sale, and that the attorney’s fees for the preparation of the necessary
deed and other legal papers as well as the requisite documentary stamps
shall be for the account of the VENDOR, while the registration fees to be
payable to the Register of Deeds and transfer tax shall be for the account of
the VENDEE.

IN WITNESS WHEREOF, we have hereunto signed this Deed of Sale,

this 29th day of November 2013, in Baguio City, Philippines.

NANCY O. PACIS NICOLLO O. PASADENA

Vendor Vendee

SIGNED IN THE PRESENCE OF:

NORMAN O. PANATA NICASIO O. POLICARPIO

93
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared NANCY O. PACIS and NICOLLO
O. PASADENA who have satisfactorily proven to me their identities through
NORMAN O. PANATA, who is personally known to me and who personally
knows the parties, that they are the same persons who executed and
voluntarily signed the foregoing Deed of Sale of a Subdivided Registered
Land and acknowledged to me that the same is their free and voluntary
acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 39;

Page No. 8;
Book No. I;
Series of 2013

94
DEED OF SALE OF A FRANCHISE OF A PUBLIC UTILITY VEHICLE

KNOW ALL MEN BY THESE PRESENTS:

This DEED OF SALE OF A FRANCHISE OF A PUBLIC UTILITY VEHICLE,

made and executed by and between:

OMAR P. QUIRINO, single, of legal age, Filipino citizen, with

residence and postal address at 725 Wangal, La Trinidad, Benguet,
Philippines, hereinafter referred to as the VENDOR;

-and-

OSCAR P. QUINTANA, single, of legal age, Filipino citizen, with

residence and postal address at 21 Lower Burgos, Baguio City, Philippines,
hereinafter referred to as the VENDEE;

W I T N E S S E T H:

WHEREAS, the VENDOR is the lawful owner of a Certificate of Public

convenience to Operate a Taxi Service issued by the Land Transportation
Franchising and Regulatory Board, Cordillera Administrative Region, Baguio
City under case No. 2006-CAR-165;

WHEREAS, for and in consideration of the sum of ONE HUNDRED

TWENTY THOUSAND PESOS (Php 120,000.00), Philippine Currency, to me
in hand and the receipt whereof is hereby acknowledged from the VENDEE
to my entire satisfaction does by these present sell, transfer and convey, in
favor of the VENDEE his heirs and assigns the above mentioned Franchise
free and clear of all liens and encumbrances;

WHEREAS, the VENDOR hereby warrants good and clean ownership

over that Franchise and that his rights, interests and participation over it
has not been previously alienated, sold nor transferred to any third party,
whomsoever;

That the VENDOR shall defend the possession and ownership of the
above-mentioned Franchise of the VENDEE, against any possible claim of
ownership by any third party and adverse claimants; and

That the VENDOR is executing this deed of sale freely and voluntary
and for all legal intents and purposes that it may serve.

IN WITNESS WHEREOF, the PARTIES have hereunto set their hands

this 29th day of November 2013, in the City of Baguio, Philippines.
95
OMAR P. QUIRINO OSCAR P. QUINTANA
Vendor Vendee
CTC No. 63183279 CTC No. 84631740
Issued on 01/3/2013 Issued on 01/5/2013
Issued at La Trinidad, Benguet Issued at Baguio City

SIGNED IN THE PRESENCE OF :

ORAL P. QUIROGA ORCHIDIA P. QUINTO

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared OMAR P. QUIRINO and
OSCAR P. QUINTANA, personally known to me to be the same persons who
voluntary executed the foregoing Deed of Sale of Franchise of a Public
Utility Vehicle which they acknowledged before me as their free and
voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
PTR No. 1928374/Baguio City/01-04-13
Doc. No. 40; Roll of Atty. No. 67548/05-18-10
Page No. 8; IBP OR No. 739281/Baguio-Benguet/01-04-13
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2013 Commission Serial No. 01-NC-11 (R)
DEED OF SALE OF HEAVY EQUIPMENT

96
KNOW ALL MEN BY THESE PRESENTS:

This DEED OF SALE OF HEAVY EQUIPMENT, made and executed by

and between:

PETER Q. RIVERA, single, of legal age, Filipino Citizen, with residence

and postal address at 87 Gibraltar, Baguio City, Philippines, hereinafter
referred to as the VENDOR;

-and-

PAUL Q. RAMIREZ, single, of legal age, Filipino Citizen, with residence

and postal address at 138 Victoria Village, Quezon Hill, Baguio City,
Philippines, hereinafter referred to as the VENDEE;

W I T N E S S E T H T H A T:

The VENDOR is the owner of a heavy equipment, which is particularly

described hereunder, to wit:

ONE (1) UNIT HEAVY EQUIPMENT

Equipment name: Truck

Product Group: CONS
Bore & Stroke: 140x152mm [5.50 x 6.00 cu in]
Displacement: 14 liter [855cu in]
Aspiration: Turbocharged
Configuration: In-line 6 Cylinder
Length mm/in: 1661/65
Width mm/in: 934.6/36.79
Height mm/in: 1745.8/68.73
Weigh kg/lb: 1258/2770

The VENDOR agreed to sell and the VENDEE is willing to buy the
above-described heavy equipment;

For and in consideration of the total sum of THREE HUNDRED

THOUSAND TWO HUNDRED FIFTY PESOS (Php 300,250.00), PHILIPPINE
CURRENCY, receipt of said total purchase price is hereto acknowledged by
the VENDOR, paid by the VENDEE to the VENDOR, the VENDOR by these
present hereby does SELL, TRANSFER and CONVEY, unto the said VENDEE,
her heirs and assigns the above-described heavy equipment;
The VENDOR hereby warrants that the above-described heavy
equipment is free from liens and encumbrances.
97
IN WITNESS WHEREOF, the parties have hereunto set their hands
this 29th day of November 2013, in the City of Baguio, Philippines.

PETER Q. RIVERA PAUL Q. RAMIREZ

Vendor Vendee

SIGNED IN THE PRESENCE OF:

PRIMITIVO Q. REA PONCIANO Q. REY

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared PETER Q. RIVERA and PAUL Q.
RAMIREZ personally known to me to be the same persons who executed
and signed the foregoing Deed of Sale of Heavy Equipment which they
acknowledged before me as their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
PTR No. 1928374/Baguio City/01-04-13
Doc. No. 41; Roll of Atty. No. 67548/05-18-10
Page No. 9; IBP OR No. 739281/Baguio-Benguet/01-04-13
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2013 Commission Serial No. 01-NC-11 (R)
DEED OF SALE OF IMPROVEMENTS
WITH SIMULTANEOUS TRANSFER OF RIGHTS
98
KNOW ALL MEN BY THESE PRESENTS:

This DEED OF SALE OF IMPROVEMENTS WITH SIMULTANEOUS

TRANSFER OF RIGHTS, made and executed by and between:

QUEENALYN R. SILVERIO, single, of legal age, Filipino Citizen, with

residence and postal address at 328 Aurora Hill, Baguio City, Philippines
hereinafter referred to as the TRANSFEROR;

-and-

QUENTINE R. SALAZAR, single, of legal age, Filipino Citizen, with

residence and postal address at 172 Pias St., Camp 7, Baguio City,
Philippines, hereinafter referred to as the TRANSFEREE;

W I T N E S S E T H T H A T:

1. The TRANSFEROR is the exclusive/absolute owner and possessor of

that certain registered parcel of land situated in Alapang, La Trinidad,
Benguet, Philippines, covered by TRANSFER CERTIFICATE OF TITLE
No. T-73163 issued by the Register of Deeds of Benguet and more
specifically described as follows, to wit:

TCT No. T-73163

A parcel of land (Lot 98-B, Psd-1-008521, being a

xxx containing an area of TWO HUNDRED SIXTY FIVE

(265) SQUARE METERS, more or less. xxx

2. The TRANSFEROR agreed to sell and the TRANSFEREE is willing to buy

the above-described parcel of registered land including all its
improvements;

99
3. For and in consideration of the total sum of NINETY THOUSAND
EIGHT HUNDRED PESOS (Php 90,800.00), PHILIPPINE CURRENCY,
receipt of said total purchase price is hereto acknowledged by the
TRANSFEROR, paid by the TRANSFEREE to the TRANSFEROR, the
TRANSFEROR by these present hereby SELL, TRANSFER and CONVEY,
unto the said TRANSFEREE, their heirs and assigns the above-
described parcel of REGISTERED LAND including all improvements;

4. It is hereby declared that the boundaries of the foregoing land are

visible by means of natural and man-made boundaries as shown in
the survey plan of the above-described parcel of land;

5. The TRANSFEROR hereby warrants that the above-described parcel

of land is free from liens and encumbrances and further warrants the
peaceful possession by the TRANSFEREE of the hereto sold property;

6. Further, that the requirements under the provisions of Article 1623

of the New Civil Code have been complied with.

IN WITNESS WHEREOF, the parties have hereunto set their hands

this 29th day of November 2013, in the City of Baguio, Philippines.

QUEENALYN R. SILVERIO QUENTINE R. SALAZAR

Transferor Transferee
CTC No. 3826789 CTC No. 52705148
Issued on 02/16/2013 Issued on 01/21/2013
Issued at Baguio City Issued at Baguio City

SIGNED IN THE PRESENCE OF :

QUIRINO R. SIMBORIO QUINTA R. SABALBORO

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.
100
BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared QUEENALYN R. SILVERIO and
QUENTINE R. SALAZAR, who have satisfactorily proven to me their identity
through their Passport No. SS7489146 valid until December 25, 2014 and
Professional Driver’s License No. AO58357136, respectively, that they are
the same persons who executed and voluntarily signed the foregoing Deed
of Sale of Improvements with Simultaneous Transfer of Rights which they
acknowledged before me as their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 42;

Page No. 9;
Book No. I;
Series of 2013

DEED OF SALE OF A MOTOR VEHICLE ENGINE

KNOW ALL MEN BY THESE PRESENTS:

101
This DEED OF SALE OF A MOTOR VEHICLE ENGINE, made and
executed by and between:

REGINO S. TANTOCO, single, of legal age, Filipino Citizen, with

residence and postal address at 48 Gibraltar, Baguio City, Philippines
hereinafter referred to as the VENDOR;

-and-

RONALDO S. TENEDERO, single, of legal age, Filipino Citizen, with

residence and postal address at 318 Victoria Village, Quezon Hill, Baguio
City, Philippines, hereinafter referred to as the VENDEE;

W I T N E S S E T H T H A T:

The VENDOR is the owner a motor vehicle engine, which is

particularly described hereunder, to wit:

ONE (1) UNIT MOTOR VEHICLE ENGINE

Make: Ford Mustang

Year: 1994
VIN Number: 3FALP5
Engine Number: E9P
Transmission Number: 8317

The VENDOR agreed to sell and the VENDEE is willing to buy the
above-described vehicle engine;

For and in consideration of the total sum of FIFTY THOUSAND PESOS

(Php 50,000.00), PHILIPPINE CURRENCY, receipt of said total purchase price
is hereto acknowledged by the VENDOR, paid by the VENDEE to the
VENDOR, the VENDOR by these present hereby does SELL, TRANSFER and
CONVEY, unto the said VENDEE, her heirs and assigns the above-described
motor engine;

The VENDOR hereby warrants that the above-described engine is

free from liens and encumbrances.

IN WITNESS WHEREOF, the parties have hereunto set their hands

this 29th day of November 2013, in the City of Baguio, Philippines.

102
REGINO S. TANTOCO RONALDO S. TENEDERO
Vendor Vendee
Passport No. SS 7562957 Professional Driver’s License
valid until November 15, 2014 No. AO95621759
valid until Sept. 15. 2016

SIGNED IN THE PRESENCE OF:

ROGER S. TANJUATCO RAMONCITO S. TINDALO

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared REGINO S. TANTOCO and
RONALDO S. TENEDERO who exhibited to me their respective identification
documents as indicated below their respective names and signatures,
known to me as the same persons who executed and voluntarily signed the
foregoing Deed of Sale of a Motor Vehicle Engine which they
acknowledged before me as their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
PTR No. 1928374/Baguio City/01-04-13
Doc. No. 43; Roll of Atty. No. 67548/05-18-10
Page No. 9; IBP OR No. 739281/Baguio-Benguet/01-04-13
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2013 Commission Serial No. 01-NC-11 (R)
DEED OF SALE OF A MOTOR VEHICLE WITH FRANCHISE

103
KNOW ALL MEN BY THESE PRESENTS:

This DEED OF SALE OF A MOTOR VEHICLE WITH FRANCHISE, made

and executed by and between:

STEPHEN T. URIARTE, single, of legal age, Filipino citizen, with

residence and postal address at 25 Wangal, La Trinidad, Benguet,
Philippines, hereinafter referred to as the VENDOR;

- and-

SEBASTIAN T. UJANO, single, of legal age, Filipino citizen, with

residence and postal address at 12 Lower Burgos, Baguio City, Philippines,
hereinafter referred to as the VENDEE;

W I T N E S S E T H:

Whereas, the VENDOR is the owner a motor vehicle, hereinafter

referred to as “Personalty” which is particularly described hereunder, to
wit:

ONE (1) UNIT MOTOR VEHICLE

Whereas, the VENDOR is also the lawful owner of a Certificate of

Public convenience to Operate a Taxi Service issued by the Land
Transportation Franchising and Regulatory Board, Cordillera Administrative
Region, Baguio City under case No. 2006-CAR-165;
Whereas, for and in consideration of the sum of ONE HUNDRED
EIGHTY THOUSAND PESOS (Php 180,000.00), Philippine Currency, to me in
hand and the receipt whereof is hereby acknowledged from the VENDEE to
my entire satisfaction does by these present SELL, TRANSFER and CONVEY,
104
in favor of the VENDEE his heirs and assigns the above mentioned Motor
Vehicle with Franchise free and clear of all liens and encumbrances.

Whereas, the VENDOR hereby warrants good and clean ownership

over that motor vehicle with franchise and that his rights, interests and
participation over it has not been previously alienated, sold nor transferred
to any third party, whomsoever;

That the VENDOR shall defend the possession and ownership of the
above-mentioned motor vehicle with franchise of the VENDEE, against any
possible claim of ownership by any third party and adverse claimants;

Finally, that the VENDOR is executing this deed of sale freely and
voluntary and for all legal intents and purposes that it may serve.

IN WITNESS WHEREOF, the PARTIES have hereunto set their hands

this 29th day of November 2013, in the City of Baguio, Philippines.

STEPHEN T. URIARTE SEBASTIAN T. UJANO

Vendor Vendee
CTC No. 63183279 CTC No. 84631740
Issued on 01/3/2013 Issued on 01/5/2013
Issued at La Trinidad, Benguet Issued at Baguio City

SIGNED IN THE PRESENCE OF :

SALLY T. UNTALAN SAMANTHA T. UMALI

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

105
BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared STEPHEN T. URIARTE and
SEBASTIAN T. UJANO, personally known to me to be the same persons who
voluntary executed the foregoing Deed of Sale of a Motor Vehicle with
Franchise which they acknowledged before me as their free and voluntary
acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 44;

Page No. 9;
Book No. I;
Series of 2013

DEED OF UNDERTAKING

106
I, TRAVIS U. VILLANUEVA, of legal age, Filipino citizen, married and
the incumbent Mayor of Urdaneta City, Pangasinan, after having duly
sworn in accordance with the law hereby voluntarily depose and say:

1. That the City Government of Tuguegarao is the consignee of a

shipment of two (2) units Schindler Elevator 5385MRL, 1450KG.,
1.2MPS, 4stops/opening which comes with miscellaneous spare parts
and accessories covered by Bill of Lading No. 4758-8462-857.847.

2. That under the provision of Section of Section 382 of Title Six, Book II
of Republic Act No. 7160 otherwise known as “THE NEW LOCAL
GOVERNMENT CODE”, we, as a local government unit, shall be
exempt of duties and taxes for the importation of machines,
equipments, tools, supplies and spare parts;

3. That upon release and possession of the said shipment, and in

consideration of said privilege, the words “ENTERED DUTY-TAX-FREE
UNDER THE NEW LOCAL GOVERNMENT CODE”, shall be printed in a
conspicuous space on the machinery and equipment which was
accorded duty and tax release;

4. That I am executing this Undertaking to attest to the truth of the

foregoing facts.

IN WITNESS WHEREOF, I have hereunto set my hand this 29 th day of

November 2013, in Baguio City, Philippines.

TRAVIS U. VILLANUEVA
Affiant

SUBSCRIBED AND SWORN to before me in the City of Baguio this 29 th

day of November 2013, by TRAVIS U. VILLANUEVA, who has satisfactorily
proven his identity to me through his Professional Driver’s License No. A03-
107
72047 valid until August 26, 2014, that he is the same person who
personally signed the foregoing Undertaking before me.

JUAN DE LA CRUZ JR.

Doc. No. 45;

Page No. 9;
Book No. I;
Series of 2013

DEED OF WAIVER OF RIGHTS

108
KNOW ALL MEN BY THESE PRESENTS:

This DEED OF WAIVER OF RIGHTS, made and executed into by and

between:

VICTOR U. YAP, married to VICTORIA U. YAP, Filipino citizen, of legal

age, with residence and postal address at 63 Quezon Hill, Baguio City,
Philippines, hereinafter referred to as the WAIVOR;

-in favor of-

ZACHARY W. UMINGAN, married to ZEALEA W. UMINGAN, Filipino

citizen, of legal age, with residence and postal address at 89 New Lucban,
Baguio City, Philippines, hereinafter referred to as the WAIVEE;

W I T N E S S E T H:

Whereas, in a certain public document executed on March 1, 2013,

the WAIVOR sold under Pacto de Retro unto the WAIVEE certain real
estates situated in 28, Sanitary Camp and 56, Trancoville, Baguio City and
more particularly described as follows, to wit:

A PARCEL OF LAND situated in Sanitary Camp, Baguio

City containing an area of SIX HUNDRED (600) square meters
more or less. xxx Bounded on the E-along lines1-2-3, Lot 32; on
the N-along lines 3-4 Lot 33: on the W- along lines 4-5-6-7, Lot
43; and on the S- along lines 7-8-1, Lot 54, all Cad 405-D,
Baguio cadastre.

II.

A PARCEL OF LAND (Lot 20 Blk 54 of consolidation

subdivision plan (LRC) Pcs-13265, being a portion of the
consolidation of Lots 4751-A and 4751-B (LRC) Psd-50533, Lot
3, Psd-100703, Lot 1, Psd-150980, LRC Rec. Nos. Nos. N-27024,
51768, 89632, N-11782, N-13466, and 21071 situated in
Trancoville, City of Baguio, Prov. of Benguet, Is. of Luzon.
Bounded on NE., point 4 to 1 by Road Lot 22, on...to the point
of beginning; containing an area of (280) square meters more
or less..." xxx
said property being covered by Original Certificate of Title Nos. 957427 and
967276, respectively, issued by the Register of Deeds of Baguio City;

109
Whereas, in accordance with the stipulation contained in said public
instrument, the WAIVOR has reserved the right to redeem the subject
properties within a period of one (1) year from and after the date of
execution thereof;

Whereas, the WAIVOR is willing to renounce and waive his right to

redeem said properties for valuable consideration, which the WAIVEE has
agreed to pay more specifically mentioned herein below;

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

MILLION PESOS (PHP 3,000,000.00), Philippine Currency, in addition to the
original purchase price, which additional sum the WAIVOR hereby
acknowledges to have received from the WAIVEE to his entire satisfaction,
the said WAIVOR does by these presents renounce and waive all his rights
and interests in and to the real properties above-described, more
specifically the right to redeem which he has reserved unto himself by
virtue of the above described public instrument executed on March 1, 2013
duly inscribed in the corresponding Certificate of Title as per entry Nos.
2859 and 2614, and as a consequence of this waiver, the WAIVEE has
become the henceforth the sole and absolute owner of the subject
properties without any reservation in favor of the WAIVOR.

IN WITNESS WHEREOF, the parties hereunto set their hands this 29 th

day of November 2013, in the City of Baguio, Philippines.

VICTOR U. YAP WITH MY MARITAL CONSENT:

Waivor
CTC No. 84217593
Issued on 01/12/2013 VICTORIA U. YAP
Issued at Baguio City

ZACHARY W. UMINGAN
Waivee
CTC No. 84164784
Issued on 01/29/2013
Issued at Baguio City

SIGNED IN THE PRESENCE OF:

VICENTE U. YARCIA ZENAIDA W. UMILI

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

110
CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 29 th
day of November 2013, personally appeared VICTOR U. YAP, VICTORIA U.
YAP, and ZACHARY W. UMINGAN, who have satisfactorily proven their
identities through:

VICENTE U. YARCIA with Taxpayer Identification Number 222-333-555

ZENAIDA W. UMILI with Taxpayer Identification Number 555-677-890

both of whom personally know the parties, that they are the same persons
who executed and voluntarily signed the foregoing Deed of Waiver of
Rights (over Registered Land) which they acknowledged before me as their
free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 46;

Page No. 10;
Book No. I;
Series of 2013

111
AGREEMENT

KNOW ALL MEN BY THESE PRESENTS:

This AGREEMENT entered into by and between:

ARTHUR B. CRUZ, of legal age, Filipino citizens, with residence at

Buguias, Benguet, herein referred to as the FIRST PARTY;

-and-

DELILAH E. FRANCO, of legal age, Filipino Citizen with residence at

New Lucban, Baguio City, Philippines, herein referred to as the SECOND
PARTY;

W I T N E S S E T H:

Whereas, the FIRST PARTY is the registered owner of that TEN

WHEELER TRUCK bearing plate number AYI 223, while the SECOND PARTY
is a businesswoman duly authorized to haul scrap materials from Benguet
Corporation, Balatoc, Itogon, Benguet;

Whereas, the SECOND PARTY hereby leased from the FIRST PARTY
the aforementioned truck to haul scrap materials owned by Benguet
Corporation from the Balatoc Mines starting on December 13, 2013 up to
June 20, 2015, and the latter on the other hand agreed to lease out the
same to the former;

Whereas, this agreement was entered into freely and voluntarily by

and between the parties and they shall faithfully and religiously comply
with the terms hereof.

IN WITNESS WHEREOF, parties herein affixed their signatures this 6 th

day of December 2013 in the City of Baguio, Philippines.

ARTHUR B. CRUZ DELILAH E. FRANCO

First Party Second Party
Professional Driver’s TIN 777-980-555
License No. A01-01-010293
valid until July 6, 2015

112
SIGNED IN THE PRESENCE OF:

GERTRUDE H. ISIDRO JUANITO K. LACSAMANA

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared ARTHUR B. CRUZ and DELILAH E.
FRANCO, who exhibited to me their respective identification documents
appearing below their names and signatures, both known to me to be the
same persons who executed and voluntarily signed the foregoing
Agreement and which they acknowledged before me as their free and
voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 47;

Page No. 10;
Book No. I;
Series of 2013

113
COMPROMISE AGREEMENT

KNOW ALL MEN BY THESE PRESENTS:

This COMPROMISE AGREEMENT executed by and among:

BENITO C. DE LA CRUZ, BENVOLIO C. DE LA CRUZ, BRUTUS C. DE LA

CRUZ, all of legal ages, Filipinos, all married, with postal address at DE LA
CRUZ LAW OFFICES, 7F Citylight Tower, Bonifacio Rd., Baguio City, herein
represented by BENITO C. DE LA CRUZ by virtue of a Special Power of
Attorney executed on November 25, 2013, and hereinafter referred to as
the FIRST PARTIES;

-and-

BAGUIO METROPOLITAN DOCTORS, INC., doing business under the

name and style as PINES METROPOLITAN MEDICAL CENTER, a corporation
duly organized and existing under Philippine laws, with business address at
3 Camdas, Baguio City, herein represented by its Medical Director, CESARIO
D. ENTRADA, M.D., hereinafter referred to as the SECOND PARTY;

-and-

DIEGO E. FORTUNA, M.D., of legal age, Filipino, single, with business

address at PINES METROPOLITAN MEDICAL CENTER, 3 Camdas, Baguio
City, hereinafter referred to as the THIRD PARTY;

W I T N E S S E T H:

Whereas, the FIRST PARTIES are the plaintiffs in Civil Case No. 95-
9233, entitled “BENITO C. DE LA CRUZ, et al., versus BAGUIO
METROPOLITAN DOCTORS, INC, et al." pending in the Regional Trial Court
of Baguio City, Branch 6, hereinafter referred to as the "Pending Case";

Whereas, the SECOND PARTY and THIRD PARTY are the defendants
in said Pending Case;

Whereas, all the parties are desirous of settling amicably the Pending
Case, which has been pending for almost eight (8) years, and thereby put to
rest a long and costly litigation;

NOW, THEREFORE, in consideration of the foregoing premises, the

parties hereby undertake as follows:

114
1. The SECOND PARTY shall voluntarily undertake the following:

1.1.To make available to BENITO C. DE LA CRUZ a private room

at the Makati Medical Center which is appropriate and
adequate, considering his present medical condition,
including the continued use of the hospital bed he is now
using and a sofa bed, all free of charge and for as long as
he remains clinically alive and in need of medical attention;
and,

1.2.To provide BENITO C. DE LA CRUZ, likewise free of charge,

medicine, drugs, life-support systems, medical equipment
and other facilities, medical assistance, neurological
treatment and other appropriate medical services from
competent nurses, doctors or specialists – which may be
advisable or necessary to maintain him in his present
condition, including treatment of complications or illnesses
of whatever kind or nature which may arise from said
treatment or condition.

2. The THIRD PARTY, undertake to make available his expertise or

services when and as needed by BENITO C. DE LA CRUZ, upon
request by the FIRST PARTIES or the SECOND PARTY: Provided,
that, if for any reason whatsoever the THIRD PARTY is unable to
do so, he shall exert his best efforts to make available the services
of a substitute doctor or specialist, likewise free of charge.

3. The parties agree to, and shall cause, the dismissal, with
prejudice, of the Pending Case, including all claims and
counterclaims therein, and agree not to file any similar case,
whether civil, administrative or criminal, of any kind or nature
whatsoever, arising from the same facts, incident, claim, cause or
causes of action.

4. Except as provided in paragraphs 1 and 2 hereof, the parties

hereby mutually, irrevocably, freely and voluntarily release and
forever discharge one another, including the officers, directors,
employees, stockholders, successors-in-interest of the SECOND
PARTY and the heirs and assigns of the THIRD PARTY, from any
and all manner of action, causes of action, sum of money,
damages, liability, responsibility, obligation, claims and demands
whatsoever in law or equity, which they had, now have, or may
have against each other, including, but not limited to, actual,
moral, exemplary and all other damages or causes of action
provided for under the law, if any, arising, directly or indirectly,
115
from the facts and circumstances giving rise to, surrounding or
arising from the complaint and/or counterclaims in the Pending
Case , all of which claims or causes of action by these presents the
parties hereby abandon and waive.

5. This agreement shall not in any way be construed as an admission

on the part of any party of any fault, negligence or liability, of
whatever kind and nature, in connection with the Pending Case.

6. In case of material breach of the terms and conditions of this

agreement, the innocent party is hereby authorized to apply for a
writ of execution in the Pending Case for the purpose of
compelling compliance with the terms and conditions of this
agreement.

IN WITNESS WHEREOF, the parties have hereunto set their hands

th
this 6 day of December 2013 in the City of Baguio, Philippines.

FIRST PARTIES: BENITO C. DE LA CRUZ

For Himself and in behalf of BENVOLIO C.
DE LA CRUZ and BRUTUS C. DE LA CRUZ
Professional Driver’s License
No. A01-09-180755
Valid until July 18, 2014

SECOND PARTY: CESARIO D. ENTRADA, M.D.

In behalf of BAGUIO
METROPOLITAN DOCTORS, INC.
PRC License No.0-34932285
Valid until June 16, 2015

THIRD PARTY: DIEGO E. FORTUNA, M.D.

PRC License No.035435782
Valid until Nov. 4, 2016

SIGNED IN THE PRESENCE OF:

GERONIMO H. IRLANDA JENNY K. LABORATORIO

116
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared BENITO C. DE LA CRUZ, CESARIO
D. ENTRADA, M.D. and DIEGO E. FORTUNA, M.D. who exhibited to me
their respective identification documents as appearing below their
respective names and signatures, known to me as the same persons who
executed and voluntarily signed the foregoing Compromise Agreement
which they acknowledged before me as their free and voluntary acts and
deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 48;

Page No. 10;
Book No. I;
Series of 2013

117
CONTRACT FOR PIECE OF WORK

KNOW ALL MEN BY THESE PRESENTS:

This CONTRACT FOR PIECE OF WORK entered into by and between:

CAROLINE D. EMERITO, of legal age, Filipino citizen, with residence

and postal address at Maria Pucay Road, Guisad, Baguio City, Philippines,
and hereinafter referred to as the FIRST PARTY,

-and-

FRANCIS G. HOLLANDAISE, of legal age, Filipino citizen, with

residence and postal address at 18 Poblacion, La Trinidad, Benguet,
Philippines, and herein referred to as the SECOND PARTY;

W I T N E S S E T H:

Whereas, the FIRST PARTY desires to engage the services of the

SECOND PARTY to drill a DEEP WELL at MARIA PUCAY ROAD, GUISAD,
BAGUIO CITY and the SECOND PARTY is willing to extend his services to the
FIRST PARTY as desired under certain terms and conditions;

NOW THEREFORE, the PARTIES have hereunto agreed, as they

hereby agree, on the following stipulations for the foregoing purposes, to
wit:

A. SCOPE OF THE WORK

The SECOND PARTY shall perform the following:

a) Faithfully and completely furnish to the satisfaction of the FIRST

PARTY all necessary labor, tools, supervision and management of the
drilling project;

b) Drill a borehole with a depth of at least TWO HUNDRED (200) feet

and a diameter of not less than SIX (6) inches;

c) Install FOUR (4) inches (diameter) G.I./B.I. pipe casings and

perforated/slotted casings;

d) Install a gravel pack on the annular space between the borehole wall
and the casing;

118
e) Develop the well by surging and bailing, cement grout the annular
space between the borehole and the lining from the ground surface
to FORTY (40) FEET below/downwards;

f) Install the pump and its accessories; and

g) Clean the drilling site upon its completion and demobilize all
equipment, tools and/or his personnel.

The FIRST PARTY shall pay the total consideration in the amount of
EIGHTY THOUSAND PESOS (Php 80,000.00) which will cover for the
following, to wit:

a) FOUR (4) INCH DIAMETER G.I./B.I. PIPES:

b) TWO (2) INCH DIAMETER G.I. PIPES:
c) COSTS of LABOR.

B. MODE OF PAYMENT

The FIRST PARTY agreed, as she hereby agrees, to pay to the

SECOND PARTY FIFTY (50%) PERCENT of the EIGHTY THOUSAND PESOS
(Php 80,000.00) contract price upon execution of this contract which
represents the partial payment and the other FIFTY (50%) PERCENT shall
be paid upon the purchase of the above-mentioned pipes. But in no case
shall the FIRST PARTY pay an amount in excess of EIGHTY THOUSAND
PESOS (Php 80,000.00).

Should the contract price of EIGHTY THOUSAND PESOS (Php

80,000.00) not suffice for the job contract, the SECOND PARTY hereby
obliged himself to shoulder the amount in excess thereof.

C. WORK DURATION

It is hereby agreed upon that the SECOND PARTY shall accomplish

the drilling job within THIRTY (30) to SIXTY (60) DAYS.

IN WITNESS WHEREOF, parties herein affixed their signatures this 6 th

day of December 2013 in the City of Baguio, Philippines.

CAROLINE D. EMERITO FRANCIS G. HOLLANDAISE

First Party Second Party
Passport No. AW123490 TIN 444-333-555
valid until July 9, 2015
119
SIGNED IN THE PRESENCE OF:

ISIDRO J. KALAPATI LOVE M. NAMNAMA

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared CAROLINE D. EMERITO and
FRANCIS G. HOLLANDAISE, who exhibited to me their respective
identification documents appearing below their names and signatures, both
known to me to be the same persons who executed and voluntarily signed
the foregoing Contract for Piece of Work and which they acknowledged
before me as their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 49;

Page No. 10;
Book No. I;
Series of 2013

120
CONTRACT OF EMPLOYMENT

KNOW ALL MEN BY THESE PRESENTS:

This CONTRACT OF EMPLOYMENT entered into by and between:

DESDEMONA E. FERGUSON, single, of legal age, Filipino citizen, with

residence and postal address at 34 Palma Road, Baguio City, Philippines,
sole proprietor of FEDS PREMIERE FINANCING, a sole proprietorship duly
existing under Philippine Laws, with office address at 3/F Laperal Building,
Session Road, Baguio City hereinafter referred to as the EMPLOYER;

-and-

GEMMA H. ILADO, single, of legal age, Filipino citizen, with residence

and postal address 10 Brookspoint, Aurora Hill, Baguio City, and hereinafter
referred to as the EMPLOYEE;

W I T N E S S E T H:

Whereas, the EMPLOYER desires to engage the services of the

EMPLOYEE as CONTRACTUAL EMPLOYEE at FEDS PREMIERE FINANCING
and the EMPLOYEE is willing to accept, work and extend her services to the
EMPLOYER as desired under the following terms and conditions, to wit:

A. DESIGNATION:

The Employee shall be hired as a CONTRACTUAL AUDITING

ASSISTANT;

B. SALARY:

The Employee shall be paid a monthly salary of TWENTY

THOUSAND PESOS (Php 20,000.00);

121
C. CONTRACT DURATION:

It is hereby agreed that the EMPLOYEE shall be hired as such for a

period of ONE (1) YEAR which shall be renewable upon the mutual
consent and agreement of the parties, Provided, however, that upon
the expiration of this contract any extension of employment granted to
the EMPLOYEE shall not be deemed as automatic renewal and instead
should be covered by a separate contract, Provided, further, that any
work extended by the EMPLOYEE after the expiration of this contract
and with the consent of the EMPLOYER shall be paid PRO RATA;

D. TERMINATION OF CONTRACT:

Either party may pre-terminate this contract, Provided, that the

party concerned shall serve written notice to the other of her intention
to terminate the same at least ONE (1) MONTH prior to the intended
termination, Provided, further, that should the EMPLOYEE desire to
terminate this contract she shall surrender any document or
accountability entrusted to her in relation to her employment.

IN WITNESS WHEREOF, the parties have hereunto affixed their

signatures this 6th day of December 2013 in the City of Baguio, Philippines.

DESDEMONA E. FERGUSON GEMMA H. ILADO

Employer Employee
Professional Driver’s License TIN 768-908-607
No. A0-01-140577
Valid until March 19, 2016

SIGNED IN THE PRESENCE OF:

JEROME K. LAMANO MERCEDES N. OPLE

122
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared DESDEMONA E. FERGUSON and
GEMMA H. ILADO, who exhibited to me their respective identification
documents appearing below their names and signatures, both known to me
to be the same persons who executed and voluntarily signed the foregoing
Contract Of Employment and which they acknowledged before me as their
free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 50;

Page No. 10;
Book No. I;
Series of 2013

123
CONTRACT OF EMPLOYMENT

KNOW ALL MEN BY THESE PRESENTS:

This CONTRACT OF EMPLOYMENT entered into by and between:

DESDEMONA E. FERGUSON, single, of legal age, Filipino citizen, with

-and-

JEROME K. LAMANO, single, of legal age, Filipino citizen, with

residence and postal address No. 10 Ambiong Road, Aurora Hill, Baguio
City, and hereinafter referred to as the EMPLOYEE.

W I T N E S S E T H:

Whereas, the EMPLOYER desires to engage the services of the

EMPLOYEE as PERMANENT EMPLOYEE at FEDS PREMIERE FINANCING and
the EMPLOYEE is willing to accept, work and extend her services to the
EMPLOYER as desired under the following terms and conditions, to wit:

A. DESIGNATION:
The Employee shall be hired as an AUDITOR;

B. SALARY:
The Employee shall be paid a monthly salary of THIRTY
THOUSAND PESOS (Php 30,000.00);

C. CONTRACT DURATION:
It is hereby agreed that the EMPLOYEE shall be hired as such for a
PERMANENT PERIOD;

D. TERMINATION OF CONTRACT:
Either party may pre-terminate this contract, Provided, that the
party concerned shall serve written notice to the other of his/her
intention to terminate the same at least ONE (1) MONTH prior to the
intended termination, Provided, further, that should the EMPLOYEE
desire to terminate this contract he shall surrender any document or
accountability entrusted to him in relation to his employment.

124
IN WITNESS WHEREOF, the parties have hereunto affixed their
signatures this 6th day of December 2013 in the City of Baguio, Philippines.

DESDEMONA E. FERGUSON JEROME K. LAMANO

Employer Employee
Professional Driver’s License TIN 648-768-503
No. A0-01-140577
Valid until March 19, 2016

SIGNED IN THE PRESENCE OF:

GEMMA H. ILADO MERCEDES N. OPLE

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared DESDEMONA E. FERGUSON and
JEROME K. LAMANO, who exhibited to me their respective identification
documents appearing below their names and signatures, both known to me
to be the same persons who executed and voluntarily signed the foregoing
Contract of Employment and which they acknowledged before me as their
free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
PTR No. 1928374/Baguio City/01-04-13
Doc. No. 51; Roll of Atty. No. 67548/05-18-10
Page No. 11; IBP OR No. 739281/Baguio-Benguet/01-04-13
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2013 Commission Serial No. 01-NC-11 (R)

125
CONTRACT OF LEASE

KNOW ALL MEN BY THESE PRESENTS:

This CONTRACT OF LEASE entered into by and between:

ELVIRA F. GANSOBIN, single, of legal age, Filipino Citizen, with

residence and postal address at 64 Palma Road, Baguio City, Philippines,
and hereinafter referred to as the LESSOR;

-and-

HAROLD I. JAVILLONAR, single, of legal age, Filipino Citizen, with

residence and postal address 123 Ambiong Road, Aurora Hill, Baguio City,
and hereinafter referred to as the LESSEE.

W I T N E S S E T H:

Whereas, the LESSOR is the lawful, absolute and registered owner of

a residential house located at 6 Genesis Point Village, Tuba, Benguet,
Philippines, hereinafter referred to as the LEASED PREMISES;

Whereas, LESSEE desires to lease the Leased Premises and LESSOR is

willing to lease the same unto the LESSEE, subject to the terms and
conditions hereinafter specified:

NOW, THEREFORE, for and in consideration of the forgoing and

mutual covenant herein contained, LESSOR does hereby LEASE, RENT, LET
and DELIVER by way of lease unto the LESSEE the Leased Premises, and the
LESSEE hereby accepts the same, subject to the following terms and
conditions:

1. TERMS. This lease shall be for a fixed period of ONE (1) YEAR
commencing on January 1, 2013 and shall expire on January 1, 2014,
renewable thereafter upon the mutual agreement of the parties.

2. RENTAL. The monthly rent for the Leased Premises shall be

SEVENTEEN THOUSAND PESOS (P 17,000.00) to be paid by the lessee
to the lessor within the first ten days of each and every month
without the need of demand.

126
3. DEFAULT PAYMENT. In case of default by the LESSEE in the payment
of the rent, such as when the checks are dishonored, the LESSOR at
its option may terminate this contract and eject the LESSEE. The
LESSOR has the right to padlock the premises when the LESSEE is in
default of payment for one (1) month and may forfeit whatever
rental deposit or advances have been given by the LESSEE.

4. SUB-LEASE. The LESSEE shall not directly or indirectly sublet, allow

or permit the Leased Premises to be occupied in whole or in part by
any person, firm or corporation. Neither shall the LESSEE assign its
rights hereunder to any other person or entity and no right of
interest thereto or therein shall be conferred on or vested in anyone
by the LESSEE without the LESSOR'S written approval.

5. APPLIANCES. The Leased Premises is furnished and provided with

appliances. The Lessee shall be responsible for any and all repairs of
appliances damaged through the lease period.

6. PUBLIC UTILITIES. The LESSEE shall pay for its telephone, electric,
cable TV, water, Internet, association dues and other public services
and utilities during the duration of the lease;

7. FORCE MAJEURE. If whole or any part of the Leased Premises shall

be destroyed or damaged by fire, flood, lightning, typhoon,
earthquake, storm, riot or any other unforeseen disabling cause of
acts of God, as to render the leased premises during the term
substantially unfit for use and occupation of the LESSEE, then this
lease contract may be terminated without compensation by the
LESSOR or by the LESSEE by notice in writing to the other.

8. LESSOR'S RIGHT OF ENTRY. The LESSOR or its authorized agent shall

after giving due notice to the LESSEE shall have the right to enter the
premises in the presence of the LESSEE or its representative at any
reasonable hour to examine the same or make repairs therein or for
the operation and maintenance of the property, or to exhibit the
leased premises to prospective LESSEE, or for any other lawful
purposes which she may deem necessary.

127
9. EXPIRATION OF LEASE. At the expiration of the term of this lease or
cancellation thereof, as herein provided, the LESSEE will promptly
deliver to the LESSOR the Leased Premises with all corresponding
keys and in as good and tenable condition as the same is now,
ordinary wear and tear expected devoid of all occupants, movable
furniture, articles and effects of any kind. Non-compliance with the
terms of this clause by the LESSEE will give the LESSOR the right, at
the latter's option, to refuse to accept the delivery of the premises
and compel the LESSEE to pay rent therefrom at the same rate plus
Twenty Five Percent (25%) thereof as penalty until the LESSEE shall
have complied with the terms hereof. The same penalty shall be
imposed in case the LESSEE fails to leave the premises after the
expiration of this Contract of Lease or termination for any reason
whatsoever.

10.JUDICIAL RELIEF. Should any one of the parties herein be compelled

to seek judicial relief against the other, the losing party shall pay an
amount of One Hundred Percent (100%) of the amount claimed in
the complaint as attorney's fees which shall in no case be less than
P50, 000.00, in addition to other costs and damages which said party
may be entitled to under the law.

11.This CONTRACT OF LEASE shall be valid and binding between the

parties, their successors-in-interest and assigns.

IN WITNESS WHEREOF, parties herein affixed their signatures this 6 th

day of December 2013 in the City of Baguio, Philippines.

ELVIRA F. GANSOBIN HAROLD I. JAVILLONAR

Lessor Lessee
TIN 091-091-091 TIN 123-123-123

SIGNED IN THE PRESENCE OF:

KASSANDRA L. MANALO NATHANIEL O. PASCUA

128
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared ELVIRA F. GANSOBIN and HAROLD
I. JAVILLONAR, who exhibited to me their respective identification
documents appearing below their names and signatures, both known to me
to be the same persons who executed and voluntarily signed the foregoing
Contract of Lease and which they acknowledged before me as their free
and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 52;

Page No. 11;
Book No. I;
Series of 2013

129
CONTRACT OF SERVICES

KNOW ALL MEN BY THESE PRESENTS:

This CONTRACT OF SERVICES executed by and between:

ENGR. FLORENCE G. HOWARD, a licensed Geodetic Engineer in the

Philippines, with office address at 18 Poblacion, La Trinidad, Benguet,
Philippines, and hereinafter referred to as the SURVEYOR,

-and-

IAN J. KAY, of legal age, Filipino Citizen, with residence and postal
address at 322 Magsaysay Avenue, Baguio City, Philippines, and hereinafter
referred to as the CLIENT.

W I T N E S S E T H:

Whereas, the CLIENT is the surviving heir of the late LEON O. KAY
who is the owner of that parcel of land situated at Pico, La Trinidad,
Benguet with an area of 29,256 sq.m., more or less and more particularly
described in PSU-252483;

Whereas, the client desires to engage the services of the SURVEYOR

and the latter is willing to accordingly extend his technical services to the
CLIENT;

NOW THEREFORE, the PARTIES have hereunto agreed, as they

hereby agree, on the following stipulations for the foregoing purposes, to
wit:

SCOPE OF SURVEYOR’S SERVICES

Acting in the interest of the CLIENT, the SURVEYOR shall perform

and conduct the following:

a) Re-establishment of lost monuments, if needed, of approved plan

bearing number PSU-252483, ground survey, relocation, subdivision
and other technical jobs necessary for the establishment of the
boundaries;

b) Preparation of (survey) plan indicating relative positions of adverse

claimants based on technical descriptions as indicated in the
documents, subject, however, to further review;
130
c) Conduct site investigation and issue certifications, if needed,
necessary for ongoing and future cases that arises from PSU-252483
concerning matters within the duration of this contract, if any;

d) Testify in court, if necessary and subject to minimal appearance fee,

on the correctness and authenticity of the metes and bounds of the
area covered by PSU-252843 and other cases incidental thereto,
such as but not limited to the subdivision and amendment of the
approved plan;

e) To coordinate with the lead counsel on matters requiring legal action

or opinion;

f) Provide technical advice, assist and help facilitate processes on

matters regarding the release of the title or decree, provided that the
surveyor will not guarantee, as he cannot guarantee, the release of
the said title; and

g) Perform any other tasks, included, incidental or inherent to the

foregoing as maybe mutually agreed upon by both Parties.

REPONSIBILITIES OF THE CLIENT

The CLIENT shall:

a) Furnish all pertinent documents for the proper accomplishment of

the services of the SURVEYOR; and

b) Ensure that all surveys are referred to the SURVEYOR, and all fees
thereon fully paid and settled.

FEES FOR SERVICES

The CLIENT binds himself to pay the SURVEYOR a professional fee

in the amount of THIRTY THOUSAND PESOS (Php 30,000.00) upon the
execution of this contract.

All services extended by the SURVEYOR during the subsistence of

this contract shall be subject to fees to be agreed upon by the parties
based on the current GEP Tariff and to be paid 50 % before the surveyor
executes the said service and 50 % upon conveyance of the final output;
and

131
The CLIENT likewise agrees and binds himself to segregate, by a
proper Deed or Document, a 200 square meter portion of the parcel of
land subject of this contract in favor of the SURVEYOR upon the signing
of this contract on the further condition that the CLIENT has the option
to choose the location from which the said portion shall be segregated;

In connection with the 200 square meters portion mentioned

above, the SURVEYOR has requested and the CLIENT has agreed that
the proper Deed or Document to be executed upon the signing of this
contract shall be in the name of one of the children of the SURVEYOR,
who as the transferee of such portion is hereby authorized, including his
heirs and assigns and the SURVEYOR himself to take possession and
make or introduce any and all improvements on the portion mentioned
above.

GUARANTEE CLAUSE

The CLIENT hereby guarantees that he is duly authorized to

represent the heirs of LEON O. KAY and/or enter into this contract.

The SURVEYOR hereby guarantees that all services subject of this

contract shall be duly executed and performed. Provided, however, that
the SURVEYOR will not guarantee, as he cannot guarantee, the
EXPIDITIOUS, IMMEDIATE and/or FAVORABLE APPROVAL by the
proper authorities of said surveys, due to circumstances beyond the
control of the SURVEYOR, such as but not limited to, protest by third
person/s or third party/ies as the case may be;

TERMINATION OF THE CONTRACT

This contract shall remain in force and effect unless and until both
Parties mutually agree in writing to terminate the terms
abovementioned; provided however, that either party is furnished one
(1) month notice prior to termination.

IN WITNESS WHEREOF, parties herein affixed their signatures this 6 th

day of December 2013 in the City of Baguio, Philippines.

IAN J. KAY ENGR. FLORENCE G. HOWARD

Client Surveyor
TIN 091-102-091 TIN 123-223-133

132
SIGNED IN THE PRESENCE OF:

LARA M. NORTON OREO P. QUARTZ

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared IAN J. KAY and ENGR. FLORENCE
G. HOWARD, who exhibited to me their respective identification
documents appearing below their names and signatures, both known to me
to be the same persons who executed and voluntarily signed the foregoing
Contract of Services and which they acknowledged before me as their free
and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 53;

Page No. 11;
Book No. I;
Series of 2013

133
CONTRACT OF SUB-LEASE

KNOW ALL MEN BY THESE PRESENTS:

This CONTRACT OF SUB-LEASE made and entered into by and

between:

GERALD H. IGOR, of legal age, married, Filipino, with residence and

postal address 68 Pacdal, Baguio City, Philippines, and hereinafter referred
to as the SUB-LESSOR;

-and-

JEREMY K. LIBERA, of legal age, married, Filipino and with residence

and postal address at Tuding, Itogon, Benguet, Philippines, and hereinafter
referred to as the SUB-LESSEE;

W I T N E S S E T H:

Whereas, the SUB-LESSOR is the LESSEE of that business

establishment located at Abanao Extension, Baguio City;

Whereas, the SUB-LESSOR hereby SUBLEASES that aforementioned

building owned by MARIO N. O’NEAL, including the FIVE (5) BILLIARD OR
POOL TABLES therein, unto the SUBLESSEE;

NOW THEREFORE, the parties have agreed on this contract under the
following terms and conditions, to wit:

A. TERM OF SUB-LEASE – TWO (2) YEARS which shall commence and be

effective upon the signing of this contract and shall be renewable
upon mutual consent of the parties;

B. RENTAL – The SUB-LESSEE shall pay to the SUB-LESSOR for the use
and occupancy of the said stall the amount of THIRTY THOUSAND
(Php 30,000.00) PESOS per month payable on or before the 1st day of
each calendar month during the entire duration of this contract. The
SUB-LESSEE however shall deposit SIXTY THOUSAND (Php 60,000.00)
PESOS upon the singing of this document. The said deposit however,
shall be applied to the last two months of this contract should the
term be completed;

C. SUB-LEASE – The SUB-LESSEE is not allowed under any circumstances

to re-sublease the said portion;
134
D. ADVANCE NOTICE TO VACATE – The SUB-LESSEE shall give the SUB-
LESSOR thirty (30) days written notice in advance of his intention to
vacate the premises before the expiration of the term;

E. MAINTENANCE – The SUB-LESSEE shall have the obligation to

maintain in good condition the aforementioned billiard tables
including the premises of the leased building. Provided, that any
damages to the said billiard tables and the leased premises during
the subsistence of this contract until its termination shall be for the
account of the SUB-LESSEE and the latter shall be obliged to cause
the repair of the damage, if any;

F. IMPROVEMENTS – The SUB-LESSEE is allowed to introduce

improvements in the said leased premises with the condition that it
will not alter the purpose for which the said premises was leased and
the SUB-LESSEE shall not remove any improvement introduced
thereon after the termination of this contract;

G. BREACH OR DEFAULT – Should the SUB-LESSEE violate any of the

foregoing terms and conditions, the SUB-LESSOR shall have the right
to terminate and cancel this contract extra-judicially and the latter
may then exclude the former from the premises and shall not be
liable to reimburse the SIXTY THOUSAND (Php 60,000.00) PESOS
DEPOSIT;

H. MUNICIPAL SERVICES – The SUB-LESSEE shall be responsible for the

payment of all municipal services, such as but not limited to, water
and electrical bills, and that upon the termination of this contract she
will surrender the leased premises free from all unpaid bills,
whatsoever;

Whereas, this lease contract shall be binding to the PARTIES, their

heirs and assigns and shall be faithfully complied with.

IN WITNESS WHEREOF, parties herein affixed their signatures this 6 th

day of December 2013 in the City of Baguio, Philippines.

GERALD H. IGOR JEREMY K. LIBERA

Sub-Lessor Sub-Lessee
SSS No. 3-3454358-9 TIN 555-009-555

135
SIGNED IN THE PRESENCE OF:

MARK N. ONSE PAOLO Q. RIVERA

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared GERALD H. IGOR and JEREMY K.
LIBERA, who exhibited to me their respective identification documents
appearing below their names and signatures, both known to me to be the
same persons who executed and voluntarily signed the foregoing Contract
of Sub-Lease and which they acknowledged before me as their free and
voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 54;

Page No. 11;
Book No. I;
Series of 2013

136
CONTRACT TO SELL

KNOW ALL MEN BY THESE PRESENTS:

This CONTRACT TO SELL executed by and between:

HAROLD I. JOVEN, single, of legal age, Filipino citizen, with office

address at Narda’s Commercial Building, Session Road, Baguio City,
Philippines, and herein referred to as the FIRST PARTY;

-and-

JASON K. LIRIO, single, Filipino citizen, of legal age, with postal address
at 68 Maligaya Park Subd., Novaliches, Quezon City, Philippines, and herein
referred to as the SECOND PARTY;

W I T N E S S E T H:

Whereas, by virtue of an authority, the FIRST PARTY hereby enters

into a contract to sell with the SECOND PARTY over that parcel of land
situated at Alapang, La Trinidad, Benguet, covered by Transfer Certificate of
Title No. T-52919 and particularly described as follows:

TRANSFER CERTIFICATE OF TITLE No. T-52919

A parcel of land (Lot 9, Block 6, Psd-CAR-009561, being a

portion of Lot 4, Psu-192324-Amd), situated at Barangay
Alapang, Municipality of La Trinidad, Province of Benguet,
Island of Island. Bounded on the NW., along line 1-2 by Lot 10,
Block 6; and on the NE., along line 2-3 by Lot 19, Block 6; along
line 3-4 by Lot 20, Block 6; on the SE., along line 4-5 by Lot 8,
Block 6; on the SW., long line 5-1 by Road Lot 2; all of the
subdivision plan. Beginning at a point marked “1” on plan
being S. 340 deg. 11” W., 545.81 m. from BLBM No. 1 Bo. of
Alapang, La Trinidad, Benguet, thence;

N. 270 deg. 26’ E., 12.51 m. to point 2;

S. 620 deg. 32’ E., 3.94 m. to point 3;
S. 620 deg. 32’ E., 4.06 m. to point 4;
S. 270 deg. 27’ W., 12.50 m. to point 5;
N. 620 deg. 32’ W., 8.00 m. to point of beginning.

Containing an area of ONE HUNDRED (100) SQUARE METERS,

more or less. All points referred to are indicated on the plan
137
and are marked on the ground by P.S. cyl. conc. mons. 15 x 40
cms. Bearings True; date of Original survey on March 5, 1988;
date of subdivision survey on February 8-22, 2002, executed by
Junior Geodetic Engineer Paulino Ballola under the supervision
of Engr. Philip P. Piluden and was approved on December 17,
2002.

Whereas, for and in consideration of the sum of FOUR HUNDRED

SEVENTY FIVE THOUSAND (Php 475,000.00) PESOS, Philippine currency, paid
in hand by the SECOND PARTY, the PARTIES herein hereby voluntarily enter
into this Contract to Sell under the following terms and conditions:

PAYMENT:
a. The SECOND PARTY pays the amount of FOUR HUNDRED SEVENTY
FIVE THOUSAND (Php 475,000.00) PESOS upon the signing of the
contract;
b. All payments shall be made directly to WINACA DEVELOPMENT
CORPORATION with office address at Narda’s Commercial Center,
Km. 5, La Trinidad, Benguet. Unauthorized payment shall not be
honored by the FIRST PARTY;

PENALTY AND CHARGES

a. Any unpaid payment shall be charged a penalty equivalent to
TWENTY (20%) PERCENT per annum of the total unpaid balance;

RELEASE OF TITLE
a. The title to the lot shall be released six (6) to nine (9) months after
full payment of the purchase price thereof and that of the agreed
consideration in the contract to build a residential house thereon;
b. Capital and documentary stamps shall be at the account of the
FIRST PARTY while the Transfer taxes and other related expenses
shall be at the account of the SECOND PARTY;

DEFAULT PROVISIONS
a. If, at any time, the SECOND PARTY fails to pay the balance or
scheduled payments within the required period he shall be
considered in default, and a penalty as provided for in item No. 2
hereof shall be charged, and with the option given to the FIRST
PARTY to rescind this contract after the expiration of the grace
period and all advance payments made shall be forfeited in favor of
the latter;
b. The provisions herein above-contained shall be without prejudice
to the right of the SECOND PARTY to SELL, TRANSFER or CONVEY
his rights and interests under this contract to qualified party within
the grace period allowed and before actual cancellation of this
138
contract, subject, however, to the written consent of the FIRST
PARTY;
c. Should this contract be cancelled by the SECOND PARTY, the FIRST
PARTY shall refund to the former the cash surrender value of the
payments on the property equivalent to FIFTY (50%) PERCENT of
the total payments made, less all expenses that the latter may have
incurred by reason of the execution of the contract, and expenses
that may be incurred for repairs on the premises, if any. Refund is
also exclusive of payments for insurance premiums, agents
commissions, electric and water bills and related expenses, which
may have been paid by the FIRST PARTY for and in behalf of the
SECOND PARTY, if any;
d. Except for the stipulations on the mode of payment and other
conditions necessary for the eventual execution of the Deed of
Absolute Sale by the FIRST PARTY in favor of the SECOND PARTY,
all other stipulations herein are understood to be made part of the
DEED which shall be executed upon complete/full payment of the
consideration of this contract;

Whereas, the FIRST PARTY warrants that the above-described

residential house and lot are free from any lien and/or encumbrance 60 days
or less from full payment of the balance;

Whereas, the provisions of Art. 1623 of the New Civil Code of the
Philippines has been complied with;

Whereas, this contract shall be binding and enforceable upon the

heirs, assigns and successors of the parties herein.

IN WITNESS WHEREOF, parties herein affixed their signatures this 6 th

day of December 2013 in the City of Baguio, Philippines.

HAROLD I. JOVEN JASON K. LIRIO

First Party Second Party
Passport No. RR893490 TIN 777-980-555
valid until July 4, 2015

SIGNED IN THE PRESENCE OF:

IRENE J. KOSOVO LORD M. NOVO

139
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared HAROLD I. JOVEN and JASON K.
LIRIO, who exhibited to me their respective identification documents
appearing below their names and signatures, both known to me to be the
same persons who executed and voluntarily signed the foregoing Contract
to Sell and which they acknowledged before me as their free and voluntary
acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 55;

Page No. 11;
Book No. I;
Series of 2013

140
INDEMNITY AGREEMENT

KNOW ALL MEN BY THESE PRESENTS:

Whereas, IRENEO J. KALENTONG and JOVENCIA K. KALENTONG,

both died intestate leaving KRISTINA K. KALENTONG, KRISTOFF K.
KALENTONG, and KASSANDRA K. KALENTONG as the only surviving heirs;

That for the purpose of this contract, the said deceased is being
represented by one of their surviving heirs KRISTOFF K. KALENTONG, of
legal age, single, Filipino Citizen and with residence and postal address at
North Sanitary Camp, Baguio City, Philippines, by virtue of that Special
Power of Attorney executed by her co-heirs KRISTINA K. KALENTONG and
KASSANDRA K. KALENTONG, a copy of which is hereto attached for easy
reference.

Whereas, at the time of the respective deaths of the said deceased,

they maintained the following BANK ACCOUNTS:

BANCO DE ORO, Upper Session Road, Baguio City Branch

ACCOUNT NUMBER AMOUNT ACCOUNT TYPE

02-000B-00152-CTF-A P1, 925,475.70 CTF-A

111-81584-5 P1, 076,913.96 PLI

Whereas, the surviving heirs of the deceased desire to withdraw the

proceeds from the aforementioned accounts. As such, KRISTOFF K.
KALENTONG has presented/submitted, among others, the original copies of
the respective Death Certificates;

Whereas, pursuant thereto, the surviving heirs, through their

representative and co-heir herein, hereby release, discharge and free and
further undertake to indemnify, Banco De Oro from any and all liabilities,
claims, damages, or other causes of whatever nature that may now exist or
hereafter exist, in connection with the release in their favor the deposits
left by their deceased parents.

IN WITNESS WHEREOF, parties herein affixed their signatures this 6 th

day of December 2013 in the City of Baguio, Philippines.

KRISTOFF K. KALENTONG LEANDRO M. NAVARETTE

Representative Co-Heir Bank Manager
141
Postal ID No. 1209384 SSS No. 5-9438767-9
SIGNED IN THE PRESENCE OF:

MIRIAM N. OSIAS PRECIOUS Q. REQUINTA

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared KRISTOFF K. KALENTONG and
LEANDRO M. NAVARETTE, who exhibited to me their respective
identification documents appearing below their names and signatures, both
known to me to be the same persons who executed and voluntarily signed
the foregoing Indemnity Agreement and which they acknowledged before
me as their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 56;

Page No. 12;
Book No. I;
Series of 2013

142
MEMORANDUM OF AGREEMENT

KNOW ALL MEN BY THESE PRESENTS:

This Memorandum of Agreement made and executed by:

JASMINE K. LIBERTAD, of legal age, Filipino, widow, with residence

and postal address at 40 Suello Village, Marcos Highway, Baguio City, and
hereinafter referred as the FIRST PARTY;

-and-

MARGAUX N. ONDIMA, of legal age, married, Filipino, with postal

address at Km. 6, La Trinidad, Benguet, and hereinafter referred as the
SECOND PARTY;

W I T N E S S E T H:

Whereas, the SECOND PARTY is indebted to the FIRST PARTY in the

principal amount of ONE HUNDRED FIFTY THOUSAND PESOS
(Php150,000.00) as of November 22, 1996 receipt of which is already
acknowledged by the SECOND PARTY by virtue of that MEMORANDUM OF
AGREEMENT executed on May 17, 2012, which remains unpaid;

Whereas, the same amount had already accumulated into FIVE

HUNDRED THOUSAND SEVEN HUNDRED TWENTY ONE and THIRTY THREE
CENTAVOS (Php 500,721.33) inclusive of interest and penalties at the rate
of twenty six percent (26%) and five percent (5%) per annum respectively
as of November 28, 2012 and the amount of interest is also increasing at
the time of execution of this agreement;

Whereas, the SECOND PARTY hereby agrees to pay the said loan
inclusive of interests and penalties in favor of the FIRST PARTY herein and
the latter likewise agrees to accept the same, under the following terms
and conditions, to wit:

1. The SECOND PARTY hereby acknowledges the loan obligation in the

aforementioned MEMORANDUM OF AGREEMENT is still subsisting
in the principal amount of ONE HUNDRED FIFTY THOUSAND
(Php150, 000.00) plus the accumulated interest and penalties which
now has the total amount of FIVE HUNDRED THOUSAND SEVEN
HUNDRED TWENTY ONE and THIRTY THREE CENTAVOS

143
(Php500,721.33) wherein said amount shall be paid on or before
August 31, 2014;

2. The SECOND PARTY shall pay the total amount of the loan in nine (9)
equal monthly installments in the amount of FIFTY FIVE THOUSAND
SIX HUNDRED TWENTY FOUR and FIFTEEN CENTAVOS (Php 55,
624.15) commencing in the month of December 2013 up to August
31, 2013 with the single payment in the last month in the amount of
ONE HUNDRED FOUR THOUSAND PESOS (Php 104, 000.00);

3. Finally, both parties hereby agree to mutually comply in good faith

with all the terms and conditions of this agreement.

Whereas, this Agreement shall be enforceable and binding to parties

herein, their heirs and assigns.

IN WITNESS WHEREOF, parties herein affixed their signatures this 6 th

day of December 2013 in the City of Baguio, Philippines.

JASMINE K. LIBERTAD MARGAUX N. ONDIMA

First Party Second Party
SSS No. 8-6759870-9 TIN 679-999-876

SIGNED IN THE PRESENCE OF:

PRINCESS Q. REYNA SHARMAINE T. URIARTE

144
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared JASMINE K. LIBERTAD and
MARGAUX N. ONDIMA, who exhibited to me their respective identification
documents appearing below their names and signatures, both known to me
to be the same persons who executed and voluntarily signed the foregoing
Memorandum of Agreement and which they acknowledged before me as
their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 57;

Page No. 12;
Book No. I;
Series of 2013

145
PARTITION AGREEMENT OF A REGISTERED LAND
WITH SIMULTANEOUS WAIVER

KNOW ALL MEN BY THESE PRESENTS:

This PARTITION AGREEMENT OF A REGISTERED LAND WITH

SIMULTANEOUS WAIVER entered into by and between:

KATHERINE LEVISTE-MONDRAGON, of legal age, widow, Filipino

citizen, with residence and postal address at Montecillo, Camp 7 Barangay,
Baguio City, Philippines;

MARGARET LEVISTE-NAVA, of legal age, widow, Filipino citizen, with

residence and postal address at Montecillo, Camp 7 Barangay, Baguio City,
Philippines;

NAOMI LEVISTE-OANDASAN, of legal age, widow, Filipino citizen,

with residence and postal address at Montecillo, Camp 7 Barangay, Baguio
City, Philippines;

PRICILLA LEVISTE-QUIRINO, of legal age, married to Fidel Quirino,

Filipino citizen, with residence and postal address at Montecillo, Camp 7
Barangay, Baguio City, Philippines; and,

ROWENA LEVISTE-SAMARIA, of legal age, widow, Filipino citizen,

with residence and postal address at Montecillo, Camp 7 Barangay, Baguio
City, Philippines.

W I T N E S S E T H:

Whereas, the above-mentioned parties are the co-owners of that

parcel of land situated at Datakan, Kapangan, Benguet, Philippines, and
covered by TCT No. T-1086 containing an area of FIVE (5) HECTARES by
virtue of that Deed of Extrajudicial Settlement of Estate, which was entered
in the Notarial Registry of HONORIO G. BUCCAT JR. as Doc. No. 50; Page No.
5; Book No. I; Series of 2013, and more particularly described as follows:

Lot 1
Transfer Certificate of Title No. T-1086, Lot 1. Beginning at a point
marked 1 on plan F-49403, N. 86-09’ E. 2680.24 m. more or less from
B.L.L.M. No.1, Mpl. Dist. of Kapangan, Mt. Province, thence N. 48-43’ E.
62.05 m. to point 2; N. 67-07’ E. 77.72 m. to point 3; N. 64-43’ E. 53.70 m.
to point 4; S. 46-22’ W. 98.84 m. to point 5; N. 89-46’ W. 101.27 m. to
point 1, point of beginning. With an area of 0.4629 hectare. Point 3 Old
G.I.S. in a tree; point 4 Nail in tree; and the rest are B.L. Conc. Mons.
146
Bounded on the North, by property of Severino Malitas and Public Land;
on the Southeast and South, by Creek; and on the Northwest, by
property of Sudimay.

Lot 2
Beginning at a point marked 1 on plan F-49403, N. 86-24’ E. 2493.38
m. more or less from B.L.L.M. No. 1, Mpl. Dist. of Kapangan, Mt. Prov.,
thence N. 50-37’ E. 95.96 m. to point 2; S. 50-06’ E. 51.70 m. to point 3; S.
46-06’ E. 45.31 m. to point 4; S. 34-48’ W. 107.07 m. to point 5; S. 58-14’
W. 94.21 m. to point 6; N. 26-53’ W. 119.52 m. to point 7; S. 81-56’ W.
48.37 m. to point 8; N. 49-32’ W. 32.95 m. to point 9; N. 36-15’ E. 21.68
m. to point 10; N. 85-37’ E. 105.98 m. to point 1, point of beginning.
Containing an area of 2.3318 hectares. Point 2, B.L. on Boulder; points
3,5,6 and 7, Nails in trees; Points 4, 8 and 9, B.L. on Rocks; and the rest
are B. L. Conc. Mons. Bounded on the Northeast, by property of Tomas;
on the Southeast, by creek; on the Northwest, by properties of Insas and
Mariano Casio; and on the Northwest, by Creek.

Lot 3
Beginning at a point marked 1 on plan F-49403, N. 85-27’ E. 2473.33
m. more or less from B.L.L.M. No. 1, Mpl. Of Kapangan, Mt. Province,
thence N. 77-08’ E. 222.88 m. to point 2; S. 57-17’ W. 182.42 m. to point
3; S. 80-58’ W. 62.41 m. to point 4; N. 2-06’ W. 58.81 m. to point 1, point
of beginning. Containing an area of 0.8726 hectare. Points 1 and 2, Old
B.L. Conc. Mons.; and the rest are B.L. Conc. Mons. Bounded on the
North, by property of Severino Malitas; on the Southeast, by Creek; on
the South, by property of Casio; and on the West, by property of Rosalia
Vda. De Pacalso. Bearings true. Declination 1-30’ E. Points referred to
are marked on plan F-49403, Sheet No. 1 Surveyed under authority of
Sections 41-43 Act 2874 and in accordance with existing regulations of
the Bureau of Lands, by Nemesio Albano, Jr. Surveyor, under the
supervision of Gregorio L. Arizabal, Public Land Surveyor, on July 22-25,
1931 and approved on May 20, 1933.

Lot 4
Beginning at a point marked 1 on plan F-49403, N. 87-22’ E. 2173.10
m. more or less from B.L.L.M. No. 1 Mpl. Dist. of Kapangan, Mt. Province,
thence N. 66-42’ W. 56.61 m. to point 2; N. 6-19’ E. 26.37 m. to point 3; N.
30-15’ W. 10. 52 m. to point 4; N. 51-16’ E. 19.50 m. to point 5; S. 84-02’
E. 17.30 m. to point 6; N. 60-16’ E. 36.25 m. to point 7; S. 29-05’ m. to
point 8; N. 75-58’ E. 54.50 m. to point 9; S. 39-03’ W. 110.75 m. to point
1, point of beginning. Containing an area of 0.5608 hectare. Point 9, Old
X on Rock; and the rest are B.L. Conc. Mons. Bounded on the North by
Properties of Da-aya, Sabelo and Insas; on the Southeast, by property of
Locloc Serafino; on the Southwest, by property Locloc Serafino; and on
the West, by properties of Bagtang and Da-aya. Bearings True.
Declination 1-30’ E. Points referred to are marked on plan F-49403,
Sheet No. 2 Surveyed under authority of Sections 41-43 Act No. 2874
and in accordance with existing regulations of the Bureau of Lands, by
Nemesio Albano, Jr. Surveyor, under the supervision of Gregorio L.
Arizabal, Public Land Surveyor, on July 22-25, 1931 and approved on
May 20, 1933.

147
Lot 5
Beginning at a point marked 1 on plan F-49403, S. 87-13’ E. 1943.96
m. more or less from B.L.L.M. No. 1 Mpl. Dist. of Kapangan, thence S. 45-
32’ m. 9.07 m. to point 2; N. 21-47’ E. 7.52 m. to point 3; N. 42-20’ W.
8.54 m. to point 4; N. 55-20’ W. 11.04 m. to point 5; S. 73-29’ W. 14.31 m.
to point 6; N. 25-01’ W. 63.13 m. to point 7; N. 76-11’ E. 53.73 m. to point
8; S. 57-07’ E. 43.90 m. to point 9; S. 10-26’ W. 15.14 m. to point 10; S.
29-35’ W. 33.59 m. to point 11; N. 80-74’ W. 6.24 m. to point 12; S. 20-46’
W. 13.11 m. to point 1, point of beginning. Containing an area of 0.4355
hectare. Pointsnd 9, B.L. Conc. Mons.; and the rest are Old B.L. Conc.
Mons. Bounded on the Northwest, by property of Tella; on the Southeast,
by properties of Tella and Laoyan Baporo; on the Southwest, by
property of Geraldo Pilpilic; and on the Northwest, by Public Land.
Bearings True. Declination 0-21’ E. Points referred to are marked on
Plan F-49403, Sheet No. 3. Surveyed under authority of sections 41-43
Act No. 2874 and in accordance with existing regulations of the Bureau
of Lands, by Teodoro Salanga, Public Land Surveyor, on April 3,1935
and approved on May 4, 1937.

Lot 6
Beginning at a point marked 1 on plan 49403, S. 87-14’ E. 2624.71
m. more or less from B.L.L.M. No. 1 Mpl. Dist. of Kapangan, thence S. 27-
59’ E. 95.19 m. to point 2; S. 34-42’ E. 9.49 m. to point 3; S. 39-32’ w.
36.26 m. to point 4; N. 59-38’ W. 26.85 m. to point 5; N. 15-59’ W. 77.88
m. to point 6; N. 29-22’ E. 36.01 m. to point 1, point of beginning.
Containing an area of 0.3910 hectare. Point 4, B.L. on stone; point 5, Old
X on Stone; Point 6, Old B.L. Conc. Mon.; and the rest are B.L. Conc. Mons.
Bounded on the Northwest, Public Land; on the Southeast, by Public
Land; on the Southwest, by property of of Locloc Serafino; and on the
Northwest, by property of Vintiria. Bearing true. Declination 0-21’ E.
Points referred to are marked on plan F-49403, Sheet No. 4. Surveyed
under the authority of Section 41-43 Act No. 2874 and in accordance
with existing regulations of the Bureau of Lands, by Ricardo R. Quilop,
Jr. Surveyor, under the supervision of Gaudencio Fantony, Public Land
Surveyor, on April 6, 1936 and approved on May 4, 1937.

Whereas, the parties have caused the subdivision of the above-

described real property into SIX (6) lots as per Subdivision Plan 1230 and
they have partitioned and adjudicated among themselves the said property
and as indicated in Transfer Certificate of Title No. 1086 as follows:

1. LOT 1 and 2 with an area of 0.4629 HECTARES shall be adjudicated in

favor of KATHERINE LEVISTE-MONDRAGON;
2. LOT 3 shall be adjudicated in favor of MARGARET LEVISTE-NAVA;
3. LOT 4 shall be adjudicated in favor of NAOMI LEVISTE-OANDASAN;
4. LOT 5 shall be adjudicated in favor of PRICILLA LEVISTE-QUIRINO;
5. LOT 6 shall be adjudicated in favor of ROWENA LEVISTE-SAMARIA;

Whereas, the copy of Transfer Certificate of Title No. 1086 is hereto

attached and made as integral part hereof;

148
Whereas, the co-owner KATHERINE LEVISTE-MONDRAGON, for and
in consideration of her love and affection to her children namely: EDWARD
L. MONDRAGON, married to Emily Mondragon, GEORGE L. MONDRAGON,
married to Marie Mondragon, WILLIAM L. MONDRAGON, single, RICHARD
L. MONDRAGON, married to Cristine Mondragon, ARTHUR L.
MONDRAGON, married to Cynthia Mondragon and HENRY L.
MONDRAGON, single, all of legal age, Filipino Citizens and all residents of
La Trinidad, Benguet, Philippines, do hereby WAIVE, as she hereby
WAIVED, pro indiviso, all her rights, share and participation over the said
parcel of land to her aforementioned children;

Whereas, the parties hereby request, the Register of Deeds of

Benguet to issue individual Titles in accordance with this partition
agreement.

IN WITNESS WHEREOF, parties herein affixed their signatures this 6 th

day of December 2013 in the City of Baguio, Philippines.

KATHERINE LEVISTE-MONDRAGON MARGARET NAVA

Postal ID No. 6667786 Postal ID No. 1206869

NAOMI LEVISTE-OANDASAN PRICILLA QUIRINO

Postal ID No. 1203334 Postal ID No. 1203555

ROWENA LEVISTE-SAMARIA
Non-Professional Driver’s License No.
A03-01-1403327
Valid until May 14, 2014

SIGNED IN THE PRESENCE OF:

SILVERIA T. UMALI TIMOTEA U.

VALDEZ

149
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared KATHERINE LEVISTE-
MONDRAGON, MARGARET LEVISTE-NAVA, NAOMI LEVISTE-OANDASAN,
PRICILLA LEVISTE-QUIRINO, and ROWENA LEVISTE-SAMARIA, who
exhibited to me their respective identification documents appearing below
their names and signatures, both known to me to be the same persons who
executed and voluntarily signed the foregoing Partition Agreement of a
Registered Land with Simultaneous Waiver and which they acknowledged
before me as their free and voluntary acts and deeds.

This instrument consisting of FIVE (5) 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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 58;

Page No. 12;
Book No. I;
Series of 2013

150
PARTITION AGREEMENT

KNOW ALL MEN BY THESE PRESENTS:

This PARTITION AGREEMENT entered into by and between:

LEONARD M. NAPA, of legal age, single, Filipino citizen, with

residence and postal address at Montecillo, Camp 7 Barangay, Baguio City,
Philippines and herein referred to as the FIRST PARTY;

MICHAEL M. NAPA, married to Sharon R. Napa, of legal age, Filipino

citizen, with residence and postal address at Montecillo, Camp 7 Barangay,
Baguio City, Philippines and herein referred to as the SECOND PARTY;

-and-

NATHAN M. NAPA married to Danielle B. Napa, of legal age, Filipino

Citizen, with residence and postal address at Montecillo, Camp 7 Barangay,
Baguio City, Philippines and herein referred to as the THIRD PARTY;

W I T N E S S E T H:

Whereas, by virtue of that Deed of Donation of Registered Land

entered in the Notarial Registry of LAIRD DIONEL N. URBANOZO as Doc. No.
15; Page No. 3; Book No. I; Series of 2013; dated June 14, 2013; the above-
named PARTIES are the co-owners of that parcel of land situated at
Montecillo, Camp 7 Barangay, Baguio City, Philippines containing an area of
THREE HUNDRED AND SEVENTY NINE (379) SQUARE METERS covered by
Transfer Certificate of Title No. T-18349 and more particularly described as
follows, to wit:

TRANSFER CERTIFICATE OF TITLE No. T-18349

“A parcel of land (Lot 1-F-1-C, Psd-1-06520, being a

portion of Lot 1-F-1, Psd-1-06067, L.R.C. REC No. _____)
situated at Montecillo, Camp 7 Barangay, Baguio City, Island
of Luzon, Philippines. Bounded on the SW., along line 1-2-3 by
Lot 1-D, Psd-1-05141, on the W., N., NE., E, & S., along lines 3-
4-5-6-7-8-1 by Lot 1-F-1-E, Psd-1-06520. Beginning at a point
marked “1” on Lot 1-F-1-C, on plan being N. 37 deg., 48’ E.,
1478.03 M. from Triangulation Sta. “CENTER”, Baguio City.
Thence N. 16 deg., 57’ W., 19.99 m. to point 2; thence S. 77
deg., 11’ W., 9.82 m. to point 3; thence N. 8 deg., 51’ W., 14.05
151
m. to point 4; thence N. 74 deg. 19’ E., 10.95 m. to point 5;
thence S., 42 deg., 10’ E., 8.72 m. to point 6, thence S. 22 deg.,
24’ E., 22.50 m. to point 7l; thence S., 14 deg., 39’ E., 4.35 m. to
point 8; thence S., 74 deg., 47’ W., 8.8 m. to point of beginning,
containing an area of THREE HUNDRED AND SEVENTY NINE
(379) SQUARE METERS. All points referred to are indicated
on the plan and are marked on the ground as follows: points
4,5,7 & 8 by P.S. Cyl. Conc. Mons. 15 x 60 cm., point 6 by X on
stone and the rest by Old P.S. cyl. Conc. mons 15 x 60 cm.
bearing true, date of original survey on June 26-27, 1941;
date of subdivision survey on July 3, 1982 and approved on
Aug. 5, 1982.“.

Whereas, the PARTIES herein caused the subdivision of the

aforementioned parcel of land into THREE (3) lots;

Whereas, by virtue of that Approved Consolidation Subdivision Plan

of LOTS 1-F-C-1, 1-F-C-2, 1-F-C-3 Psd-CAR-013970 bearing number Pcs-CAR-
001126 as prepared for LEONARD M. NAPA, et.al., the PARTIES herein
hereby SUBDIVIDE, PARTITION and ADJUDICATE among themselves the
aforementioned parcel of land as follows, to wit:

1. Lot 1-F-C-1, Psd-CAR-013970 with an area of ONE HUNDRED SIXTEEN

(116) SQUARE METERS shall be adjudicated in favor of NATHAN M.
NAPA, THIRD PARTY herein. A copy of the Technical Description of
Lot 1-F-C-1, Psd-CAR-013970 is hereto attached and made part
hereof;
2. Lot 1-F-C-2, Psd-CAR-013970 with an area of ONE HUNDRED THIRTY
SIX (136) SQUARE METERS, shall be adjudicated in favor of LEONARD
M. NAPA, FIRST PARTY herein. Copy of the Technical Description of
Lot 1-F-C-2, Psd-CAR-013970 is hereto attached and made part
hereof; and
3. Lot 1-F-C-3, Psd-CAR-013970 with an area of ONE HUNDRED
TWENTY SEVEN (127) SQUARE METERS, shall be adjudicated in favor
of MICHAEL M. NAPA, SECOND PARTY herein. Copy of the Technical
Description of Lot 1-F-C-2, Psd-CAR-013970 is hereto attached and
made part hereof.

Whereas, the parties hereto hereby request, the Registrar of Deeds

of Benguet to issue individual Titles in accordance with this Partition
Agreement and as per the Approved Consolidation Subdivision Plan of
LOTS 1-F-C-1, 1-F-C-2, 1-F-C-3 Psd-CAR-013970 bearing number Pcs-CAR-
001126 a copy of which is hereto attached for reference.

152
Whereas, the above-described parcel of land is in the possession of
the PARTIES herein.
IN WITNESS WHEREOF, parties herein affixed their signatures this 6 th
day of December 2013 in the City of Baguio, Philippines.

LEONARD M. NAPA MICHAEL M. NAPA NATHAN M. NAPA

Postal ID No. 1222224 Postal ID No. 123356 Postal ID No. 1267597

SIGNED IN THE PRESENCE OF:

PAUL N. MANAOIS LUIGI O. MARIANO

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared LEONARD M. NAPA, MICHAEL M.
NAPA, and NATHAN M. NAPA, who exhibited to me their respective
identification documents appearing below their names and signatures, both
known to me to be the same persons who executed and voluntarily signed
the foregoing Partition Agreement and which they acknowledged before
me as their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
PTR No. 1928374/Baguio City/01-04-13
Doc. No. 59; Roll of Atty. No. 67548/05-18-10
Page No. 12; IBP OR No. 739281/Baguio-Benguet/01-04-13
Book No. I;
Series of 2013 153
MCLE Compliance No. IV-90210/04-22-13
Commission Serial No. 01-NC-11 (R)

154
BUSINESS SPACE LEASE AGREEMENT

KNOW ALL MEN BY THESE PRESENTS:

This BUSINESS SPACE LEASE AGREEMENT is executed and entered

into by and between:

MIKAELLA N. PANELA, married to JEREMY Y. PANELA, of legal age,

Filipino citizen, with residence and postal address at Unit 2 Genesis Point
Village, Irisan, Baguio City, hereinafter referred to as the LESSOR;

-and-

NELSON O. QUIRINO, single, of legal age, Filipino citizen, with

residence and postal address at Gibraltar Road, Baguio City, hereinafter
referred to as the LESSEE.

W I T N E S S E T H T H A T:

PREMISES LEASED:

The LESSOR shall allow the LESSEE to rent/lease the lower and/or
basement portion of a Commercial Building located at 4 Jose Sumulong St.,
Baguio City. The basement portion has two (2) partitions with separate
entries, viz:

1. One partition with ingress from the front gate/garage which is not
included in the lease contract;

2. One partition with entry outside and adjacent the gate is the
exact location of the leased premises.

The LESSEE’S occupation is only and specifically outside the main

gate’s perimeter or the right portion of the residential building’s basement
situated at Southwest until the Southeast portion with reference point
facing the residential building from the main road (Sumulong Street);

PERIOD OF CONTRACT, RENTAL, DEPOSIT, DUE DATE AND SURCHARGES:

This contract of lease shall be binding and enforced for the period of
one (1) year beginning from January 1, 2014 until December 31, 2014
provided however, that the LESSEE shall pay proportional rent for the
period December 7, 2013 to December 31, 2013.

155
The contract shall not be renewed after December 31, 2014.

In case there is valid cause to pre-terminate this contract, the party

pre-terminating the same shall give notice to the other at least a month
prior to the effectivity of pre-termination.

The monthly rental shall be TWENTY THOUSAND PESOS

(Php20,000.00) payable every last day of the applicable month starting on
January 31, 2014. The rental for the period December 7, 2013 to December
31, 2013 amounting to Php 12,000.00 shall be paid not later than
December 31, 2013.

In the event that the LESSEE would be delayed in the financial

obligation and the payment would only take effect on or before 10 th of the
succeeding month, a 10% surcharge is added to the previous monthly
rental dues. Another 10% surcharge would be meted the delayed payment
if such would be concluded after the succeeding month’s ending.

TERMS AND CONDITIONS OF THE LEASE:

1. The LESSEE shall, at his sole exclusive account and responsibility, pay
the electric and water bills pertaining to the leased premises;

2. The LESSEE shall not make any alteration, modification and/or

change or in any manner introduced improvements or repair in the
leased premises whether minor or major, temporary or permanent,
unless otherwise with the written consent and approval of the
LESSOR. The LESSEE is legally liable of any damages incurred in the
alteration of the leased property and shall at her expense pay such
damages.

3. The LESSEE shall in no case sub-lease the rented premises;

4. The LESSEE shall be obligated to maintain sanitation in the premises

and observe proper waste disposal of garbage;

5. The LESSEE is obliged to install anti-fire gadgets and/or fire

extinguishers for fire prevention which shall not be taken away after
the termination of the contract. The LESSEE shall strictly prohibit
smoking in the rented premises;

6. Liquefied petroleum gas (LPG) for cooking purpose only is allowed for
use. No inflammable material of any kind whatsoever shall be used,
stored or maintained by the LESSEE in the leased premises.

156
IN WITNESS WHEREOF, the parties have hereunto set their hands
th
this 6 day of December 2013 in the City of Baguio, Philippines.

MIKAELLA N. PANELA NELSON O. QUIRINO

Lessor Lessee

SIGNED IN THE PRESENCE OF:

ROGER Q. SANTOS SHEILA Q. TORRES

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared MIKAELLA N. PANELA and NELSON
O. QUIRINO, personally known to me to be the same persons who
voluntary executed the foregoing Business Space Lease Agreement which
they acknowledged before me as their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DELA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
PTR No. 1928374/Baguio City/01-04-13
Doc. No. 60; Roll of Atty. No. 67548/05-18-10
Page No. 12; IBP OR No. 739281/Baguio-Benguet/01-04-13
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2013 Commission Serial No. 01-NC-11 (R)

157
CONTRACT OF LEGAL SERVICES

KNOW ALL MEN BY THESE PRESENTS:

This Contract of Legal Services made and entered into by and

between:

TIONG SAN DEPARTMENT STORE, a business company existing and

registered under the Securities and Exchange Commission (SEC), owned
and represented by EDWARD YEE, located at Magsaysay, Baguio City,
hereinafter known as the CLIENT;

-and-

DELA CRUZ LAW FIRM AND ASSOCIATES under the leadership of

ATTY. JOHN DELA CRUZ, based and located at Chanum St., Baguio City
hereinafter known as the COUNSEL;

W I T N E S S E T H:

Whereas, the CLIENT entered into and acquired the legal services of
Atty. John Dela Cruz as the counsel of the Tiong San Department Store in
the case instituted by the latter against Maria Aquino, docketed as Criminal
Case No. E1 – 23456 at Branch 7 of the Regional Trial Court for the case of
Shop Lifting;

Whereas, while the engagement of COUNSEL as lawyer for the

CLIENT, the following terms and conditions have been agreed upon:

1. That COUNSEL shall not engage his legal services to any business
corporation and institution related and similar to that of the business
operated by the CLIENT;

2. That the legal services agreement between the CLIENT and COUNSEL
would expire after five (5) years or on December 31, 2018;

3. That the CLIENT would not engage the legal services of other lawyers
without the prior consent of COUNSEL;

4. That any violation committed by either party to the terms and

conditions of this contract shall be subject to legal sanctions.

158
IN WITNESS WHEREOF, the parties have hereunto set their hands
th
this 6 day of December 2013 at the City of Baguio, Philippines.

EDWARD YEE ATTY. JOHN DELA CRUZ

Client/Proprietor Dela Cruz Law Firm and Associates
Tiongsan Department Store

SIGNED IN THE PRESENCE OF:

WILLIAM CHING RICHARD YAP

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared EDWARD YEE and ATTY. JOHN
DELA CRUZ, personally known to me to be the same persons who executed
the foregoing Contract of Legal Services which they acknowledged before
me as their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
PTR No. 1928374/Baguio City/01-04-13
Doc. No. 61; Roll of Atty. No. 67548/05-18-10
Page No. 13; IBP OR No. 739281/Baguio-Benguet/01-04-13
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2013 Commission Serial No. 01-NC-11 (R)

GENERAL POWER OF ATTORNEY

159
KNOW ALL MEN BY THESE PRESENTS:

I, DARIUS R. SAMANIEGO, single, of legal age, Filipino citizen, with

residence and postal address at 14 M. Roxas, Trancoville, Baguio City,
Philippines, DO HEREBY NAME, CONSTITUTE AND APPOINT LONGINUS S.
GREGORIO, of legal age, single, Filipino, and a resident of 9 Rimando Road,
Baguio City, Philippines, to be my true and lawful ATTORNEY-IN-FACT, for
me and in my name, place and stead to perform the following acts and
things, to wit:

1. To manage and administer all my property, real and personal, that

may be found in the Philippines;

2. To ask demand, sue for, recover, collect and receipt for any and all
sums of money, debts, accounts, legacies, bequests, interest,
dividends, demands, and other things of value of whatsoever nature
or kind as may now be or may hereafter become due, owing, payable
or belonging to me , and to have, use and take any and all lawful
ways and means for the recovery thereof by suit, attachment,
garnishment or otherwise, and to compromise, settle and agree for
the same;

3. To buy or negotiate for the sale, hire or lease, mortgage, or

otherwise hypothecate lands, tenements and hereditaments or other
forms of real property, upon such terms and conditions and under
such covenants as my said attorney-in-fact shall see fit and proper;

4. To purchase and sell, mortgage pledge or otherwise hypothecate

goods, wares, merchandise, chattels, and other personal property or
in action;

5. To attend any and all meetings, special, regular, ordinary or

extraordinary, of any and all firms, corporations, association, or other
concerns of which I may now be or hereafter become a member or
stockholder, and then and there to exercise my voice and vote and
whatsoever other privileges, rights and prerogatives as may
correspond to me by reason of my membership, shares or other
participation therein;

6. To make, sign, execute and deliver contracts, documents,

agreements, and other writings of whatever nature or kind, with any
and all third persons, concerns, or entities, upon terms and
conditions acceptable to my said attorney;
160
7. To prosecute and defend any and all suits, actions and other
proceedings in the courts, tribunal, departments and offices of the
government of the Philippines, and to terminate, compromise, settle
and adjust the same and the subject-matter thereof;

8. To delegate in whole or in part any or all of the powers herein

granted or conferred, by means of an instrument in favor of any third
person whom my said attorney may select.

HEREBY GIVING AND GRANTING unto my said attorney full power

and authority whatsoever requisite or necessary or proper to be done in
and about the premises as fully to all intents and purposes as I might or
could lawfully do if personally present, with power of substitution and
revocation, and hereby, ratifying and confirming all that my said attorney or
his substitute shall lawfully do or cause to be done under and by virtue of
these presents.

IN WITNESS WHEREOF, I have hereunto set my hand this 10 th day of

January 2013, in the City of Baguio, Philippines.

DARIUS R. SAMANIEGO
Principal
Passport No. ZZ0023023
Valid until May 30, 2016

Conforme:

LONGINUS S. GREGORIO
Attorney-in-fact
TIN 090-922-080

SIGNED IN THE PRESENCE OF:

BRUTUS D. PLATONO CASSIUS F. SOCRATO

ACKNOWLEDGMENT
161
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared DARIUS R. SAMANIEGO and
LONGINUS S. GREGORIO who exhibited to me their respective
identification documents as appearing below their respective names and
signatures, known to me as the same persons who executed and voluntarily
signed the foregoing General Power of Attorney which they acknowledged
before me as their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 62;

Page No. 13;
Book No. I;
Series of 2013

162
SPECIAL POWER OF ATTORNEY

KNOW ALL MEN BY THESE PRESENTS:

We, SPOUSES CALLISTO J. CENTURIO and GANYMEDE J. CENTURIO,

both of legal age, Filipino citizens, with residence and postal address at 37
Barangay Ferdinand, Campo Sioco, Baguio City, hereby NAME, CONSTITUTE
AND APPOINT EUROPA C. SATURNINO, single, of legal age, with residence
and postal address at 132 Fairview Subdivision, Baguio City, Philippines, as our
true and legal representative to act for and in our names and stead, within a
period of ONE (1) YEAR, and to perform the following acts, deeds and things,
to wit:

1. To sell, offer for sale, and come to an agreement as to the purchase

price, and thereafter to sign for us and in our name and receive
payment from the sale of our property, a motor vehicle, more
particularly described as follows:

Make & Series: Mitsubishi Lancer 2004 Model

Engine No.: VN - 139731
Chassis No.: JNBGP7362V6217830
Plate No.: WTJ 476
MV File No.: 1123 – 0000042831A
Type of Body: SUV

2. To sign, execute and deliver the Deed of Absolute Sale, contract or

any other instrument or document of whatever kind, as may be
necessary or proper as said Attorney-in-Fact may, in her discretion,
deem to be our best interest;

3. To demand, collect, receive and accept the proceeds thereof, the

purchase price be on the amount of SIX HUNDRED THOUSAND
PESOS (Php 600,000.00), in cash or in check, and, if in check, to
endorse and encash the same in any third party and/or any bank or
banking institution.

HEREBY GRANTING unto our representative full power and

authority to execute and perform every act necessary to render effective
the power to sell the foregoing properties, as fully to all intents and
purposes as we might or could do if personally present shall lawfully do or
cause to be done by virtue of these presents with full power of substitution
and revocation, and HEREBY RATIFYING AND CONFIRMING ALL that our
Attorney-in-fact or her substitute shall lawfully do or cause to be done by
virtue hereof.
163
IN WITNESS WHEREOF, we have hereunto set our hands this 6th day
of December 2013, in the City of Baguio, Philippines.

CALLISTO J. CENTURIO GANYMEDE J. CENTURIO

Principal Principal
SSS No. 1-1569347-5 TIN 087-054-941

Conforme:
EUROPA C. SATURNINO
Attorney-in-Fact
TIN 476-879-090

SIGNED IN THE PRESENCE OF:

VENUS E. MARCIAL PRIMO R. VALDEZ

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared Spouses CALLISTO J. CENTURIO
and GANYMEDE J. CENTURIO who exhibited to me their respective
identification documents as indicated below their respective names and
signatures, known to me as the same persons who executed and signed the
foregoing Special Power of Attorney to Sell a Personal Property which they
acknowledged before me as their free and voluntary acts and deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
PTR No. 1928374/Baguio City/01-04-13
Doc. No. 63; Roll of Atty. No. 67548/05-18-10
Page No. 13; IBP OR No. 739281/Baguio-Benguet/01-04-13
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2013 Commission Serial No. 01-NC-11 (R)
164
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.

WAIVER, RELEASE, AND QUITCLAIM

I, CASSIOPEIA S. ANDROMEDA, Filipino, of legal age, single and a

resident of 89 Military Cut-off, Baguio City, Philippines, after being sworn to
in accordance with law, hereby depose and state:

1. That by these presents, I hereby state that I have voluntarily resigned

as STAFF NURSE of STARRY STARRY NIGHT HOSPITAL located at 67
Magsaysay Avenue, Baguio City;

2. That I hereby acknowledge to have received from my employer the

sum of ONE HUNDRED THOUSAND PESOS (Php 100,000.00) which is
in full and final satisfaction of my salary and other benefits that may
be due me for the service which I have rendered for the latter;

3. That I hereby declare that I have no further claims whatsoever

against my employer, its President, members of the Board, officers or
any of its staff and that I hereby release and forever discharge all of
them from any and all claims, demands, cause of action of whatever
nature arising out of my employment with the latter;

4. I further agree that this WAIVER, RELEASE, AND QUITCLAIM may be

pleaded in bar to any suit or proceeding (Civil, SSS, PhilHealth, Labor,
etc.) to which either I, or my heirs and assigns, may have against my
employer in connection with my employment with the latter;

5. That the payment which I have received as provided herein should

not in any way be construed as an admission of liability on the part of
my employer and is voluntarily accepted by me and will, if need be,
serve as full and final settlement of any amounts due me or any
claims or cause of action, either past, present, future, which I may
have in connection with my employment with my employer;

6. As such, I finally make manifest that I have no further claims or cause

of action against my employer or any person connected with the
administration and operation of the latter and forever release the
latter from any and all liability.

165
IN WITNESS WHEREOF, I have hereunto set my hand this 6 th day of
December 2013 in Baguio City, Philippines.

CASSIOPEIA S. ANDROMEDA
Affiant

SUBSCRIBED AND SWORN to before me in the City of Baguio this 6 th

day of December 2013, by CASSIOPEIA S. ANDROMEDA, who has
satisfactorily proven her identity to me through her Non-Professional
Driver’s License No. A01-09-070685 valid until July 6, 2015, that she is the
same person who personally signed the foregoing Waiver, Release, and
Quitclaim before me and acknowledged that she executed the same.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 64;

Page No. 13;
Book No. I;
Series of 2013

166
REVOCATION OF POWER OF ATTORNEY

KNOW ALL MEN BY THESE PRESENTS:

Whereas, I, ANNE B. CRUZ, of legal age, married, resident of 9

Aurora Hill, Baguio City, by a certain public instrument made and executed
in Baguio City on January 31, 2013 before HONORIO G. BUCCAT JR., Notary
Public for and in the City of Baguio, and bearing Not. Reg. No. 23; Page 5,
Book I, Series of 2013 of his Notarial Register, did name, constitute, and
appoint MARIE Z. SANTOS, resident of Bakakeng, Baguio City, my true and
lawful ATTORNEY-IN-FACT, for the purpose and with powers mentioned in
said public instrument;

Whereas, the said public instrument or Power of Attorney, was duly

registered in the Office of the Register of Deeds of Baguio City on February
2, 2013, as per Entry No. 2, Vol. II, Book I, of said Office;

NOW, THEREFORE, I, ANNE B. CRUZ, by virtue of these presents,

hereby REVOKE, ANNUL, and make VOID the said power of attorney and all
powers and authority therein or thereby given or granted, or intended to
be given or granted to said MARIE Z. SANTOS.

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

December 2013, in the City of Baguio, Philippines.

ANNE B. CRUZ
TIN 409-798-090

SIGNED IN THE PRESENCE OF:

JOHN B. DE LA CRUZ TINA F. DE LA TORRE

167
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared ANNE B. CRUZ, personally known
to me to be the same person who voluntary executed the foregoing
Revocation of Power of Attorney which she acknowledged before me as
her free and voluntary 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 party and her witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 65;

Page No. 13;
Book No. I;
Series of 2013

168
SUBSTITUTION OF ATTORNEY – IN – FACT

KNOW ALL MEN BY THESE PRESENTS:

Whereas, I, ROMEO Z. VASQUEZ, of legal age, married, resident of

North Sanitary Camp, Baguio City, had been appointed ATTORNEY-IN- FACT
of JULIET Y. VELASQUEZ, of legal age, married, resident of Camp Dangwa,
La Trinidad, Benguet, by virtue of a POWER OF ATTORNEY executed in
Baguio City on January 30, 2013 and acknowledged before LAIRD DIONEL N.
URBANOZO, Notary Public for and in the City of Baguio, and bearing Not.
Reg. No. 12, Page 3, Book I, Series of 2013 of his Notarial Register;

Whereas, by the said power of attorney, I was granted full power to

appoint a substitute of my choice for and in respect of all or any of the
matters mentioned in said power of attorney;

Whereas, by virtue of said grant, I hereby NAME, CONSTITUTE AND

APPOINT BENVOLIO W. VALDEZ, my true and lawful SUBSTITUTE
ATTORNEY for me and my name as Attorney-in-Fact of said JULIET Y.
VELASQUEZ, and in her name, place and stead, to do and perform any and
all acts and things which I, as Attorney-in-Fact of said JULIET Y. VELASQUEZ
could lawfully do and perform under said power of attorney, as fully to all
intents and purposes as I or said JULIET Y. VELASQUEZ, might or could
lawfully do if personally present, save only in the matter of appointing a
substitute other than the substitute herein designated; and

HEREBY RATIFYING AND CONFIRMING all that said BENVOLIO W.

VALDEZ may lawfully do or cause to be done by virtue of these presents.

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

December 2013 in the City of Baguio, Philippines.

ROMEO Z. VASQUEZ

Conforme:
BENVOLIO W. VALDEZ
Substitute Attorney-in-Fact

SIGNED IN THE PRESENCE OF:

MACBETH S. WILLIAMS HAMLET S. INGLES

169
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.

BEFORE ME, a Notary Public in and for the City of Baguio, this 6 th day
of December 2013, personally appeared ROMEO Z. VASQUEZ and
BENVOLIO W. VALDEZ, personally known to me to be the same persons
who voluntary executed the foregoing Substitution of Attorney-in-Fact
which they acknowledged before me as their free and voluntary acts and
deeds.

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 parties and their witnesses.

WITNESS MY HAND AND SEAL.

JUAN DE LA CRUZ JR.

Doc. No. 66;

Page No. 14;
Book No. I;
Series of 2013

170
EJECTMENT
CASES
EJECTMENT is a legal action brought by one claiming a right to possess real
property against another who possesses the premises adversely or who is a
holdover tenant who remains beyond the termination of a lease but who is
not merely a trespasser.

171
Republic of the Philippines
Municipal Trial Court in Cities
First Judicial Region
Branch I, Baguio City

ANGELICA Y. SANTIBANYEZ,
Plaintiff,

-versus- Civil Case No. _______

For: Unlawful Detainer

MARIA MAGDALENA P. ALDANA,

Defendant.
x----------------------------------------------x

COMPLAINT

COMES NOW the plaintiff through the undersigned counsel and unto
this Honorable Court alleges:

1. That plaintiff is a Filipino citizen, of legal age, married, and residing at

8 Orchard Street, Brent Townhomes, Baguio City;

2. That defendant is also a Filipino citizen, of legal age, with residence

and postal address at 1 Cabinet Hill, Baguio City where she may be
served with summons;

3. That the plaintiff is the lessor of the condominium unit located at 1

Cabinet Hill, Baguio City, Baguio City;

4. That by virtue of a verbal agreement of lease, plaintiff leased unto

the defendant the aforesaid condominium unit under the express
obligation of paying a monthly rent of fifteen thousand pesos
(₱15,000.00), payable within the first five (5) days of every month;

5. That the plaintiff has verbally demanded several times for the
defendant to vacate the said condominium unit and to pay the
outstanding rents, now amounting to forty-five thousand pesos
(₱45,000.000) covering the months of October, November, and
December 2013;

6. That on January 2, 2014, plaintiff sent a letter of demand for

payment of rentals and to order the defendant to vacate the
condominium unit, which was received by the defendant;
172
7. That despite said letter of demand which was followed through with
verbal demands, defendant failed and still refused to pay the
outstanding rentals and to vacate the condominium unit;

8. That this case has been referred to the Office of the Barangay
Captain for conciliation but to no avail;

9. That by reason of the failure of the defendant to vacate the premises

and to pay the rent, plaintiff was compelled to file this complaint
engaging the services of counsel in the amount of twenty thousand
pesos (₱20,000.00).

PRAYER

WHEREFORE, it is respectfully prayed that after due hearing,

judgment be rendered in favor of the plaintiff, and ordering the defendant:

1. to vacate the condominium unit;

2. to pay the sum of forty-five thousand pesos (₱45,000.000)

representing the arrears of rent now overdue, and further rentals
until the defendant fully vacates the premises; and

3. to pay the cost of the suit.

Plaintiff prays for such other remedy as this Honorable Court may
deem just and equitable.

Baguio City, Philippines, this 10th day of January 2014.

JUAN DE LA CRUZ JR.

Counsel for the Plaintiff
100A Session Road, Baguio City
(074) 422-1234
PTR No. 1928374/Baguio City/01-04-13
Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-04-13
MCLE Compliance No. IV-90210/04-22-13

173
VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, ANGELICA Y. SANTIBANYEZ, of legal age, married, Filipino citizen,

and a resident of 8 Orchard Street, Brent Townhomes, Baguio City,
Philippines after having been duly sworn in accordance with law, depose
and state that:

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

2. I have caused the preparation and the filing of the foregoing

complaint;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession;

4. I have not commenced any other action or proceeding involving the

same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;

5. To the best of my knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency.

6. If I should thereafter learn that a similar action or proceeding has

been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that
fact within five (5) days therefrom to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto set my hand this 10th day of

January 2014, at Baguio City, Philippines.

ANGELICA Y. SANTIBANYEZ
Affiant

174
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 10th day of January 2014, by ANGELICA Y. SANTIBANYEZ,
who is personally known to me.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
PTR No. 1928374/Baguio City/01-02-14
Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-90210/04-22-13
Commission Serial No. 01-NC-11 (R)

Doc. No. 67;

Page No. 14;
Book No. I;
Series of 2014

Copy Furnished:

Atty. Fernando Jose Altamirano Del Castillo

Counsel for the Defendant
45 Hotel, Leonard Wood Road, Baguio City

175
DEMAND LETTER

2 January 2014

MARIA MAGDALENA P. ALDANA,

1 Cabinet Hill
Baguio City

Dear Ms. Aldana:

I write in behalf of Mrs. Angelica Y. Santibanyez of 8 Orchard Street, Brent

Townhomes, Baguio City.

Be reminded that you have not paid your rent on the leased premises for
the months of October, November, and December 2013 amounting to
forty-five thousand pesos (₱45,000.000). Demand was made upon you
orally to pay your outstanding rental fees but you refused.

Final demand is being made upon you to pay your outstanding rent and
vacate the leased premises within five (5) days from receipt of this letter or
else my client will have no option left but to file the appropriate case
against you in the courts of law.

It is recommended that you act on this matter immediately to avoid the

embarrassment and rigors of court litigation.

Thank you.

Very truly yours,

JUAN DE LA CRUZ JR.

Counsel for Mrs. Santibanyez

176
Republic of the Philippines
Cabinet Hill-Teacher’s Camp Barangay
Baguio City
OFFICE OF THE LUPONG TAGAPAMAYAPA

ANGELICA Y. SANTIBANYEZ,
Complainant,

-versus- Barangay Case No. 2014-01

For: Unlawful Detainer

MARIA MAGDALENA P. ALDANA,

Respondent.
x----------------------------------------------x

CERTIFICATION TO FILE ACTION

This is to certify that:

1. There has been personal confrontation between the parties in the
above captioned case before the Punong Barangay and the Lupon ng
Tagapagkasundo.
2. There were neither settlement nor conciliation during the arbitration
and mediation proceedings in the barangay.
3. Both Parties agreed and decided to elevate the above stated case to
a higher court of law.
THEREFORE, the corresponding complaint for the dispute may now
be filed in a court of law.
Issued this 8th day of January 2014 at Cabinet Hill-Teacher’s Camp,
Baguio City.

SERGIO M. FERNANDO
Lupon Secretary

Attested:

FACUNDO S. ALIPIN
Punong Barangay Received By:

177
Republic of the Philippines
Municipal Trial Court in Cities
First Judicial Region
Branch I, Baguio City

ANGELICA Y. SANTIBANYEZ,
Plaintiff,

-versus- Civil Case No. 12345-2014

For: Unlawful Detainer

MARIA MAGDALENA P. ALDANA,

Defendant.
x----------------------------------------------x

ANSWER

With all due respect to this Honorable Court, Defendant, through the
undersigned Counsel, respectfully alleges:

1. That Defendant admits the allegations stated in paragraph 2 of the

Complaint as to her personal circumstances;

2. That Defendant admits the allegations contained in paragraph 3 as to

the lessor and location of the condominium unit;

3. That Defendant admits the allegations stated in paragraph 4 as to the

verbal agreement of lease;

4. That Defendant admits the allegations contained in paragraph 8 as to

the non-conciliation at the Office of the Punong Barangay;

5. That Defendant specifically denies the allegations contained in

paragraphs 5, 6, and 7 with respect to the non-payment of
outstanding rents from October to December 2013;

6. That Defendant specifically denies the allegations stated in paragraph

9 of the Complaint for the need of engaging the services of counsel;

SPECIAL AFFIRMATIVE DEFENSES

7. That Defendant noticed on October 2013 that the unit is

deteriorating as the roof is infested with termites and may fall at any
178
moment. The plumbing system of the unit also started to leak water
in the bathroom and under the sink. Defendant reported these
problems to the Plaintiff for several consecutive days, however she
did not give attention to these;

8. That Defendant upholds the principle that the Plaintiff must not be
unjustly enriched at Defendant’s expense. Defendant worried that
accidents may occur due to these problems, took it to herself to have
the unit repaired which included the repairs of the roof and the
plumbing system in which Defendant incurred expenses amounting
to Php 50,000.00;

9. That Defendant reported to Plaintiff the expenses incurred for

repairs but Plaintiff did not believe the reports despite of the
evidence presented by the Defendant. Plaintiff still demanded the
payment for the rent even if it is incumbent upon her to maintain the
safety and living conditions of the unit as stipulated in the contract of
lease;

10.That if Plaintiff had given attention to the reported problems of the

unit by the Defendant, the services of a lawyer would not have been
necessary;

COUNTERCLAIM

11.That due to the Plaintiff’s unnecessary acts, Defendant was forced to

engage the services of the undersigned Counsel wherein they agreed
to pay Php 50,000.00 as Attorney’s Fees and Php 2,000.00
Appearance Fee for every hearing;

12.That due to these acts of the Plaintiff, Defendant suffered and will
continue to suffer no end of mental anguish, anxieties, humiliation,
wounded feelings and sleepless nights for which if quantified would
amount to Php 20,000.00 in the form of Moral Damages;

13.That in order to deter the commission of the same act, Plaintiff

should be ordered to pay the amount of Php 10,000.00 as Exemplary
Damages.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of

this Honorable Court that after due notice and hearing, judgment be
rendered in favor of the Defendant:
179
1. Ordering Plaintiff to pay the amount of Php 50,000.00 as
Attorney’s Fees and Php 2,000.00 Appearance Fee for every
hearing;

2. Ordering Plaintiff to pay Php 20,000.00 as Moral Damages;

3. Ordering Plaintiff to pay Php 10,000.00 as Exemplary Damages;

4. Ordering Plaintiff to pay the costs of this suit.

Defendant further prays for other reliefs and remedies just and
equitable under the premises.

Baguio City, Philippines, this 13th day of January 2014.

FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Defendant
PTR No. 11123445:1-3-14:Baguio City
IBP No. 654123:1-3-14:Baguio City
Roll No. 56565:4-1-00:Manila
MCLE Compliance No. 67657:5-20-13:Manila
45 Hotel, Leonard Wood Road, Baguio City

180
VERIFICATION
I, MARIA MAGDALENA P. ALDANA, of legal age, Filipino citizen,
single, and a resident of 1 Cabinet Hill, Baguio City, Philippines, after having
been duly sworn to in accordance with law, depose and state that:
1. I am the Defendant in the above-entitled case;
2. I have caused the preparation and the filing of the foregoing
answer;
3. I have read the contents thereof and the same are true and
correct to the best of my personal knowledge and on the basis of
copies of documents and records in my possession.
IN WITNESS WHEREOF, I have hereunto set my hand this 13th day of
January 2014, at Baguio City, Philippines.

MARIA MAGDALENA P. ALDANA

Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 13th day of January 2014, by MARIA MAGDALENA P.
ALDANA, who is personally known to me.

FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Notary Public
Until December 31, 2014
45 Hotel, Leonard Wood Road, Baguio City
PTR No. 11123445:1-3-14:Baguio City
IBP No. 654123:1-3-14:Baguio City
Roll No. 56565:4-1-00:Manila
MCLE Compliance No. 67657:5-20-13:Manila
Commission Serial No. 02-NC-13 (R)

Doc. No. 5
Page No. 1
Book No. V
Series of 2014

Copy Furnished:

JUAN DELA CRUZ JR.

Counsel for the Plaintiff
100A Session Road, Baguio City
181
Republic of the Philippines
Municipal Trial Court in Cities
First Judicial Region
Branch I, Baguio City

ANGELICA Y. SANTIBANYEZ,
Plaintiff,

-versus- Civil Case No. _____

For: Forcible Entry

MARI MAR P. ALDANA,

Defendant.
x-------------------------------------x

COMPLAINT

COMES NOW the plaintiff through the undersigned counsel and unto
this Honorable Court alleges:

1. That plaintiff is a Filipino citizen, of legal age, married, and residing at

8 Orchard Street, Brent Townhomes, Baguio City;

2. That defendant is also a Filipino citizen, of legal age, with residence

and postal address at 1 Cabinet Hill, Baguio City where she may be
served with summons;

3. That the plaintiff is the absolute owner of the Angelica Building

located at 1 Cabinet Hill, Baguio City, Baguio City;

4. That on December 25, 2013, the defendant, by means of force,

intimidation, strategy and stealth, unlawfully entered upon the
penthouse of the above described property;

5. As if to add injury, defendant unloaded her belongings in the

penthouse and claimed it as her own even placing her filthy dog
Fulgoso on the premises and a sign saying “Property of Mari Mar! No
trespassing!” on the door;

6. That plaintiff confronted the defendant but she refused to vacate

said penthouse and still persists in continuing the unlawful acts upon
the property;

182
7. That this case has been referred to the Office of the Barangay
Captain for conciliation but to no avail;

8. That by reason of the failure of the defendant to vacate the premises

plaintiff was compelled to file this complaint engaging the services of
counsel in the amount of twenty thousand pesos (₱20,000.00).

PRAYER

WHEREFORE, it is respectfully prayed that after due hearing,

judgment be rendered in favor of the plaintiff, and ordering the defendant:

1. Before hearing, a temporary restraining order be issued against the

defendant;

2. After due notice and hearing, to issue Writ of Injunction ordering

defendant:
a. To allow plaintiff to take possession of her property;
b. To make the Injunction against defendant permanent and
indefinite;

3. Judgment be rendered in favor of the plaintiff ordering defendant to

pay, by way of reimbursement of litigation expenses, the amount of
not less than twenty thousand pesos (₱20,000.00) and to pay
reasonable Attorney’s fees;

Plaintiff prays for such other remedy as this Honorable Court may
deem just and equitable.

Baguio City, Philippines, this 10th day of January 2014.

JUAN DE LA CRUZ JR.

183
VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, ANGELICA Y. SANTIBANYEZ, of legal age, married, Filipino citizen,

and a resident of 8 Orchard Street, Brent Townhomes, Baguio City,
Philippines after having been duly sworn in accordance with law, depose
and state that:

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

2. I have caused the preparation and the filing of the foregoing

complaint;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession;

4. I have not commenced any other action or proceeding involving the

same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;

5. To the best of my knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency.

6. If I should thereafter learn that a similar action or proceeding has

been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that
fact within five (5) days therefrom to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto set my hand this 10th day of

January 2014, at Baguio City, Philippines.

ANGELICA Y. SANTIBANYEZ
Affiant

184
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 10th day of January 2014, by ANGELICA Y. SANTIBANYEZ,
who is personally known to me.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
PTR No. 1928374/Baguio City/01-02-14
Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-90210/04-22-13
Commission Serial No. 01-NC-11 (R)

Doc. No. 68;

Page No. 14;
Book No. I;
Series of 2014

Copy Furnished:

Atty. Fernando Jose Altamirano Del Castillo

Counsel for the Defendant
45 Hotel, Leonard Wood Road, Baguio City

185
Republic of the Philippines
Cabinet Hill-Teacher’s Camp Barangay
Baguio City
OFFICE OF THE LUPONG TAGAPAMAYAPA

ANGELICA Y. SANTIBANYEZ,
Complainant,

-versus- Barangay Case No. 2014-02

For: Forcible Entry
MARI MAR P. ALDANA,
Respondent.
x--------------------------------------x

CERTIFICATION TO FILE ACTION

This is to certify that:

SERGIO M. FERNANDO
Lupon Secretary

Attested:

FACUNDO S. ALIPIN
Punong Barangay Received By:

186
Republic of the Philippines
Municipal Trial Court in Cities
First Judicial Region
Branch I, Baguio City

ANGELICA Y. SANTIBANYEZ,
Plaintiff,

-versus- Civil Case No. 12346-2014

For: Forcible Entry

MARI MAR P. ALDANA,

Defendant.
x--------------------------------------x

ANSWER

With all due respect to this Honorable Court, Defendant, through the
undersigned Counsel, respectfully alleges:

1. That Defendant admits the allegations stated in paragraph 2, 3, 5, 6,

and 7 of the Complaint, except the description on paragraph 5 of the
dog Fulgoso being filthy which she specifically denies;

2. That Defendant specifically denies the allegation contained in

paragraph 4 with respect to unlawfully entering the penthouse by
means of force, intimidation, strategy and stealth;

3. That Defendant specifically denies the allegations stated in paragraph

8 of the Complaint for the need of engaging the services of counsel;

SPECIAL AFFIRMATIVE DEFENSES

4. That Defendant was invited by Sergio Santibanyez at the penthouse

on December 25, 2013 and he said to her, “From this day forward,
you will now live in this penthouse. No hell or high water, nor even
my stepmother can make you leave our penthouse of love and
dreams. This I promise you and I will take care of you. I will tell my
stepmother of this thing by tomorrow morning.”

187
COUNTERCLAIM

5. That due to the Plaintiff’s unnecessary acts, Defendant was forced to

engage the services of the undersigned Counsel wherein they agreed
to pay Php 50,000.00 as Attorney’s Fees and Php 2,000.00
Appearance Fee for every hearing;

6. That due to these acts of the Plaintiff, Defendant suffered and will
continue to suffer no end of mental anguish, anxieties, humiliation,
wounded feelings and sleepless nights for which if quantified would
amount to Php 10,000.00 in the form of Moral Damages;

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of

this Honorable Court that after due notice and hearing, judgment be
rendered in favor of the Defendant:

1. Ordering Plaintiff to pay the amount of Php 50,000.00 as

Attorney’s Fees and Php 2,000.00 Appearance Fee for every
hearing;

2. Ordering Plaintiff to pay Php 10,000.00 as Moral Damages;

3. Ordering Plaintiff to pay the costs of this suit.

Defendant further prays for other reliefs and remedies just and
equitable under the premises.

Baguio City, Philippines, this 13th day of January 2014.

FERNANDO JOSE ALTAMIRANO DEL CASTILLO

188
VERIFICATION

I, MARI MAR P. ALDANA, of legal age, Filipino citizen, single, and a

resident of 1 Cabinet Hill, Baguio City, Philippines, after having been duly
sworn to in accordance with law, depose and state that:
1. I am the Defendant in the above-entitled case;
2. I have caused the preparation and the filing of the foregoing
answer;
3. I have read the contents thereof and the same are true and
correct to the best of my personal knowledge and on the basis of
copies of documents and records in my possession.
IN WITNESS WHEREOF, I have hereunto set my hand this 13th day of
January 2014, at Baguio City, Philippines.

MARI MAR P. ALDANA

Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 13th day of January 2014, by MARI MAR P. ALDANA, who is
personally known to me.

FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Copy Furnished:

JUAN DELA CRUZ JR.

Counsel for the Plaintiff
100A Session Road, Baguio City
189
Republic of the Philippines
Municipal Trial Court in Cities
First Judicial Region
Branch I, Baguio City

ANGELICA Y. SANTIBANYEZ,
Plaintiff,

-versus- Civil Case No. _____

For: Unlawful Detainer

MARIA MAGDALENA P. ALDANA,

Defendant.
x----------------------------------------------x

COMPLAINT

COMES NOW the plaintiff through the undersigned counsel and unto
this Honorable Court alleges:

1. That plaintiff is a Filipino citizen, of legal age, married, and residing at

8 Orchard Street, Brent Townhomes, Baguio City;

2. That defendant is also a Filipino citizen, of legal age, with residence

and postal address at 1 Cabinet Hill, Baguio City where she may be
served with summons;

3. That the plaintiff is the lessor of the condominium unit located at 1

Cabinet Hill, Baguio City, Baguio City;

4. That by virtue of a verbal agreement of lease, plaintiff leased unto

the defendant the aforesaid condominium unit under the express
obligation of paying a monthly rent of fifteen thousand pesos
(₱15,000.00), payable within the first five (5) days of every month;

6. That on January 2, 2014, plaintiff sent a letter of demand for

payment of rentals and to order the defendant to vacate the
condominium unit, which was received by the defendant;
190
7. That despite said letter of demand which was followed through with
verbal demands, defendant failed and still refused to pay the
outstanding rentals and to vacate the condominium unit;

8. That this case has been referred to the Office of the Barangay
Captain for conciliation but to no avail;

9. That by reason of the failure of the defendant to vacate the premises

and to pay the rent, plaintiff was compelled to file this complaint
engaging the services of counsel in the amount of twenty thousand
pesos (₱20,000.00).

PRAYER

WHEREFORE, it is respectfully prayed that after due hearing,

judgment be rendered in favor of the plaintiff, and ordering the defendant:

1. to vacate the condominium unit;

2. to pay the sum of forty-five thousand pesos (₱45,000.000)

representing the arrears of rent now overdue, and further rentals
until the defendant fully vacates the premises; and

3. to pay the cost of the suit.

Plaintiff prays for such other remedy as this Honorable Court may
deem just and equitable.

Baguio City, Philippines, this 10th day of January 2014.

JUAN DE LA CRUZ JR.

191
VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, ANGELICA Y. SANTIBANYEZ, of legal age, married, Filipino citizen,

and a resident of 8 Orchard Street, Brent Townhomes, Baguio City,
Philippines after having been duly sworn in accordance with law, depose
and state that:

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

2. I have caused the preparation and the filing of the foregoing

complaint;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession;

4. I have not commenced any other action or proceeding involving the

same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;

5. To the best of my knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency.

6. If I should thereafter learn that a similar action or proceeding has

been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that
fact within five (5) days therefrom to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto set my hand this 10th day of

January 2014, at Baguio City, Philippines.

ANGELICA Y. SANTIBANYEZ
Affiant

192
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 10th day of January 2014, by ANGELICA Y. SANTIBANYEZ,
who is personally known to me.

JUAN DE LA CRUZ JR.

Doc. No. 67;

Page No. 14;
Book No. I;
Series of 2014

Copy Furnished:

Atty. Fernando Jose Altamirano Del Castillo

Counsel for the Defendant
45 Hotel, Leonard Wood Road, Baguio City

193
DEMAND LETTER

2 January 2014

MARIA MAGDALENA P. ALDANA,

1 Cabinet Hill
Baguio City

Dear Ms. Aldana:

I write in behalf of Mrs. Angelica Y. Santibanyez of 8 Orchard Street, Brent

Townhomes, Baguio City.

It is recommended that you act on this matter immediately to avoid the

embarrassment and rigors of court litigation.

Thank you.

Very truly yours,

JUAN DELA CRUZ JR.

Counsel for Mrs. Santibanyez

194
Republic of the Philippines
Cabinet Hill-Teacher’s Camp Barangay
Baguio City
OFFICE OF THE LUPONG TAGAPAMAYAPA

ANGELICA Y. SANTIBANYEZ,
Complainant,

-versus- Barangay Case No. 2014-01

For: Unlawful Detainer
MARIA MAGDALENA P. ALDANA,
Respondent.
x----------------------------------------------x

CERTIFICATION TO FILE ACTION

This is to certify that:

SERGIO M. FERNANDO
Lupon Secretary

Attested:

FACUNDO S. ALIPIN
Punong Barangay Received By:

195
Republic of the Philippines
Municipal Trial Court in Cities
First Judicial Region
Branch I, Baguio City

ANGELICA Y. SANTIBANYEZ,
Plaintiff,

-versus- Civil Case No. 12345-2014

For: Unlawful Detainer

MARIA MAGDALENA P. ALDANA,

Defendant.
x----------------------------------------------x

ANSWER

With all due respect to this Honorable Court, Defendant, through the
undersigned Counsel, respectfully alleges:

1. That Defendant admits the allegations stated in paragraph 2 of the

Complaint as to her personal circumstances;

2. That Defendant admits the allegations contained in paragraph 3 as to

the lessor and location of the condominium unit;

3. That Defendant admits the allegations stated in paragraph 4 as to the

verbal agreement of lease;

4. That Defendant admits the allegations contained in paragraph 8 as to

the non-conciliation at the Office of the Punong Barangay;

5. That Defendant specifically denies the allegations contained in

paragraphs 5, 6, and 7 with respect to the non-payment of
outstanding rents from October to December 2013;

6. That Defendant specifically denies the allegations stated in paragraph

9 of the Complaint for the need of engaging the services of counsel;

SPECIAL AFFIRMATIVE DEFENSES

7. That Defendant noticed on October 2013 that the unit is

deteriorating as the roof is infested with termites and may fall at any
196
moment. The plumbing system of the unit also started to leak water
in the bathroom and under the sink. Defendant reported these
problems to the Plaintiff for several consecutive days, however she
did not give attention to these;

9. That Defendant reported to Plaintiff the expenses incurred for

10.That if Plaintiff had given attention to the reported problems of the

unit by the Defendant, the services of a lawyer would not have been
necessary;

COUNTERCLAIM

11.That due to the Plaintiff’s unnecessary acts, Defendant was forced to

engage the services of the undersigned Counsel wherein they agreed
to pay Php 50,000.00 as Attorney’s Fees and Php 2,000.00
Appearance Fee for every hearing;

13.That in order to deter the commission of the same act, Plaintiff

should be ordered to pay the amount of Php 10,000.00 as Exemplary
Damages.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of

this Honorable Court that after due notice and hearing, judgment be
rendered in favor of the Defendant:
197
1. Ordering Plaintiff to pay the amount of Php 50,000.00 as
Attorney’s Fees and Php 2,000.00 Appearance Fee for every
hearing;

2. Ordering Plaintiff to pay Php 20,000.00 as Moral Damages;

3. Ordering Plaintiff to pay Php 10,000.00 as Exemplary Damages;

4. Ordering Plaintiff to pay the costs of this suit.

Defendant further prays for other reliefs and remedies just and
equitable under the premises.

Baguio City, Philippines, this 13th day of January 2014.

FERNANDO JOSE ALTAMIRANO DEL CASTILLO

198
VERIFICATION

I, MARIA MAGDALENA P. ALDANA, of legal age, Filipino citizen,

single, and a resident of 1 Cabinet Hill, Baguio City, Philippines, after having
been duly sworn to in accordance with law, depose and state that:
1. I am the Defendant in the above-entitled case;
2. I have caused the preparation and the filing of the foregoing
answer;
3. I have read the contents thereof and the same are true and
correct to the best of my personal knowledge and on the basis of
copies of documents and records in my possession.
IN WITNESS WHEREOF, I have hereunto set my hand this 13th day of
January 2014, at Baguio City, Philippines.

MARIA MAGDALENA P. ALDANA

Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 13th day of January 2014, by MARIA MAGDALENA P.
ALDANA, who is personally known to me.

FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Copy Furnished:

JUAN DELA CRUZ JR.

Counsel for the Plaintiff
100A Session Road, Baguio City
199
Republic of the Philippines
Municipal Trial Court in Cities
First Judicial Region
Branch I, Baguio City

ANGELICA Y. SANTIBANYEZ,
Plaintiff,

-versus- Civil Case No. _____

For: Forcible Entry

MARI MAR P. ALDANA,

Defendant.
x-------------------------------------x

COMPLAINT

COMES NOW the plaintiff through the undersigned counsel and unto
this Honorable Court alleges:

1. That plaintiff is a Filipino citizen, of legal age, married, and residing at

8 Orchard Street, Brent Townhomes, Baguio City;

2. That defendant is also a Filipino citizen, of legal age, with residence

and postal address at 1 Cabinet Hill, Baguio City where she may be
served with summons;

3. That the plaintiff is the absolute owner of the Angelica Building

located at 1 Cabinet Hill, Baguio City, Baguio City;

4. That on December 25, 2013, the defendant, by means of force,

intimidation, strategy and stealth, unlawfully entered upon the
penthouse of the above described property;

5. As if to add injury, defendant unloaded her belongings in the

penthouse and claimed it as her own even placing her filthy dog
Fulgoso on the premises and a sign saying “Property of Mari Mar! No
trespassing!” on the door;

6. That plaintiff confronted the defendant but she refused to vacate

said penthouse and still persists in continuing the unlawful acts upon
the property;

200
7. That this case has been referred to the Office of the Barangay
Captain for conciliation but to no avail;

8. That by reason of the failure of the defendant to vacate the premises

plaintiff was compelled to file this complaint engaging the services of
counsel in the amount of twenty thousand pesos (₱20,000.00).

PRAYER

WHEREFORE, it is respectfully prayed that after due hearing,

judgment be rendered in favor of the plaintiff, and ordering the defendant:

1. Before hearing, a temporary restraining order be issued against the

defendant;

2. After due notice and hearing, to issue Writ of Injunction ordering

defendant:
a. To allow plaintiff to take possession of her property;
b. To make the Injunction against defendant permanent and
indefinite;

3. Judgment be rendered in favor of the plaintiff ordering defendant to

pay, by way of reimbursement of litigation expenses, the amount of
not less than twenty thousand pesos (₱20,000.00) and to pay
reasonable Attorney’s fees;

Plaintiff prays for such other remedy as this Honorable Court may
deem just and equitable.

Baguio City, Philippines, this 10th day of January 2014.

JUAN DE LA CRUZ JR.

201
VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, ANGELICA Y. SANTIBANYEZ, of legal age, married, Filipino citizen,

and a resident of 8 Orchard Street, Brent Townhomes, Baguio City,
Philippines after having been duly sworn in accordance with law, depose
and state that:

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

2. I have caused the preparation and the filing of the foregoing

complaint;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession;

4. I have not commenced any other action or proceeding involving the

same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;

5. To the best of my knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency.

6. If I should thereafter learn that a similar action or proceeding has

been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that
fact within five (5) days therefrom to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto set my hand this 10th day of

January 2014, at Baguio City, Philippines.

ANGELICA Y. SANTIBANYEZ
Affiant

202
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 10th day of January 2014, by ANGELICA Y. SANTIBANYEZ,
who is personally known to me.

JUAN DE LA CRUZ JR.

Doc. No. 68;

Page No. 14;
Book No. I;
Series of 2014

Copy Furnished:

Atty. Fernando Jose Altamirano Del Castillo

Counsel for the Defendant
45 Hotel, Leonard Wood Road, Baguio City

203
Republic of the Philippines
Cabinet Hill-Teacher’s Camp Barangay
Baguio City
OFFICE OF THE LUPONG TAGAPAMAYAPA

ANGELICA Y. SANTIBANYEZ,
Complainant,

-versus- Barangay Case No. 2014-02

For: Forcible Entry
MARI MAR P. ALDANA,
Respondent.
x--------------------------------------x

CERTIFICATION TO FILE ACTION

This is to certify that:

SERGIO M. FERNANDO
Lupon Secretary

Attested:

FACUNDO S. ALIPIN
Punong Barangay Received By:

204
Republic of the Philippines
Municipal Trial Court in Cities
First Judicial Region
Branch I, Baguio City

ANGELICA Y. SANTIBANYEZ,
Plaintiff,

-versus- Civil Case No. 12346-2014

For: Forcible Entry

MARI MAR P. ALDANA,

Defendant.
x--------------------------------------x

ANSWER

With all due respect to this Honorable Court, Defendant, through the
undersigned Counsel, respectfully alleges:

1. That Defendant admits the allegations stated in paragraph 2, 3, 5, 6,

and 7 of the Complaint, except the description on paragraph 5 of the
dog Fulgoso being filthy which she specifically denies;

2. That Defendant specifically denies the allegation contained in

paragraph 4 with respect to unlawfully entering the penthouse by
means of force, intimidation, strategy and stealth;

3. That Defendant specifically denies the allegations stated in paragraph

8 of the Complaint for the need of engaging the services of counsel;

SPECIAL AFFIRMATIVE DEFENSES

4. That Defendant was invited by Sergio Santibanyez at the penthouse

205
COUNTERCLAIM

5. That due to the Plaintiff’s unnecessary acts, Defendant was forced to

engage the services of the undersigned Counsel wherein they agreed
to pay Php 50,000.00 as Attorney’s Fees and Php 2,000.00
Appearance Fee for every hearing;

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of

this Honorable Court that after due notice and hearing, judgment be
rendered in favor of the Defendant:

1. Ordering Plaintiff to pay the amount of Php 50,000.00 as

Attorney’s Fees and Php 2,000.00 Appearance Fee for every
hearing;

2. Ordering Plaintiff to pay Php 10,000.00 as Moral Damages;

3. Ordering Plaintiff to pay the costs of this suit.

Defendant further prays for other reliefs and remedies just and
equitable under the premises.

Baguio City, Philippines, this 13th day of January 2014.

FERNANDO JOSE ALTAMIRANO DEL CASTILLO

206
VERIFICATION

I, MARI MAR P. ALDANA, of legal age, Filipino citizen, single, and a

MARI MAR P. ALDANA

Affiant
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 13th day of January 2014, by MARI MAR P. ALDANA, who is
personally known to me.

FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Copy Furnished:

JUAN DELA CRUZ JR.

Counsel for the Plaintiff
100A Session Road, Baguio City
207
MOTIONS
MOTION an application to the court requesting an order or rule in favor of
the applicant

Note: The body of a Motion usually has four parts:

1. Title
2. Ground for the Motion
3. Argument in Support of the Motion
4. Relief Sought to be obtained

208
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

QUAY SIGH DEVELOPERS, INC.,

Plaintiff,

-versus- Civil Case No.: 12001-R

FOR COLLECTION OF SUM OF
MONEY
ZACHARY ZEBEDEE Y. XAVIER,
Defendant.
x--------------------------------------------x

MOTION FOR BILL OF PARTICULARS

COMES NOW, the defendant, through the undersigned counsel in the

above-entitled case and unto this Honorable Court respectfully avers:

1. That the plaintiff's complaint in paragraph 5 alleges:

From August to December 2013, defendant never

paid anything to herein plaintiff. The check that she
issued as partial payment for the first month also
bounced. x x x (underscoring supplied)

2. The said allegation is not averred with sufficient definiteness and

particularity, specifically it does not mention the amount of the check
therein mentioned, its check number, date, and the drawee bank;

3. That a more definite statement on the matters as above-indicated is

necessary in order to enable the defendant to prepare his responsive
pleading because from the very onset of this controversy, the main
dispute was on what was actually and exactly agreed upon by the
parties as the amount of monthly rentals on the lease of plaintiff's
property;

4. However, due to the fact that defendant corporation had to transfer

its liaison offices depending on its project sites, the check stub where
the above-mentioned check came from was probably misplaced and
could no longer be found;
209
5. That a bill of particulars or a more definite statement as to the
particulars of the said check which was allegedly issued by the
defendants as partial payment for the first month would definitely
simplify the issues in this case, and hopefully clarify the negotiations
between the parties for an amicable settlement.

PRAYER

WHEREFORE, defendant most respectfully prays that an order be

issued by this Honorable Court requiring the plaintiff to make a more
definite statement as to the particulars of the check mentioned in
paragraph 5 of its complaint, particularly stating its amount, check number,
date, and the name of the drawee bank.

Baguio City, Philippines, this 13th day of January 2014.

ATTY. JUAN DE LA CRUZ JR.

Counsel for the Defendant
100A Session Road, Baguio City
(074) 422-1234
PTR No. 1928374/Baguio City/01-02-14
Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-90210/04-22-13

210
REQUEST FOR AND NOTICE OF HEARING

ATTY. JEAN F. VALJEAN

Branch Clerk of Court
Regional Trial Court
Branch 7, Baguio City

Please submit the foregoing Motion to the Court for its consideration
and approval immediately upon receipt thereof and kindly include the
same in the court’s calendar for hearing on 17 January 2014, at 8:30 in the
morning.

ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Plaintiff
45 Hotel, Leonard Wood Road, Baguio City

Please take notice that counsel has requested to be heard on 17

January 2014, at 8:30 in the morning.

ATTY. JUAN DE LA CRUZ JR.

Counsel for the Defendant

Copy Furnished:

ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Plaintiff
PTR No. 11123445:1-3-14:Baguio City
IBP No. 654123:1-3-14:Baguio City
Roll No. 56565:4-1-00:Manila
MCLE Compliance No. 67657:5-20-13:Manila
45 Hotel, Leonard Wood Road, Baguio City

211
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

YOLANDA X. WATERLOO,
Plaintiff,
-versus- Civil Case No.: 6633-R
FOR COLLECTION OF SUM OF
XAVIER W. VILLANUEVA, MONEY
Defendant.
x------------------------------------x

MOTION FOR JUDGMENT ON THE PLEADINGS

COMES NOW, the plaintiff, through the undersigned counsel in the

above-entitled case and unto this Honorable Court respectfully states:

1. That on December 27, 2013, plaintiff filed a complaint for collection

of sum of money in the amount of FIVE HUNDRED THOUSAND PESOS
(Php 500,000.00) against defendant;

2. That in his answer, the defendant admitted the obligation, but he

was asking for an extension of time to pay his obligation and instead
the herein complaint was filed;

3. That the said answer admits the material allegations of the complaint
has not tendered any issue and in view thereof, a judgment on the
pleadings can be rendered.

PRAYER

WHEREFORE, it is respectfully prayed of this Honorable Court to

render judgment on the pleadings.

Baguio City, Philippines, this 13th day of January 2014.

ATTY. JUAN DE LA CRUZ JR.

Counsel for the Plaintiff
100A Session Road, Baguio City
(074) 422-1234
PTR No. 1928374/Baguio City/01-02-14
Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-90210/04-22-13
212
REQUEST FOR AND NOTICE OF HEARING

ATTY. JEAN F. VALJEAN

Branch Clerk of Court
Regional Trial Court
Branch 7, Baguio City

ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Defendant
45 Hotel, Leonard Wood Road, Baguio City

Please take notice that counsel has requested to be heard on 17

January 2014, at 8:30 in the morning.

ATTY. JUAN DE LA CRUZ JR.

Counsel for the Plaintiff

Copy Furnished:

ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

213
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- Criminal Case No.: 4591-R

FOR UNJUST VEXATION

WARREN V. ULTRAMARINO,
Accused.
x-----------------------------------x

MOTION FOR POSTPONEMENT OF HEARING

COMES NOW, the undersigned counsel for the accused respectfully

prays for Postponement of Hearing in the above-entitled case and
respectfully manifests:

1. That counsel received the Notice of Hearing for Promulgation of

Decision dated 2 January 2014 on 6 January 2014;

2. That in the said Notice, the promulgation of the decision is set on 20

January 2014 at 9:00 o’clock in the morning;

a. That, unfortunately, counsel cannot appear on such date and

time as he had earlier committed himself to appear before the
Regional Trial Court, Branch X, La Trinidad, Benguet, in the
case People of the Philippines vs. Warlito U. Vicente, Crim. Case
No. 00004-S for Rape; hence, this motion;

3. That counsel will be available on 22 January 2014 at 9:00 o’clock in

the morning;

4. That this motion is not interposed to delay the proceedings of the

case but due solely for the reason aforecited and that counsel offers
his sincerest apology.

214
PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this

Honorable Court to grant this motion and that the scheduled hearing on 20
January 2014 be postponed to 22 January 2014 at 9:00 o’clock in the
morning.

A General Relief is likewise prayed for.

Baguio City, Philippines, this 13th day of January 2014.

ATTY. JUAN DE LA CRUZ JR.

Counsel for the Accused
100A Session Road, Baguio City
(074) 422-1234
PTR No. 1928374/Baguio City/01-02-14
Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-90210/04-22-13

215
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- Criminal Case No.: 8444-R

FOR FRUSTRATED HOMICIDE

VINCENT U. TRAJEDIA,
Accused.
x-------------------------------x

MOTION FOR RECONSIDERATION

COMES NOW, the undersigned counsel for the accused in the above-
entitled case and unto this Honorable Court most, respectfully states that:

1. He just received today a copy of an Order dated 10 January 2014

issued by this Honorable Court denying the Motion to Appeal as
Pauper Litigant filed by the accused on the ground that said Motion
failed to contain a notice of time and place of hearing;

2. The undersigned counsel sincerely apologizes for said defect as his

failure to state the aforementioned time and date of hearing of that
motion was purely due to an oversight;

3. Considering the seriousness of the case and the penalty imposed

upon the accused, the undersigned counsel in the interest of justice
most respectfully prays to the Honorable Court to reconsider and set
aside the said order and that the Motion to Appeal as Pauper Litigant
be heard, together with this Motion for Reconsideration, on 17
January 2014 at 8:00 o’clock in the morning.

216
PRAYER

WHEREFORE, premises considered, it is respectfully prayed to the

Honorable Court to reconsider and set aside the said order and that the
Motion to Appeal as Pauper Litigant be heard together with this motion for
Reconsideration.

Other reliefs and remedies just and equitable under the premises are
likewise prayed for.

Baguio City, Philippines, this 13th day of January 2014.

ATTY. JUAN DE LA CRUZ JR.

217
REQUEST FOR AND NOTICE OF HEARING

ATTY. JEAN F. VALJEAN

Branch Clerk of Court
Regional Trial Court
Branch 7, Baguio City

PROS. JOSE FERNANDO V. ALONZO

Office of the City Prosecutor
Justice Hall, Baguio City

Please take notice that counsel has requested to be heard on 17

January 2014, at 8:30 in the morning.

ATTY. JUAN DE LA CRUZ JR.

Counsel for the Accused

Copy Furnished:

PROS. JOSE FERNANDO V. ALONZO

Office of the City Prosecutor
Justice Hall, Baguio City

218
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff,
Criminal Case No.: 1234-R
-versus- FOR RECKLESS IMPRUDENCE
RESULTING IN DAMAGE
TO PROPERTY
THEODORE S. RESTITUTO,
Accused.
x---------------------------------x

MOTION FOR REDUCTION OF BAIL

COMES NOW, the accused through the undersigned counsel in the

above-entitled case, and to this Honorable Court respectfully states:

1. That the accused is charged with RECKLESS IMPRUDENCE RESULTING

IN DAMAGE TO PROPERTY now pending before this Honorable Court
with Criminal Case No. 1234-R;

2. That the recommended bond for his provisional liberty is in the

amount of FIFTY THOUSAND PESOS (Php 50,000.00);

3. That accused, considering that he is at this time suffering from

financial constraints, can only produce the amount of THIRTY
THOUSAND PESOS (Php 30,000.00) CASH;

4. That accused needs his temporary liberty in order for him to gather
all the necessary evidence for his proper defense from this baseless
accusation which he cannot do if inside prison;

5. That the accused together with his family is a permanent resident of

86 Amistad Camp 7, Baguio City and therefore the possibility for him
to jump bail is nil;

6. That the accused promises to attend all scheduled hearings in the

above entitled case and obey all processes of this Honorable Court.
219
PRAYER

WHEREFORE, premises considered and in view of the foregoing, it is

respectfully prayed to the Honorable Court that the recommended bond of
Php 50,000.00 be reduced to Php 30,000.00.

Other reliefs and remedies just and equitable under the premises are
likewise prayed for.

Baguio City, Philippines, this 13th day of January 2014.

ATTY. JUAN DE LA CRUZ JR.

220
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

SIEGFRIED R. QUIRINO,
Plaintiff,
-versus- Civil Case No.: 6234-R
FOR COLLECTION OF SUM OF
ROBERT Q. PRIMAVERA, MONEY
Defendant.
x-------------------------------------x

MOTION TO DECLARE DEFENDANT IN DEFAULT

COMES NOW, the plaintiff, through the undersigned counsel in the

above-entitled case and unto this Honorable Court respectfully states that:

1. The records of the Honorable Court show that Defendant was served
with copy of the summons and of the complaint, together with
annexes thereto on 27 December 2013;

2. Upon verification however, the records show that Defendant FAILED

TO FILE HIS ANSWER WITHIN THE REGLEMENTARY PERIOD specified
in the Rules of Court despite the service of summons and complaint;

3. As such, it is prayed that Defendant be declared in default.

WHEREFORE, it is respectfully prayed that Defendant be declared in

default pursuant to the Rules of Court and that the Honorable Court
proceed to render judgment as the complaint may warrant.

Baguio City, Philippines, this 13th day of January 2014.

ATTY. JUAN DE LA CRUZ JR.

Counsel for the Plaintiff
100A Session Road, Baguio City
(074) 422-1234
PTR No. 1928374/Baguio City/01-02-14
221
Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-90210/04-22-13
REQUEST FOR AND NOTICE OF HEARING

ATTY. JEAN F. VALJEAN

Branch Clerk of Court
Regional Trial Court
Branch 7, Baguio City

ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Defendant
45 Hotel, Leonard Wood Road, Baguio City

Please take notice that counsel has requested to be heard on 17

January 2014, at 8:30 in the morning.

ATTY. JUAN DE LA CRUZ JR.

Counsel for the Plaintiff

Copy Furnished:

ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

222
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

QUEEN PRICILLA O. NERI,

Plaintiff,
-versus- Civil Case No.: 92081-R
FOR DAMAGES
PERCIVAL O. NONATUS,
Defendant.
x---------------------------------x

MOTION FOR EXTENSION OF TIME

COMES NOW, the plaintiff, through the undersigned counsel in the

above-entitled case and unto this Honorable Court respectfully states that:

1. He has been required to file a Reply to defendant’s Answer on 20

January 2014;

2. The undersigned counsel, however, anticipates his inability to file the

Reply on or before said due date because of the tremendous
pressure of other equally urgent professional work requiring the
preparation of pleadings and almost daily trial appearances before
the various courts within and outside Baguio City. For this reason, the
undersigned is constrained to ask for an additional fifteen (15) days
from 20 January 2014 within which to submit the plaintiff’s Reply;

3. This motion is not intended for delay but is motivated only by the
foregoing reason.

WHEREFORE, plaintiff respectfully prays that she be granted fifteen

(15) days from 20 January 2014 to submit plaintiff’s Reply.

Baguio City, Philippines, this 13th day of January 2014.

ATTY. JUAN DE LA CRUZ JR.

Counsel for the Plaintiff
100A Session Road, Baguio City
(074) 422-1234
223
PTR No. 1928374/Baguio City/01-02-14
Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-90210/04-22-13

224
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

NATHANIEL M. LEICHTENSTEIN,
Plaintiff,
-versus- Civil Case No.: 8809-R
FOR COLLECTION OF SUM OF
MICHAELLOUS L. KRIEG, MONEY WITH DAMAGES
Defendant.
x------------------------------------x

MOTION FOR EXECUTION OF JUDGMENT

COMES NOW, the plaintiff, through the undersigned counsel in the

above-entitled case and unto this Honorable Court, states:

1. That a decision has been rendered in this case on 27 December 2013

in favor of the Plaintiffs and against the Defendants;

2. That the period for appeal has already expired without the
defendants having perfected an appeal from said decision;

3. That the said decision is now final and executory.

WHEREFORE, it is respectfully prayed that an order of execution of

the decision be issued.

Baguio City, Philippines, this 13th day of January 2014.

ATTY. JUAN DE LA CRUZ JR.

226
REQUEST FOR AND NOTICE OF HEARING

ATTY. JEAN F. VALJEAN

Branch Clerk of Court
Regional Trial Court
Branch 7, Baguio City

ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Defendant
45 Hotel, Leonard Wood Road, Baguio City

Please take notice that counsel has requested to be heard on 17

January 2014, at 8:30 in the morning.

ATTY. JUAN DE LA CRUZ JR.

Counsel for the Plaintiff

Copy Furnished:

ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

227
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- Criminal Case No.: 7777-R

FOR OTHER DECEITS
(ARTICLE 318 OF THE
LORENZO K. JEREMIAS, REVISED PENAL CODE)
Accused.
x-------------------------------x

MOTION FOR RE-INVESTIGATION

COMES NOW, the private complainant, through the undersigned

Private Prosecutor and under the direct control and supervision of the
Public Prosecutor, and unto this Honorable Court, most respectfully state:

1. That in an Information filed by the Office of the Prosecutor dated 31

December 2013, the Accused was charged for ESTAFA under other
deceits of Article 318 of the Revised Penal Code based on the
Complaint filed by the Private Complainant, LUIGI K. JARO;

2. That the basis of the Honorable Public Prosecutor in charging the

Accused with Estafa is the provision on other deceits under Article
318 of the Revised Penal Code stating among others that, “the
respondent or even his corporation do not actually own the lot sold to
the Private Complainant, the respondent must be held liable under
Article 318 of the Revised Penal Code”.

3. That the Accused should have been charged for ESTAFA under
ARTICLE 315 Paragraph 2a of the Revised Penal Code, and not under
Article 318, which provides that, ESTAFA could be committed by
means of false pretenses or fraudulent acts executed prior to or
simultaneously with commission of the fraud by using a fictitious
name, or falsely pretending to possess power, influence,
228
qualifications, PROPERTY, credit, agency, business transactions; or by
means of other similar deceits;

4. That the Affidavit Complaint of the Private Complainant stated

therein that the Accused obtained money from the Private
Complainant in the amount of FOUR HUNDRED THOUSAND PESOS
(PHP 400,000.00) to be used to build a house over a property which
the Accused offered to the Private Complainant. It turned out
however that the land was not the property of LORENZO K. JEREMIAS
or in the name of his corporation. With all the representations and
false pretenses made by the Accused that he owned a property and
assuming the obligation to build a house thereon but subsequently
no property or building was erected, shows that indeed the Accused
only deceived the Private Complainant to obtain his money;

5. That the act of the Accused in misrepresenting that he is the owner

of a lot being the subject of a house and lot package to obtain money
from the Private Complainant and misappropriating the same
constitutes the crime of ESTAFA under ARTICLE 315 Paragraph 2a of
the Revised Penal Code;

6. That the Private Complainant, LUIGI K. JARO, respectfully requests

that a RE-INVESTIGATION be conducted on the above-entitled case
to resolve whether or not the case falls within the ambit of ARTICLE
315 Paragraph 2a constituting the crime of ESTAFA by falsely
pretending to possess property and not ARTICLE 318 of the Revised
Penal Code;

7. That this Motion is not in any manner intended to cause delay in the
speedy disposition of this instant case or to frustrate the ends of
justice.

229
PRAYER

WHEREFORE, premises duly considered, it is most respectfully prayed

of the Honorable Court to GRANT this Motion for RE-INVESTIGATION and to
issue an Order for the RE-INVESTIGATION of the above-entitled case.

Such other relief as law and justice may warrant are likewise prayed
for.

Baguio City, Philippines, this 13th day of January 2014.

ATTY. JUAN DE LA CRUZ JR.

Private Prosecutor
100A Session Road, Baguio City
(074) 422-1234
PTR No. 1928374/Baguio City/01-02-14
Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-90210/04-22-13

With my conformity:

JOSE FERNANDO V. ALONZO

Public Prosecutor

230
REQUEST FOR AND NOTICE OF HEARING

ATTY. JEAN F. VALJEAN

Branch Clerk of Court
Regional Trial Court
Branch 7, Baguio City

PROS. JOSE FERNANDO V. ALONZO

Office of the City Prosecutor
Justice Hall, Baguio City

ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Accused
45 Hotel, Leonard Wood Road, Baguio City

Please take notice that counsel has requested to be heard on 17

January 2014, at 8:30 in the morning.

ATTY. JUAN DE LA CRUZ JR.

Private Prosecutor

Copy Furnished:

PROS. JOSE FERNANDO V. ALONZO

Office of the City Prosecutor
Justice Hall, Baguio City

ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Accused
PTR No. 11123445:1-3-14:Baguio City
IBP No. 654123:1-3-14:Baguio City
Roll No. 56565:4-1-00:Manila
MCLE Compliance No. 67657:5-20-13:Manila
231
45 Hotel, Leonard Wood Road, Baguio City
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff,
-versus- Criminal Case No.: 22349-R
FOR KIDNAPPING WITH
KRISTOFF J. INOCENCIO, MURDER
Accused.
x-----------------------------------------x

MOTION FOR JUDICIAL DETERMINATION OF PROBABLE CAUSE

COMES NOW, the undersigned private prosecutor most respectfully moves

that this Honorable Court conduct a determination of probable cause pursuant to
Article III, Section 2 of the 1987 Constitution and in support thereof state the
following:

1. The accused KRISTOFF J. INOCENCIO was charged with Kidnapping with

Murder by private complainant KRIS J. INNUIT in his Affidavit-Complaint,
herein attached as “Exhibit A,” filed before the Baguio City Office of the
Prosecutor on 8 January 2013;

2. In a resolution dated 10 January 2014 by the undersigned investigating

prosecutor, herein attached as “Exhibit B,” probable cause that the crime
was committed by the accused was found to exist.

WHEREFORE, it is respectfully prayed that probable cause be judicially

determined and for this Honorable Court to issue warrant of arrest against the
accused KRISTOFF J. INOCENCIO.

Baguio City, Philippines, this 13th day of January 2014.

ATTY. JUAN DE LA CRUZ JR.

With my conformity:

232
JOSE FERNANDO V. ALONZO
Public Prosecutor
REQUEST FOR AND NOTICE OF HEARING

ATTY. JEAN F. VALJEAN

Branch Clerk of Court
Regional Trial Court
Branch 7, Baguio City

PROS. JOSE FERNANDO V. ALONZO

Office of the City Prosecutor
Justice Hall, Baguio City

ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Accused
45 Hotel, Leonard Wood Road, Baguio City

Please take notice that counsel has requested to be heard on 17

January 2014, at 8:30 in the morning.

ATTY. JUAN DE LA CRUZ JR.

Private Prosecutor

Copy Furnished:

PROS. JOSE FERNANDO V. ALONZO

Office of the City Prosecutor
Justice Hall, Baguio City

ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Accused
PTR No. 11123445:1-3-14:Baguio City
IBP No. 654123:1-3-14:Baguio City
Roll No. 56565:4-1-00:Manila
233
MCLE Compliance No. 67657:5-20-13:Manila
45 Hotel, Leonard Wood Road, Baguio City
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- Criminal Case No.: 22349-R

FOR THEFT
JOHN IVAN JOHANESS H. GUINTO,
Accused.
x------------------------------------------x

MOTION TO QUASH

The Accused, by counsel and unto this Honorable Court, respectfully

moves to quash the Information filed against him for the crime of Theft on
the following grounds:

1. IT CONTAINS AVERMENTS WHICH, IF TRUE, WOULD CONSTITUTE A

LEGAL JUSTIFICATION;

2. THIS COURT IS WITHOUT JURISDICTION.

In support, the Accused respectfully states that:

The Information alleges that the Accused JOHN IVAN JOHANESS H.

GUINTO is eleven (11) years old and without any known address. Under
Article 12, paragraph 3 of the Revised Penal Code, a person over nine years
of age and under fifteen, unless he acted with discernment, is exempt from
criminal liability.

There is no allegation that the accused acted with discernment. Even

granting that said discernment was present, the Accused cannot be tried
but instead should be proceeded against pursuant to Article 80 of the
Revised Penal Code, which provides that a minor, unless sixteen years of
234
age at the time of a grave or less grave felony, cannot be tries but instead
shall have the benefit of a suspension of all proceedings against him. The
duty of the court would be to commit the minor to the custody or care of a
public or private benevolent or charitable institution for the care and
education of the homeless and delinquent children or to the custody of the
Department of Social Welfare and Development.

WHEREFORE, it is respectfully prayed that the Information against

the Accused be QUASHED and that the Accused be released immediately
from detention.

Baguio City, Philippines, this 13th day of January 2014.

ATTY. JUAN DE LA CRUZ JR.

235
REQUEST FOR AND NOTICE OF HEARING

ATTY. JEAN F. VALJEAN

Branch Clerk of Court
Regional Trial Court
Branch 7, Baguio City

PROS. JOSE FERNANDO V. ALONZO

Office of the City Prosecutor
Justice Hall, Baguio City

Please take notice that counsel has requested to be heard on 17

January 2014, at 8:30 in the morning.

ATTY. JUAN DE LA CRUZ JR.

Counsel for the Accused

Copy Furnished:

PROS. JOSE FERNANDO V. ALONZO

Office of the City Prosecutor
Justice Hall, Baguio City

236
NOTICES
NOTICE "information concerning a fact, actually communicated to a person
by an authorized person, or actually derived by him from a proper source."

237
DEMAND LETTER

17 January 2014

MARI MAR P. ALDAMA,

1 Cabinet Hill
Baguio City

Dear Ms. Aldana:

I write in behalf of Mrs. Angelica Y. Santibanyez of 8 Orchard Street, Brent

Townhomes, Baguio City.

It is recommended that you act on this matter immediately to avoid the

embarrassment and rigors of court litigation.

Thank you.

Very truly yours,

ATTY. JUAN DE LA CRUZ JR.

Counsel for Mrs. Santibanyez

238
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------ x

NOTICE OF ADVERSE CLAIM

THE REGISTER OF DEEDS

La Trinidad, Benguet

Sir:

I, CAESAR D. ELAYA, of legal age, Filipino citizen, single, and residing

at 14 Aurora Hill, Baguio City, Philippines, after having been duly sworn in
accordance with law, do hereby depose and say:

1. That I have an adverse claim in that certain registered real property,

covered by TCT No. T-04522 of the Registry of Deeds of the Province
of Benguet, particularly described as follows:

“A parcel of land situated at Alno, La Trinidad,

Benguet, bounded by the North by Lot No. 555, on the
East by the national road; on the South by Lot No. 566
and 564 and on the West by Lot No. 5464, containing
an area of four hundred sixteen (416) square meters,
more or less.”

2. That I bought said land from Mr. CAMILO D. ENTREGA, but since I
was a minor at the time of the purchase, I requested Mr. CENON D.
EUSTAQUIO, my uncle, to register the same in the his name for my
benefit and to be held in trust for me. My uncle agreed and so the
land was registered in his name.

3. That I am the real and actual owner of said property, and not the
registered owner thereof, and to protect my interest thereto as
actual owner, this adverse claim is being registered on said TCT, to
warn any third person from buying the same.

WHEREFORE, I hereby request the Register of Deeds of Benguet

Province to register this adverse claim in the manner provided by law.

CAESAR D. ELAYA
Affiant
239
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 17th day of January 2014, by affiant, personally known to
me, who is the same person who personally signed before me the
foregoing instrument.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
PTR No. 1928374/Baguio City/01-03-14
Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-03-14
MCLE Compliance No. IV-90210/04-22-13
Commission Serial No. 01-NC-11 (R)

Doc. No. 71;

Page No. 15;
Book No. I;
Series of 2014

240
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

NATIONAL POWER CORPORATION,

Plaintiff,
-versus- Civil Case No.: 6463-R
FOR EXPROPRIATION
DENNIS E. FERNGULLY,
Defendant.
x------------------------------------x

NOTICE OF COMMISSIONERS’ REPORT

ATTY. JUAN DE LA CRUZ JR.

Counsel for the Defendant
100A Session Road, Baguio City

Atty. DE LA CRUZ:

This is to notify the parties that pursuant to Republic Act No. 8974,
the Commissioners have submitted to the Court their report with
recommendations to determine just compensation after viewing and
examining the property owned by defendant Mr. DENNIS E. FERNGULLY
subject to expropriation proceedings initiated by plaintiff NATIONAL
POWER CORPORATION.

This is also to further notify the parties that the hearing for the Court
to consider the approval of the report will be on 3 February 2014 at 8:30 in
the morning.

Baguio City, Philippines, this 17th day of January 2014.

ATTY. JEAN F. VALJEAN

Branch Clerk of Court
Regional Trial Court
Branch 7, Baguio City
241
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

ESPERANZA F. GUINTO,
Plaintiff,

-versus- Civil Case No.: 6903-R

FOR DAMAGES

FRANCIS G. HARTMAN,
Defendant.
x------------------------------------x

NOTICE OF DEATH OF PARTY

This is to inform the death of ESPERANZA F. GUINTO, the plaintiff in

this case. The fact of death is evidenced by a Certificate of Death issued by
the Local Civil Register of Baguio City attached hereto as Annex “A”.

Baguio City, Philippines, this 17th day of January 2014.

ATTY. JUAN DE LA CRUZ JR.

Copy furnished:

ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

242
Counsel for the Defendant
45 Hotel, Leonard Wood Road, Baguio City
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

GERALD H. INTRIGUERA,
Plaintiff,

-versus- Civil Case No.: 6323-R

FOR DAMAGES

HAROLD I. JAMICHIA,
Defendant.
x------------------------------------x

NOTICE OF HEARING

ATTY. JUAN DE LA CRUZ JR.

Counsel for the Defendant
100A Session Road, Baguio City

Atty. DE LA CRUZ:

This is to notify the parties that the above-captioned case is set for
hearing on 27 January 2014 at 8:30 in the morning.

Baguio City, Philippines, this 17th day of January 2014.

ATTY. JEAN F. VALJEAN

Branch Clerk of Court
Regional Trial Court
Branch 7, Baguio City

243
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- Criminal Case No.: 6843-R

FOR COUP D’ETAT

HIRAM I. JANDUSAY, et al.,

Accused.
x---------------------------------x

NOTICE OF HEARING

ATTY. JUAN DE LA CRUZ JR.

Counsel for the Accused
100A Session Road, Baguio City

Atty. DE LA CRUZ:

This is to notify the parties that the above-captioned case is set for
hearing on 27 January 2014 at 8:30 in the morning.

Baguio City, Philippines, this 17th day of January 2014.

ATTY. JEAN F. VALJEAN

Branch Clerk of Court
Regional Trial Court
Branch 7, Baguio City

244
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

ISIDORE J. KRISTIPULO,
Plaintiff,
-versus- Civil Case No.: 6283-R
FOR RECONVEYANCE
JEDIDIAH K. LEICESTERSHIRE,
Defendant.
x------------------------------------x

NOTICE OF LIS PENDENS

THE REGISTER OF DEEDS

Baguio City

Sir:

Please take notice that a parcel of land covered by TCT. No 3322

located in Cabinet Hill, Baguio City, registered in the name of defendant is
the subject matter of an action for reconveyance of an undivided one-sixth
portion thereof filed by ISIDORE J. KRISTIPULO, above-named plaintiff.
Accordingly, please make the corresponding entries in the books of your
registry in the manner provided by law.

Baguio City, Philippines, this 17th day of January 2014.

ATTY. JUAN DE LA CRUZ JR.

245
Copy furnished:

ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Defendant
45 Hotel, Leonard Wood Road, Baguio City
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

ANTHONY B. CANDALEON,
Plaintiff,
-versus- Civil Case No.: 6633-R
FOR COLLECTION OF SUM OF
BARTHOLOMEW C. DESTRIBO, MONEY
Defendant.
x------------------------------------x

NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION

ATTY. JUAN DE LA CRUZ JR.

Counsel for the Defendant
100A Session Road, Baguio City

Atty. DE LA CRUZ:

This is to notify the parties that pursuant to Rule 23 of the Revised

Rules of Civil Procedure, the testimony, upon oral examination of ANNE B.
CASTILLE, whose address is at 88 Rufino Towers, Makati City, Philippines, as
a witness, will be taken on February 5, 2014 at 2:00 in the afternoon before
the Honorable Court, or before the Clerk of Court of Branch 7. The
circumstances of this deposition as provided in the motion are as follows:

1. The witness’s testimony will corroborate certain portions of the

testimony of the plaintiff, especially as to the fact that the defendant
defaulted in paying his obligation to plaintiff;

2. In view of the fact that she resides at a city more than 100 kilometers
away from Baguio City, the deposition will be taken.

Baguio City, Philippines, this 13th day of January 2014.

246
ATTY. JEAN F. VALJEAN
Branch Clerk of Court
Regional Trial Court
Branch 7, Baguio City
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

KRISTOFF L. NIECEANISTICO,
Plaintiff,
-versus- Civil Case No.: 6633-R
FOR ANNULMENT OF
LAROUSSE M. NIECEANISTICO, MARRIAGE
Defendant.
x------------------------------------x

NOTICE TO TAKE DEPOSITION

UPON WRITTEN INTERROGATORIES

ATTY. JUAN DE LA CRUZ JR.

Counsel for the Defendant
100A Session Road, Baguio City

Atty. DE LA CRUZ:

This is to notify the parties that pursuant to Rule 23 of the Revised

Rules of Civil Procedure, the testimony, upon written interrogatories of
NIGELLA M. LANDER, whose address is at 23 Quezon Avenue, Quezon City,
Philippines, as a witness, will be taken on February 5, 2014 at 9:00 in the
morning before the Clerk of Court of Branch 7. The circumstances of this
deposition as are provided in the motion are as follows:

1. The witness’s testimony will corroborate certain portions of the

testimony of the plaintiff, especially as to the fact that the plaintiff
and the defendant have not lived together as husband and wife and
that the plaintiff and the defendant each manifest certain traits and
behavior patterns that are indicative of their respective inabilities to
perform their marital obligations towards each other;

2. In view of the fact that she resides at a city more than 100 kilometers
away from Baguio City, the deposition will be taken.

247
Baguio City, Philippines, this 13th day of January 2014.

ATTY. JEAN F. VALJEAN

Branch Clerk of Court
Regional Trial Court
Branch 7, Baguio City

PLEADINGS

248
COMPLAINT is a sworn written statement charging a person with an
offense, subscribed by the offended party, any peace officer or other public
officer charged with the enforcement of the law violated (Rule 110, Section
3, ROC).

ESSENTIAL PARTS OF A COMPLAINT

1. Caption
2. Heading
3. Opening Sentence
4. Body alleging facts or omissions constituting a crime
5. Contrary to Law
6. Oath of Complainant with his/her signature
7. Certification of the Prosecutor
8. Jurat

DIRECT FILING OF COMPLAINT

1. Caption
2. Heading
3. Opening Sentence
4. Body alleging facts or omissions constituting the crime
5. Signature
6. Jurat

PETITION is a formal written request or prayer for a certain thing to be

done. It connotes an application in writing addressed to a court or judge,
stating facts and circumstances relied upon as a cause for judicial action,
and containing a prayer for relief.

PLEADINGS statements, in logical and legal form, of the facts that

constitute plaintiff's cause of action and defendant's ground of defense.
They are either allegations by the parties affirming or denying certain
matters of fact, or other statements by them in support of derogation of
certain principles of law, which are intended to have the effect of disclosing
to the court the real matter in dispute.

249
MISCELLANEOUS PLEADINGS these are the documents attached to the main
pleadings, or being issued as another independent pleading other than the
compliant or answer.

Republic of the Philippines

FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

ALFRED B. CERAFINO,
Plaintiff,
-versus- Civil Case No.: 6897-R
FOR DAMAGES
BILLY C. DOMETILLA,
Defendant.
x------------------------------------x

APPEARANCE AS COUNSEL

ATTY. JEAN F. VALJEAN

Branch Clerk of Court
Regional Trial Court
Branch 7, Baguio City

ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Plaintiff
45 Hotel, Leonard Wood Road, Baguio City

Please enter the appearance of the undersigned as counsel for the

defendant in the above titled case for all legal purposes.

Baguio City, Philippines, this 30th day of January 2014.

ATTY. JUAN DE LA CRUZ JR.

Copy furnished:

ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Plaintiff
45 Hotel, Leonard Wood Road, Baguio City

Republic of the Philippines

FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

CARLO D. ERENDIL,
Plaintiff,
-versus- Civil Case No.: 4977-R
FOR DAMAGES
DARYLL E. FARFETCHER,
Defendant.
x------------------------------------x

WITHDRAWAL AS COUNSEL WITH SUBSTITUTION

ATTY. JEAN F. VALJEAN

Branch Clerk of Court
Regional Trial Court
Branch 7, Baguio City

ATTY. FERNANDO JOSE A. DEL CASTILLO

Counsel for the Defendant
45 Hotel, Leonard Wood Road, Baguio City

Please make of record the WITHDRAWAL of the undersigned ATTY.

JUAN DE LA CRUZ JR. and the SUBSTITUTION of the undersigned ATTY.
MARIUS F. PONTMERCI as counsel for plaintiff CARLO D. ERENDIL with his
express conformity as indicated below. Henceforth kindly address all
pertinent notices to ATTY. MARIUS F. PONTMERCI at his address below.

Baguio City, Philippines, this 30th day of January 2014.

ATTY. JUAN DE LA CRUZ JR. ATTY. MARIUS F. PONTMERCI

100A Session Road, Baguio City 3F La Azotea Bldg., Session Road, Baguio City
(074) 422-1234 (074) 422-0987

251
PTR No. 1928374/Baguio City/01-02-14 PTR No. 1999910/Baguio City/01-02-14
Roll of Atty. No. 67548/05-18-10 Roll of Atty. No. 81319/05-05-13
IBP OR No. 739281/Baguio-Benguet/01-02-14 IBP OR No. 692876/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-90210/04-22-13 MCLE Compliance No. IV-99080/04-22-13

With Conformity: Copy Furnished:

CARLO D. ERENDIL ATTY. FERNANDO JOSE A. DEL CASTILLO

Plaintiff Counsel for the Defendant
45 Hotel, Leonard Wood Road, Baguio City

Republic of the Philippines

FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

EUGENE F. GARFINKLE,
Petitioner,
-versus- Civil Case No.: _____
FOR RESCISSION OF CONTRACT
FERDIE G. HOLLANDE, WITH DAMAGES
Respondent.
x--------------------------------------x

PETITION

COMES NOW, the petitioner, through the undersigned counsel and

unto this Honorable Court, most respectfully states:

1. That petitioner is Filipino, of legal age, and a resident of 98 Gibraltar,

Baguio City where he may be served with summons and other court
processes, while respondent is Filipino, of legal age, a friend of
petitioner, and a resident of 99 Quirino Hill, Baguio City where she
may be served with summons and other court processes;

2. That on April 1, 2013, petitioner bought from respondent the

former’s TOYOTA FORTUNER, described in attached document
ANNEX 1 and to be delivered on May 1, 2013, for ONE MILLION
PESOS (P 1,000,000.00) payable on ten equal monthly installments
up to February 1, 2014. Said sale was evidenced by a Contract of Sale
herein attached as ANNEX 2;

3. That petitioner had already paid nine monthly installments totaling

to NINE HUNDRED THOUSAND PESOS (P 900,000.00) as of January 1,
2014;

252
4. That three (3) days after latest payment, petitioner learned that
respondent already transferred said property to FRANCO G.
HERMANO, his alleged lover, through a Deed of Donation executed
on December 25, 2013 without reserving any sufficient property to
answer for his obligation and in fraud of petitioner pursuant to
ARTICLE 1387 of the CIVIL CODE OF THE PHILIPPINES;

5. That due to said fraud, petitioner was deprived of NINE HUNDRED

THOUSAND PESOS (P 900,000.00) and suffered damages;

6. That there are no other legal means to obtain reparation for such
damages sustained, so petitioner was constrained to file the instant
petition engaging him to pay FIFTY THOUSAND PESOS (P50,000.00)
for legal services; and

7. That this action for rescission with damages was commenced within
the four (4) year period allowed under ARTICLE 1389 of the CIVIL
CODE OF THE PHILIPPINES.

WHEREFORE, petitioner respectfully prays that judgment be

rendered in his favor:

1. RESCINDING the Deed of Donation dated December 25, 2013;

2. ORDERING respondent to pay ONE HUNDRED THOUSAND PESOS

(P100,000.00) as NOMINAL DAMAGES; and

3. ORDERING respondent to pay FIFTY THOUSAND PESOS (P50,000.00)

as Attorney’s Fees.

Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 30th day of January 2014.

ATTY. MARIUS F. PONTMERCI

Counsel for the Petitioner
3F La Azotea Bldg., Session Road, Baguio City
(074) 422-0987
PTR No. 1999910/Baguio City/01-02-14
Roll of Atty. No. 81319/05-05-13
IBP OR No. 692876/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-99080/04-22-13
253
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, EUGENE F. GARFINKLE, of legal age, single, Filipino citizen, and a

resident of 98 Gibraltar, Baguio City, Philippines after having been duly sworn in
accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing petition;

3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and on the basis of copies of documents
and records in my possession;

4. I have not commenced any other action or proceeding involving the same
issues in the Supreme Court, the Court of Appeals, or any other tribunal or
agency; that to the best of my knowledge and belief, no such action or
proceeding is pending in the Supreme Court, the Court of Appeals, or any
other tribunal or agency; and if I should thereafter learn that a similar
action or proceeding has been filed or is pending before the Supreme
Court, the Court of Appeals, or any other tribunal or agency, I undertake to
report that fact within five (5) days therefrom to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto set my hand this 30th day of

January 2014, at Baguio City, Philippines.

EUGENE F. GARFINKLE
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines,

th
this 30 day of January 2014, by EUGENE F. GARFINKLE, who is personally known

254
to me, who is the same person who personally signed before me the foregoing
document.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
PTR No. 1928374/Baguio City/01-04-13
Roll of Atty. No. 67548/05-18-10
Doc. No. 72; IBP OR No. 739281/Baguio-Benguet/01-04-13
Page No. 15; MCLE Compliance No. IV-90210/04-22-13
Book No. I; Commission Serial No. 01-NC-11 (R)
Series of 2014
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

GIACOMMO H. INTELLIGGIO,
Petitioner,
-versus- Civil Case No.: _____
FOR JUDICIAL PARTITION
GIANCARLO H. INTELLIGGIO,
Respondent.
x--------------------------------------x

PETITION

COMES NOW, the petitioner, through the undersigned counsel, and

unto this Honorable Court, most respectfully states that:

1. Petitioner is a Filipino citizen, of legal age, single, and resident of 23

Breeze Homes, Pias Road, Camp 7, Baguio City where he may be
served with summons and other court processes;

2. Respondent is a Filipino citizen, of legal age, single, and resident of

55 Tarbora, Trancoville, Baguio City where he may be served with
summons and other court processes;

3. Petitioner and respondent are the legitimate children and sole heirs
of their deceased father GIANNINNI J. INTELLIGGIO who died
intestate on December 30, 2013, as evidenced by his death
certificate herein attached as ANNEX 1;

4. Deceased left an intestate estate consisting of:

255
a. One (1) parcel of land located at Crystal Cave, Baguio City,
covering 750 square meters, more particularly described by
Transfer Certificate of Title No. 9238 herein attached as ANNEX 2,
and

b. Six (6) parcel of lands located at Woodsgate, Camp 7, Baguio City,

covering a total of 1,500 sq. m. and more particularly described in
Transfer Certificate of Title No. 3333-B herein attached as ANNEX
3;

5. Deceased left no indebtedness or obligations chargeable against his

intestate estate;

6. Petitioner and respondent, however, failed to agree on project

partition of said parcel of land, leading petitioner to institute this
ordinary action for partition pursuant to SECTION 1, RULE 74 of the
RULES OF COURT and thereby committing him to pay FIFTEEN
THOUSAND PESOS (P 15,000.00) for legal services.

WHEREFORE, petitioner respectfully prays that judgment be

rendered in his favor:

1. ORDERING the partition and segregation of ONE-HALF (1/2) portion

belonging to petitioner of the parcel of land described in paragraph
4(a) hereof;

2. ORDERING the partition and segregation of the ONE-HALF (1/2)

portion belonging to petitioner of the six (6) parcels of land described
in paragraph 4(b) hereof;

3. ORDERING respondent to pay petitioner FIFTEEN THOUSAND PESOS

(P 15,000.00) as Attorney’s Fees; and

4. ORDERING such other reliefs as this court may deem just and
equitable under the circumstances.

Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 30th day of January 2014.

ATTY. MARIUS F. PONTMERCI

Counsel for the Petitioner
256
3F La Azotea Bldg., Session Road, Baguio City
(074) 422-0987
PTR No. 1999910/Baguio City/01-02-14
Roll of Atty. No. 81319/05-05-13
IBP OR No. 692876/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-99080/04-22-13

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, GIACOMMO H. INTELLIGGIO, of legal age, single, Filipino citizen, and a

resident of 23 Breeze Homes, Pias Road, Camp 7, Baguio City, Philippines after
having been duly sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing petition;

3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and on the basis of copies of documents
and records in my possession;

IN WITNESS WHEREOF, I have hereunto set my hand this 30th day of

January 2014, at Baguio City, Philippines.

GIACOMMO H. INTELLIGGIO
Affiant

257
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines,
this 30th day of January 2014, by GIACOMMO H. INTELLIGGIO, who is personally
known to me, who is the same person who personally signed before me the
foregoing document.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
PTR No. 1928374/Baguio City/01-04-13
Roll of Atty. No. 67548/05-18-10
Doc. No. 73; IBP OR No. 739281/Baguio-Benguet/01-04-13
Page No. 15; MCLE Compliance No. IV-90210/04-22-13
Book No. I; Commission Serial No. 01-NC-11 (R)
Series of 2014
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

HARRY I. JANUARIO,
Plaintiff,
-versus- Civil Case No.: _____
FOR COLLECTION OF SUM OF
IRANIER J. KAZAKHLONF, MONEY
Defendant.
x------------------------------------x

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and

unto this Honorable Court, most respectfully states that:

1. Plaintiff is a Filipino citizen, of legal age, and a resident of 67 Green

Valley Subdivision, Baguio City where he may be served with
summons and other processes;

2. Defendant is also a Filipino, of legal age, and a resident of 12 Camp

Allen, Baguio City where he may be served with summons and other
processes;

3. On January 8, 2013 and over a period of six (6) months, defendant

borrowed certain amounts from plaintiff totaling to NINE HUNDRED
THOUSAND PESOS (P 900,000.00), and promised to pay these
amounts on or before November 28, 2013 as evidenced by three (3)
promissory notes herein attached as ANNEXES A, B, and C.
258
4. When the due date arrived and despite repeated demands
thereafter, both oral and written, defendant failed or refused to pay
said amount;

5. Resort to Barangay Conciliation process proved futile as defendant

failed to appear despite being duly notified. Thus, a Certification to
File Action, a copy of which is attached as ANNEX D, was issued by
the Barangay Chairperson;

6. Defendant’s obligation is due and demandable, and plaintiff is

entitled to the payment of the entire amount of Nine Hundred
Thousand Pesos (P 900,000.00);

7. By reason of defendant’s unreasonable failure or refusal to pay his

due and demandable obligation, plaintiff was forced to engage the
services of a counsel to vindicate his rights committing himself to pay
legal services amounting to Fifty Thousand Pesos (P 50,000.00).

WHEREFORE, plaintiff respectfully prays that judgment be rendered

in his favor directing defendant to pay him NINE HUNDRED THOUSAND
PESOS (P 900,000.00) plus legal interest as actual damages, and FIFTY
THOUSAND PESOS (P 50,000.00) as Attorney’s Fees.

Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 30th day of January 2014.

ATTY. MARIUS F. PONTMERCI

259
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, HARRY I. JANUARIO, of legal age, single, Filipino citizen, and a resident

of 67 Green Valley Subdivision, Baguio City, Philippines after having been duly
sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and on the basis of copies of documents
and records in my possession;

IN WITNESS WHEREOF, I have hereunto set my hand this 30th day of

January 2014, at Baguio City, Philippines.

HARRY I. JANUARIO
Affiant
260
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines,
th
this 30 day of January 2014, by HARRY I. JANUARIO, who is personally known to
me, who is the same person who personally signed before me the foregoing
document.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
PTR No. 1928374/Baguio City/01-04-13
Roll of Atty. No. 67548/05-18-10
Doc. No. 74; IBP OR No. 739281/Baguio-Benguet/01-04-13
Page No. 15; MCLE Compliance No. IV-90210/04-22-13
Book No. I; Commission Serial No. 01-NC-11 (R)
Series of 2014
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

JOHN K. LAVATORRE,
Plaintiff,
-versus- Civil Case No.: _____
FOR ANNULMENT OF
KRISTINO L. MAPALO, DOCUMENT
Defendant.
x------------------------------------x

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and

unto this Honorable Court, most respectfully states that:

1. Plaintiff is a Filipino, of legal age, single, and a resident of 78 Green

Valley Subdivision, Baguio City where he may be served with
summons and other processes, while defendant is also a Filipino, of
legal age, single, a friend of plaintiff, and a resident of 13 Camp Allen,
Baguio City where he may be served with summons and other
processes;

2. Plaintiff owns a MOTOR VEHICLE, hereinafter referred to as

personalty, which is described as follows:

ONE (1) UNIT MOTOR VEHICLE

Make: Isuzu 2012 Model
261
Plate Number: UV AFB 143
MV File Number: 4305-10999
Motor Number: 886668
Serial/ Chassis Number: VCM 6565 432
Official Receipt Number: 12334789
Certificate of Registration Number: 93334060

3. Petitioner and defendant agreed to enter into a contract of sale

wherein the former shall sell the second personalty to the latter in
exchange for money. However, as no amount was ever agreed upon
by them, the contract was never made;

4. On November 20, 2013, defendant borrowed the personalty for

business purposes and petitioner, a good friend as he was, lent said
personalty to the former on condition that the personalty be
returned ten (10) days thereafter;

5. However, on the date of the supposed delivery, defendant refused to

deliver said personalty and claimed that he bought the same from
petitioner. Defendant, through fraud, showed petitioner their
purported DEED OF ABSOLUTE SALE dated November 20, 2013,
herein attached as ANNEX 1, in which said personalty was allegedly
sold for and in consideration of SEVEN HUNDRED FIFTY THOUSAND
PESOS (P 750,000.00) and which contained the forged signature of
the latter;

6. The events led petitioner to obtain the legal services of counsel and
to institute the instant complaint for annulment of the
abovementioned document, thereby committing him FIFTY
THOUSAND PESOS (P 50,000.00) as Attorney’s Fees; and

7. This action is commenced within four (4) years from the time of
discovery of defendant’s fraud pursuant to ARTICLE 1391 of the CIVIL
CODE OF THE PHILIPPINES.

WHEREFORE, plaintiff most respectfully prays this Honorable Court to

render judgment in his favor:

1. ANNULLING the Deed of Absolute Sale dated November 20, 2013;

2. ORDERING restitution of the possession of the personalty described

in paragraph 2 hereof to plaintiff; and

3. ORDERING defendant to pay plaintiff FIFTY THOUSAND PESOS

(P50,000.00) as Attorney’s Fees.
262
Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 30th day of January 2014.

ATTY. MARIUS F. PONTMERCI

Counsel for the Plaintiff
3F La Azotea Bldg., Session Road, Baguio City
(074) 422-0987
PTR No. 1999910/Baguio City/01-02-14
Roll of Atty. No. 81319/05-05-13
IBP OR No. 692876/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-99080/04-22-13
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, JOHN K. LAVATORRE, of legal age, single, Filipino citizen, and a resident

of 78 Green Valley Subdivision, Baguio City, Philippines after having been duly
sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and on the basis of copies of documents
and records in my possession;

IN WITNESS WHEREOF, I have hereunto set my hand this 30th day of

January 2014, at Baguio City, Philippines.

JOHN K. LAVATORRE
Affiant
263
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines,
this 30th day of January 2014, by JOHN K. LAVATORRE, who is personally known
to me, who is the same person who personally signed before me the foregoing
document.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
PTR No. 1928374/Baguio City/01-04-13
Roll of Atty. No. 67548/05-18-10
Doc. No. 75; IBP OR No. 739281/Baguio-Benguet/01-04-13
Page No. 15; MCLE Compliance No. IV-90210/04-22-13
Book No. I; Commission Serial No. 01-NC-11 (R)
Series of 2014
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

MARVIN N. ONESIMUS,
Plaintiff,
-versus- Civil Case No.: _____
FOR RECONVEYANCE OF
MARGENE N. ONESIMUS, PROPERTY
Defendant.
x------------------------------------x

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and

unto this Honorable Court, most respectfully states that:

1. Plaintiff is a Filipino, of legal age, single, and a resident of 201 Upper

Woodsgate, Camp 7, Baguio City where he may be served with
summons and other court processes, while defendant is a Filipino, of
legal age, single, and a resident of 33 Montecillo, Camp 7, Baguio City
where he may be served with summons and other court processes;

2. Plaintiff and defendant are brothers and two of the children of

MARIO P. ONESIMUS, hereinafter referred to as the deceased, who
died on June 1, 2012 and left a parcel covering 450 square meters of
land at 33 Montecillo, Camp 7, Baguio City described in TCT No.
1029-B herein attached as ANNEX A;

264
3. Right after the burial of deceased, defendant requested from plaintiff
and their other sibling MARJORIE N. ONESIMUS that he be allowed to
take possession and receive income generated by the subject
property until after his eldest son could graduate from college, to
which request the siblings acceded;

4. After his eldest son NATHANIEL S. ONESIMUS graduated in college,

defendant was asked by plaintiff and their other sibling to return the
subject property so they could partition the same among themselves.
Defendant, however, refused to relinquish possession of said
property to the prejudice of the other siblings;

5. Due to defendant’s refusal to return possession of the subject

property, plaintiff was forced to institute the foregoing action,
committing him to pay FIFTEEN THOUSAND PESOS (P 15,000.00) as
consideration for legal services rendered by counsel.

WHEREFORE, plaintiff most respectfully prays this Honorable Court to

render judgment in his favor

1. ORDERING restitution of the possession of the parcel of land

described in paragraph 2 hereof to plaintiff; and

2. ORDERING defendant to pay plaintiff FIFTY THOUSAND PESOS

(P50,000.00) as Attorney’s Fees.

Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 30th day of January 2014.

ATTY. MARIUS F. PONTMERCI

265
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, MARVIN N. ONESIMUS, of legal age, single, Filipino citizen, and a

resident of 201 Upper Woodsgate, Camp 7, Baguio City, Philippines after having
been duly sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and on the basis of copies of documents
and records in my possession;

IN WITNESS WHEREOF, I have hereunto set my hand this 30th day of

January 2014, at Baguio City, Philippines.

MARVIN N. ONESIMUS
Affiant
266
SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines,
this 30th day of January 2014, by MARVIN N. ONESIMUS, who is personally
known to me, who is the same person who personally signed before me the
foregoing document.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
PTR No. 1928374/Baguio City/01-04-13
Roll of Atty. No. 67548/05-18-10
Doc. No. 76; IBP OR No. 739281/Baguio-Benguet/01-04-13
Page No. 16; MCLE Compliance No. IV-90210/04-22-13
Book No. I; Commission Serial No. 01-NC-11 (R)
Series of 2014
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

NAOMI O. PASANLANGIT,
Petitioner,
-versus- Civil Case No.: _____
FOR LEGAL SEPARATION
NATHANIEL Q. PASANLANGIT,
Respondent.
x--------------------------------------x

PETITION

COMES NOW, the petitioner, through the undersigned counsel, and

unto this Honorable Court, most respectfully states that:

1. Petitioner is a Filipino, of legal age, and a resident of 201 Sanitary

Camp, Trancoville, Baguio City where she may be served with
summons and other court processes, while respondent is a Filipino,
of legal age, and now a resident of 44 Montecillo, Camp 7, Baguio
City where he may be served with summons and other court
processes;

2. Petitioner and respondent are married to each other since February

29, 2000, as evidenced by their marriage contract herein attached as
ANNEX 1, under the regime of conjugal partnership of gains;

267
3. For almost nine (9) years, they lived together as a happy family, with
their only child NIKOLAI O. PASANLANGIT now six (6) years old,
whose birth certificate is herein attached as ANNEX 2, in the
abovementioned address of petitioner;

4. However, on January 16, 2010, respondent left petitioner and their

child, without any notice and justifiable cause. Petitioner exerted
every effort to communicate with and find respondent until one and
a half (1½) years later she saw the latter with another woman while
walking along Session Road;

5. On the same day, petitioner confronted respondent who,

unfortunately, ignored her. Two (2) days later, petitioner received a
letter, herein attached as ANNEX 3, from respondent stating, among
others, “Hindi na kita mahal. Magkanya-kanya na tayo. x x x”;

6. Due to the abandonment by respondent for more than a year,

without any justifiable cause, petitioner commenced this instant
action which committed her to engage legal services of counsel
amounting to FIFTY THOUSAND PESOS (P 50,000.00);

7. The children of petitioner and respondent are in petitioner’s custody

and are being supported by her financially and emotionally;

8. Petitioner cannot provide all the financial needs of the children as

she is earning a limited amount from her work whereas respondent
is gainfully employed and earns more than enough for his personal
needs. Petitioner earns only EIGHTEEN THOUSAND PESOS (P
18,000.00) a month as shown by her payslip attached as ANNEX 4,
whereas respondent earns FORTY FIVE THOUSAND PESOS (P
45,000.00) a month as shown by his payslip attached as ANNEX 5.
Their common property is insufficient for support of the children.

WHEREFORE, plaintiff most respectfully prays this Honorable Court to

render judgment in her favor:

1. GRANTING legal separation of petitioner and respondent;

2. AWARDING permanent custody of the minor children to petitioner,

with express acknowledgement of the respondent’s visitation rights;

3. AWARDING monthly support in the amount of TWENTY THOUSAND

PESOS (P20,000.00) for the minor child, subject to adjustments to be
made on changes in earning capacity and needs of the children; and

268
4. ORDERING respondent to pay plaintiff FIFTY THOUSAND PESOS
(P50,000.00) as Attorney’s Fees.

Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 30th day of January 2014.

ATTY. MARIUS F. PONTMERCI

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, NAOMI O. PASANLANGIT, of legal age, single, Filipino citizen, and a

resident of 201 Sanitary Camp, Trancoville, Baguio City, Philippines after having
been duly sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing petition;

3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and on the basis of copies of documents
and records in my possession;

IN WITNESS WHEREOF, I have hereunto set my hand this 30th day of

January 2014, at Baguio City, Philippines.

269
NAOMI O. PASANLANGIT
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines,

this 30th day of January 2014, by NAOMI O. PASANLANGIT, who is personally
known to me, who is the same person who personally signed before me the
foregoing document.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
PTR No. 1928374/Baguio City/01-04-13
Roll of Atty. No. 67548/05-18-10
Doc. No. 77; IBP OR No. 739281/Baguio-Benguet/01-04-13
Page No. 16; MCLE Compliance No. IV-90210/04-22-13
Book No. I; Commission Serial No. 01-NC-11 (R)
Series of 2014
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PAMELA Q. REQUIEM,
Petitioner,
-versus- Civil Case No.: _____
FOR NULLITY OF MARRIAGE
PRINCE O. REQUIEM,
Respondent.
x--------------------------------------x

PETITION

COMES NOW, the petitioner, through the undersigned counsel, and

unto this Honorable Court, most respectfully states that:

1. Petitioner is a Filipino citizen, of legal age, and married to

respondent. For purposes of this petition, she may be served with
notices and other pertinent processes through counsel;

2. Respondent is a Filipino citizen, of legal age, currently employed at

Summer Palace Hotel, and married to the petitioner. He may be
served with summons and other pertinent processes at 23 Lower
East Camp 7, Baguio City;

270
3. Petitioner and respondent were married on March 25, 1990 under
the regime of conjugal partnership of gains, and out of this marriage
they have 2 children – PERCIVAL Q. REQUIEM (15 years old) and
PRECIOUS Q. REQUIEM (6 years old). A copy of the Marriage Contract
of petitioner and respondent is attached as ANNEX A and copies of
each of the birth certificates of the minor children are attached as
ANNEXES B and C, respectively;

4. Petitioner and respondent are currently separated in fact and have

been so since May 2013. The reason for the continuing separation in
fact is the breakdown of the marriage due to respondent’s
psychological incapacity, which existed at the time of the marriage in
1990 and manifested well during the marriage, as he cannot fulfill
and discharge his marital obligations to petitioner;

5. Respondent’s psychological incapacity appears to be incurable. The

parties had attempted formal and informal counseling sessions, all of
which proved unproductive as respondent was resistant to efforts;
6. Respondent’s psychological incapacity is classified in clinical terms as
being consistent with “Schizoid Personality Disorder with narcissistic
features” which is further described as “grave, incurable and has
antecedents.” This is explained in greater detail in his Clinical
Assessment Report dated February 20 2013, attached as ANNEX D;

7. The children of petitioner and respondent are in petitioner’s custody

and are being supported by her financially and emotionally;

8. Petitioner, however, cannot provide for all the financial needs of the
children as she is only earning a limited amount of money from her
work whereas respondent is gainfully employed and earns more than
enough for his own personal needs. Petitioner earns only EIGHTEEN
THOUSAND PESOS (P 18,000.00) a month from her work as shown by
her payslip attached as ANNEX E, whereas respondent earns FORTY
FIVE THOUSAND PESOS (P 45,000.00) a month from his work as
shown by his payslip attached as ANNEX F. the common property of
the parties is likewise insufficient for the support of the children.

WHEREFORE, petitioner prays that judgment be rendered:

1. Declaring the marriage between petitioner and respondent a nullity

and, by this token, ordering the dissolution of the conjugal
partnership of gains;

2. Awarding permanent custody of the minor children to petitioner,

with express acknowledgement of the respondent’s visitation rights;
271
3. Awarding monthly support in the amount of TWENTY THOUSAND
PESOS (P 20,000.00) for each minor child, subject to adjustments to
be made on changes in earning capacity and needs of the children.

Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 30th day of January 2014.

ATTY. MARIUS F. PONTMERCI

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, PAMELA Q. REQUIEM, of legal age, single, Filipino citizen, after having

been duly sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing petition;

3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and on the basis of copies of documents
and records in my possession;

IN WITNESS WHEREOF, I have hereunto set my hand this 30th day of

January 2014, at Baguio City, Philippines.

272
PAMELA Q. REQUIEM
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines,

th
this 30 day of January 2014, by PAMELA Q. REQUIEM, who is personally known
to me, who is the same person who personally signed before me the foregoing
document.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
PTR No. 1928374/Baguio City/01-04-13
Roll of Atty. No. 67548/05-18-10
Doc. No. 78; IBP OR No. 739281/Baguio-Benguet/01-04-13
Page No. 16; MCLE Compliance No. IV-90210/04-22-13
Book No. I; Commission Serial No. 01-NC-11 (R)
Series of 2014
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

RAPAHEL S. TORTELLINI,
Petitioner,
-versus- Civil Case No.: _____
FOR ACKNOWLEDGMENT OF
SAMANTHA T. URDUJA, FOREIGN DECREE OF DIVORCE
Respondent.
x--------------------------------------x

PETITION

COMES NOW, the petitioner, through the undersigned counsel, and

unto this Honorable Court, most respectfully states that:

1. Petitioner is a Canadian citizen, of legal age, and divorced to

respondent under the Canadian law. For purposes of this petition, he
may be served with notices and other pertinent processes through
counsel at 3F La Azotea Bldg., Session Road, Baguio City;

2. Respondent is a Filipino citizen, of legal age, currently employed at

Summer Palace Hotel, and divorced to petitioner. She may be served
with summons and other pertinent processes at her postal address
55 Ambiong, Barangay Aurora Hill, Baguio City;
273
3. Petitioner and respondent met in Canada and fell in love with each
other. They were married in Canada on March 20, 2006, as evidenced
by their marriage contract herein attached as ANNEX 1 and a
photograph of the ceremony herein attached as ANNEX 2, which was
held valid within the jurisdiction of Philippines pursuant to ARTICLE
26 of the FAMILY CODE;

4. Thereafter, respondent returned to the Philippines to watch over the

construction of their family home located in at Woodsgate, Camp 7,
Baguio City. Five years after the marriage, when petitioner went to
the Philippines to check on his wife and their home, he discovered
that his wife was having an affair with another man;

5. Hurt and disappointed, petitioner returned to Canada and filed a

petition for divorce which was granted by the Superior Court of
Justice of Ontario, Canada on December 8, 2012. A decree of divorce,
herein attached as ANNEX 3, was issued and subsequently became
effective on January 8, 2013;

6. Three months after the divorce, petitioner moved on and met

another Filipina THERESE U. VILLANUEVA, of legal age and a resident
of 43 Engineer’s Hill, Baguio City;

7. Desiring now to remarry, petitioner instituted the instant

proceedings for the acknowledgement of the aforementioned
foreign decree of divorce.

WHEREFORE, it is respectfully prayed that judgment be rendered by

this Honorable Court ACKNOWEDGING the Decree of Divorce issued with
finality by the Superior Court of Justice of Ontario, Canada.

Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 30th day of January 2014.

ATTY. MARIUS F. PONTMERCI

Counsel for the Plaintiff
3F La Azotea Bldg., Session Road, Baguio City
(074) 422-0987
PTR No. 1999910/Baguio City/01-02-14
Roll of Atty. No. 81319/05-05-13
274
IBP OR No. 692876/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-99080/04-22-13

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, RAPAHEL S. TORTELLINI, of legal age, single, Canadian citizen, after

having been duly sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing petition;

3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and on the basis of copies of documents
and records in my possession;

IN WITNESS WHEREOF, I have hereunto set my hand this 30th day of

January 2014, at Baguio City, Philippines.

275
RAPAHEL S. TORTELLINI
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines,

this 30th day of January 2014, by RAPAHEL S. TORTELLINI, who is personally
known to me, who is the same person who personally signed before me the
foregoing document.

JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
PTR No. 1928374/Baguio City/01-04-13
Roll of Atty. No. 67548/05-18-10
Doc. No. 79; IBP OR No. 739281/Baguio-Benguet/01-04-13
Page No. 16; MCLE Compliance No. IV-90210/04-22-13
Book No. I; Commission Serial No. 01-NC-11 (R)
Series of 2014

276
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------- x

JUDICIAL COMPLAINT-AFFIDAVIT OF
ARTHUR B. CASTOR FOR ESTAFA

I, ARTHUR B. CASTOR, of legal age, Filipino citizen, General Manager

of First ATM Loans and Credit Corporation, with business address at Room
305, 3rd Floor, Samson Building, Lower Mabini Street, Baguio City,
Philippines, after having been sworn in accordance with law, state that:

PURPOSE

This JUDICIAL COMPLAINT-AFFIDAVIT is being offered to prove:

1. That ERINEO E. ESTAFINDO knowingly, wilfully, unlawfully, and

feloniously committed the crime of ESTAFA under Article 315(1b) of
the Revised Penal Code through the subsequent material allegations
stated;

2. That the allegations set forth herein are true by identifying and
marking supporting evidence attached herein as exhibits; and

3. All other matters, facts, and circumstances relevant and material

hereto.

PRELIMINARY STATEMENT

The person examining me is Assistant City Prosecutor JUAN DE LA

CRUZ JR. of the Baguio City Prosecutor’s Office. The examination is being
held at the same office.

I am answering his questions fully conscious that I do so under oath

and may face criminal liability for false testimony and perjury.

The following are the questions propounded by Assistant City

Prosecutor Juan de la Cruz Jr. These questions are numbered consecutively
and my answers are stated after each question.

277
1. Q: Please state your name and other personal circumstances for the
record.
A: I am Arthur B. Castor, 30 years old, General Manager of First ATM
Loans and Credit Corporation (FALCC) with office address at 3rd
Floor, Room 305, Samson Building, Lower Mabini Street, Baguio City.

2. Q: What are the circumstances of First ATM Loans and Credit

Corporation or FALCC?
A: FALCC is a domestic corporation engaged in the business of loans.

3. Q: What is the nature of your complaint?

A: I am filing a complaint for Estafa on behalf of FALCC against Erineo
A. Estafindo, a collector of loan payments for the corporation.

4. Q: Are you authorized to file this complaint?

A: Yes. I have with me the Corporate Secretary’s Certificate
authorizing me to file this complaint on behalf of the corporation.

5. Q: You gave me the sworn FALCC’s Corporate Secretary’s Certificate

authorizing you to file this complaint on behalf of the corporation. I
am marking this as Exhibit “A”. Do you agree with my action?
A: Yes.

6. Q: What does the corporation know about Erineo A. Estafindo?

A: Erineo A. Estafindo is 35 years old, a resident of 123 Mabini St.
Baguio City. He worked for FALCC as a collector from January 1, 2013
up to his suspension on January 15, 2014.

7. Q: What are the duties of Erineo A. Estafindo for FALCC?

A: His duties, among others, are to collect payments of loans for and
in behalf of FALCC, to issue official receipts, and to remit the same to
the company-designated cashier.

8. Q: Was Erineo A. Estafindo able to perform his duties?

A: No. Since he worked as a collector for FALCC, he deceitfully
collected and received loan payments without remitting the same to
the appointed cashier and, thereafter or simultaneously, took and
misappropriated the amounts mentioned.

9. Q: Do you have proof of his collection of loan payments?

A: Yes. Here are Affidavits executed by three clients of FALCC stating
that they paid to Erineo A. Estafindo certain amounts as part of their
loans with FALCC with the expectation that he will remit the same.

278
10. Q: You gave me three (3) sworn Affidavits of FALCC clients stating
they paid to Erineo A. Estafindo their loan payments. I am marking
these as Exhibits “B”, “C”, and “D”. Do you agree with my action?
A: Yes.

11. Q: You said Erineo A. Estafindo misappropriated the funds. How did
he do this?
A: Erineo A. Estafindo created two accounts in his name at Allied
Bank simultaneous with his stint as collector. He received the loan
payments and deposited these in his accounts. On January 30, 2014 a
formal demand has been made upon Erineo A. Estafindo demanding
that he return the amount of Two Hundred Thousand Five Hundred
Sixty Three Pesos and 28/100 (P200,563.28) within five (5) days from
his receipt thereof. Despite such demand, he failed, refused and still
fails and refuses, to return the same. Here is a copy of the received
demand letter.

12. Q: You gave me the demand letter of FALCC received by Erineo A.

Estafindo stating that he return the amount of Two Hundred
Thousand Five Hundred Sixty Three Pesos and 28/100 (P200,563.28)
within five (5) days from his receipt thereof. I am marking this as
Exhibit “E”. Do you agree with my action?
A: Yes.

AFFIANT FURTHER SAYETH NAUGHT.

Baguio City, Philippines, this 14th day of February 2014.

ARTHUR B. CASTOR
for FIRST ATM LOANS AND CREDIT CORPORATION
Affiant

SUBSCRIBED AND SWORN to before me in the City of Baguio,

Philippines this 14th day of February, 2014 by ARTHUR B. CASTOR who has
satisfactorily proven his identity to me through his Non-Professional
Driver’s License No. 01928374, valid until August 30, 2015, and that he is
the same person who personally signed the foregoing Judicial Complaint-
Affidavit before me.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Baguio City
MCLE Compliance No. IV-90210/04-22-13

279
ATTESTATION AND CERTIFICATION OF LEGAL COUNSEL

I, JUAN DE LA CRUZ JR. Assistant City Prosecutor, Baguio City,

Philippines, after having been sworn to in accordance with law, do hereby
depose and say:

1. That I have faithfully recorded or caused to be recorded the

questions I asked and the corresponding answers that affiant gave;

2. That I have not, nor any other person present or assisting, coached
the affiant regarding the affiant’s answers;

3. That I hereby certify that I have personally examined the affiant and
that I am fully satisfied that that affiant read and fully understood the
sworn statement and executed the same freely and voluntarily; and

4. That I fully understand that any false attestation shall subject me to

disciplinary action, including disbarment.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 14 th

day of February 2014 in the City of Baguio, Philippines.

JUAN DE LA CRUZ JR.

Counsel for the State

SUBSCRIBED AND SWORN to before me this 14 th day of February

2014 in the City of Baguio, Philippines.

ATTY. MARIUS F. PONTMERCI

Public Attorney IV
Public Attorney’s Office
Baguio City
MCLE Compliance No. IV-99080/04-22-13

280
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------- x

JUDICIAL COMPLAINT-AFFIDAVIT OF
DARWIN E. FRANCO FOR VIOLATION OF B.P. Blg. 22

I, DARWIN E. FRANCO, of legal age, Filipino citizen, a Certified Public

Accountant, with residence and postal address at 69 Irisan, Baguio City,
Philippines, after having been sworn in accordance with law, state that:

PURPOSE

This JUDICIAL COMPLAINT-AFFIDAVIT is being offered to prove:

1. That BRAULIO D. CZECHO knowingly, wilfully, unlawfully, and

feloniously violated Batas Pambansa Blg. 22 through the subsequent
material allegations stated;

2. That the allegations set forth herein are true by identifying and
marking supporting evidence attached herein as exhibits; and

3. All other matters, facts, and circumstances relevant and material

hereto.

PRELIMINARY STATEMENT

The person examining me is Assistant City Prosecutor JUAN DE LA

CRUZ JR. of the Baguio City Prosecutor’s Office. The examination is being
held at the same office.

I am answering his questions fully conscious that I do so under oath

and may face criminal liability for false testimony and perjury.

The following are the questions propounded by Assistant City

Prosecutor Juan de la Cruz Jr. These questions are numbered consecutively
and my answers are stated after each question.

1. Q: Please state your name and other personal circumstances for the
record.
281
A: I am Darwin E. Franco, 30 years old, a Certified Public Accountant,
residing at 69 Irisan, Baguio City.

2. Q: What is the nature of your complaint?

A: I am filing a complaint for violation of BP 22 against Braulio D.
Czecho who last resided at 69 Grande Island Magsaysay Road, Baguio
City.

3. Q: How did you know Braulio D. Czecho?

A: He was a classmate of mine in college.

4. Q: What happened on October 10, 2013?

A: That morning, I went to McDonalds Centermall to receive the
payment for the money Braulio D. Czecho borrowed from me last
June 2013. He issued in my favor Metrobank Check No. 12345-1234
in the amount of Two Hundred Thousand Pesos (Php 200,000.00) as
supposed payment for the loan accommodation of the same amount
that extended to him. The check is drawn against the account of
Braulio D. Czecho at Metrobank with Account No. 098761234500.
Braulio D. Czecho made the assurance and representation that the
check is a good check and it would be covered by sufficient funds
when presented for payment.

5. Q: What happened next?

A: I deposited the check in my bank account but the check was
dishonored and returned by the bank on the ground that the same
was drawn against insufficient funds.

6. Q: Do you have proof to support your claims?

A: Yes. I have here with me a certified true and faithful photocopy of
the check issued by Braulio D. Czecho in my favor in the amount of
Two Hundred Thousand Pesos (Php 200,000.00).

7. Q: You gave me a certified true and faithful photocopy of Metrobank

Check No. 12345-1234 issued by Braulio D. Czecho in favor of Darwin
E. Franco in the amount of Two Hundred Thousand Pesos, drawn
against the account of Braulio D. Czecho at Metrobank with Account
No. 098761234500, and marked “DAIF” on its face. I am marking this
as Exhibit “A”. Do you agree with my action?
A: Yes.

8. Q: What did you do next when the check was dishonored and
returned?
A: I immediately notified Braulio D. Czecho of the dishonor and
return of the said check and demanded from him that he make good
282
the said check within fifteen (15) days from receipt of my demand
letter. Here is the received copy of the demand letter I gave him.

9. Q: You gave me the demand letter sent by Darwin E. Franco and

received by Braulio D. Czecho demanding from him that he make
good the check within fifteen (15) days from receipt of the letter. I
am marking this as Exhibit “B”. Do you agree with my action?
A: Yes.

10. Q: Did Braulio D. Czecho make good of his check?

A: No. Because of this, I endorsed the check to my lawyer who
immediately sent a formal demand letter through registered mail on
January 12, 2014, which was personally received by Braulio D. Czecho
on January 13, 2014. As of today, however, Braulio D. Czecho
unjustifiably ignores all demands to pay the amount and/or to
redeem the returned check. Here is the received copy of the formal
demand letter and the return card.

11. Q: You gave me the formal demand letter received by Braulio D.

Czecho on January 13, 2014 demanding him to pay the amount of
Two Hundred Thousand Pesos (Php 200,000.00) and redeem the
dishonored check. You also gave me the return card. I am marking
these as Exhibits “C” and “D”. Do you agree with my action?
A: Yes.

AFFIANT FURTHER SAYETH NAUGHT.

Baguio City, Philippines, this 14th day of February 2014.

DARWIN E. FRANCO
Affiant

SUBSCRIBED AND SWORN to before me in the City of Baguio,

Philippines this 14th day of February, 2014 by DARWIN E. FRANCO who has
satisfactorily proven his identity to me through his Professional Regulations
Commission License No. 09123857, valid until September 30, 2015, and
that he is the same person who personally signed the foregoing Judicial
Complaint-Affidavit before me.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Baguio City
MCLE Compliance No. IV-90210/04-22-13

283
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------- x

JUDICIAL COMPLAINT-AFFIDAVIT OF
GREGORY H. ISOLDE FOR ILLEGAL RECRUITMENT

I, GREGORY H. ISOLDE, of legal age, Filipino citizen, a Licensed

Mechanical Engineer, with residence and postal address at 34 Irisan, Baguio
City, Philippines, after having been sworn in accordance with law, state
that:

PURPOSE

This JUDICIAL COMPLAINT-AFFIDAVIT is being offered to prove:

1. That ILADO L. RECUTO knowingly, wilfully, unlawfully, and feloniously

violated Article 38 of the Labor Code of the Philippines by the
commission of Illegal Recruitment through the subsequent material
allegations stated;

2. That the allegations set forth herein are true by identifying and
marking supporting evidence attached herein as exhibits; and

3. All other matters, facts, and circumstances relevant and material

hereto.

PRELIMINARY STATEMENT

The person examining me is Assistant City Prosecutor JUAN DE LA

CRUZ JR. of the Baguio City Prosecutor’s Office. The examination is being
held at the same office.

I am answering his questions fully conscious that I do so under oath

and may face criminal liability for false testimony and perjury.

The following are the questions propounded by Assistant City

Prosecutor Juan de la Cruz Jr. These questions are numbered consecutively
and my answers are stated after each question.

284
1. Q: Please state your name and other personal circumstances for the
record.
A: I am Gregory H. Isolde, 30 years old, a Licensed Mechanical
Engineer, residing at 34 Irisan, Baguio City.

2. Q: What is the nature of your complaint?

A: I am filing a complaint for illegal recruitment against Ilado L.
Recuto, who claimed to be the proprietor of Manpower Philippines,
which last had its office address at 29 Magsaysay Road, Baguio City.

3. Q: How did you know of Ilado L. Recuto and Manpower Philippines?

A: Manpower Philippines advertised its recruitment services at the
Philippine Daily Inquirer classified ads section on December 1, 2013.
The advertisement states that Ilado L. Recuto is the proprietor of
Manpower Philippines. They are looking for a Maintenance Engineer
in Mobil One’s Oil Refinery at the Kingdom of Saudi Arabia. Here is
the newspaper that contains that advertisement.

4. Q: You gave me the December 1, 2013 issue of the Philippine Daily

Inquirer which contains in its Classified Ads section the
advertisement of Manpower Philippines, a recruitment agency
owned by Ilado L. Recuto with office address at 29 Magsaysay Road,
Baguio City, looking for Maintenance Engineers for Mobil One Oil
Refinery located at the Kingdom of Saudi Arabia. I am marking this as
Exhibit “A”. Do you agree with my action?
A: Yes.

5. Q: What happened next?

A: The day after, I went to the address in the advertisement to apply
for the job with all necessary requirements. Then, I was scheduled
for an immediate interview with Ilado L. Recuto. During the
interview, Ilado L. Recuto boasted about the thousands of workers
which he has already sent to various countries in the Middle East as
shown by Manpower’s supposed numerous awards and citations
posted on the walls of their office. Then, I was informed that I had all
the necessary requirements except the mandatory placement fee of
One Hundred Thousand Pesos (Php 100,000.00) which they required
within a period of one (1) month.

6. Q: Were you able to produce and give Ilado L. Recuto the money?
A: Yes. I was able to raise the amount through various loans from my
relatives. I went back to Manpower Philippines on January 3, 2014 to
give them the placement fee. I have here the receipt stating that
Ilado L. Recuto received the amount from me as placement fee for
the job they recruited me for. I was then told to return a week after.
285
7. Q: You gave me the receipt given by Manpower Philippines signed by
Ilado L. Recuto acknowledging that they received from you the
amount of One Hundred Thousand Pesos (Php 100,000.00) as
placement fee for the job they recruited you for. I am marking this as
Exhibit “B”. Do you agree with my action?
A: Yes.

8. Q: What happened a week after?

A: I was shocked to discover that the offices of Manpower were
already abandoned and that there wasn’t a trace to be found of the
agency. I immediately went to the Department of Labor and
Employment (DOLE), and found out that Manpower Philippines was
never issued a valid license or authority to engage in recruitment and
placement by the Secretary of Labor and Employment nor did such
agency exist in their records. I also learned that similar complaints
have been filed against Manpower Philippines and specifically its
proprietor Ilado L. Recuto, by other victims for their illegal activities. I
have here that certification from DOLE.

9. Q: You gave me a DOLE issued certificate stating that Manpower

Philippines was never issued a valid license or authority to engage in
recruitment and placement of workers abroad. I am marking this as
Exhibit “C”. Do you agree with my action?
A: Yes.

AFFIANT FURTHER SAYETH NAUGHT.

Baguio City, Philippines, this 14th day of February 2014.

GREGORY H. ISOLDE
Affiant

SUBSCRIBED AND SWORN to before me in the City of Baguio,

Philippines this 14th day of February, 2014 by GREGORY H. ISOLDE who has
satisfactorily proven his identity to me through his Professional Regulations
Commission License No. 09184372, valid until October 30, 2015, and that
he is the same person who personally signed the foregoing Judicial
Complaint-Affidavit before me.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Baguio City
MCLE Compliance No. IV-90210/04-22-13

286
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------- x

JUDICIAL COMPLAINT-AFFIDAVIT OF
JEREMY K. LOVE FOR SERIOUS PHYSICAL INJURIES

I, JEREMY K. LOVE, of legal age, Filipino citizen, a professional actor,

with residence and postal address at 100 Scout Barrio, Baguio City,
Philippines, after having been sworn in accordance with law, state that:

PURPOSE

This JUDICIAL COMPLAINT-AFFIDAVIT is being offered to prove:

1. That CEDIE A. LEE, PATRASH A. LEE, FULGOSO A. LEE, LASSIE A. LEE

and DENISE L. CORNETTO knowingly, wilfully, unlawfully, and
feloniously committed the crime of Serious Physical Injuries under
Article 263 of the Revised Penal Code through the subsequent
material allegations stated;

2. That the allegations set forth herein are true by identifying and
marking supporting evidence attached herein as exhibits; and

3. All other matters, facts, and circumstances relevant and material

hereto.

PRELIMINARY STATEMENT

The person examining me is Assistant City Prosecutor JUAN DE LA

CRUZ JR. of the Baguio City Prosecutor’s Office. The examination is being
held at the same office.

I am answering his questions fully conscious that I do so under oath

and may face criminal liability for false testimony and perjury.

The following are the questions propounded by Assistant City

Prosecutor Juan de la Cruz Jr. These questions are numbered consecutively
and my answers are stated after each question.

287
1. Q: Please state your name and other personal circumstances for the
record.
A: I am Jeremy K. Love, 30 years old, a professional actor, residing at
100 Scout Barrio, Baguio City.

2. Q: What is the nature of your complaint?

A: I am filing a complaint for serious physical injuries against Cedie A.
Lee, Patrash A. Lee, Fulgoso A. Lee, Lassie A. Lee and Denise L.
Cornetto they did against me on the night of January 22, 2014 at
Prime Hotel, Baguio City.

3. Q: What happened on the night of January 22, 2014?

A: Denise L. Cornetto invited me to her hotel room at Prime Hotel
through a text message. She asked me to pass by Jollibee at her hotel
and bring her Garlic-Pepper Beef. I went to Prime Hotel and bought
the food at the Jollibee branch there and went to Room 501 where
she was staying. I knocked at the door and she opened it. She asked
me to wait inside. I did.

4. Q: What happened next?

A: Five minutes later, Denise L. Cornetto returned with Cedie A. Lee,
Patrash A. Lee, Fulgoso A. Lee, and Lassie A. Lee. They then grabbed
me, pinned me down, tied my hands and legs and started mauling
and beating me all around my body. This happened for quite a while.
I was not able to fight back and they muffled my shouts for help.
After that, they dragged me out of the hotel room and left me for
dead at the entrance gate of Baguio General Hospital.

5. Q: What happened next?

A: I was rushed to the emergency room by people at the hospital
gate where I was treated for my wounds and bruises. I thereafter
learned that I suffered a broken nose, two broken ribs, and severe
bruising all around my body and my face. My broken nose needed to
undergo an operation to align and support the broken bones. Due to
this I was hospitalized for fifteen (15) days and I could not go back to
work for more than a month due to the severe bruising on my face.
Due to my mauling and beating, I feel pain all over my body and I
could not move properly. I have here a comprehensive medical
certificate of my injuries and bruises.

6. Q: You gave me a sworn medical certificate issued by your physician

at the Baguio General Hospital documenting all your injuries and the
possible causes thereof. I am marking this as Exhibit “A”. Do you
agree with my action?
A: Yes.
288
7. Q: What happened next?
A: I referred this issue to the Lupon Tagapamayapa of Salud Mitra
where they all reside however Denise L. Cornetto, Cedie A. Lee,
Patrash A. Lee, Fulgoso A. Lee, and Lassie A. Lee did not appear at the
meeting. Due to this, the Lupon Tagapamayapa gave me this
certificate to file action.

8. Q: You gave me the Certificate to File Action from Salud Mitra

Barangay stating the nonappearance of Denise L. Cornetto, Cedie A.
Lee, Patrash A. Lee, Fulgoso A. Lee, and Lassie A. Lee. I am marking
this as Exhibit “B”. Do you agree with my action?
A: Yes.

AFFIANT FURTHER SAYETH NAUGHT.

Baguio City, Philippines, this 14th day of February 2014.

JEREMY K. LOVE
Affiant

SUBSCRIBED AND SWORN to before me in the City of Baguio,

Philippines this 14th day of February, 2014 by JEREMY K. LOVE who has
satisfactorily proven his identity to me through his Non-Professional
Driver’s License No. 01998765, valid until November 30, 2015, and that he
is the same person who personally signed the foregoing Judicial Complaint-
Affidavit before me.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Baguio City
MCLE Compliance No. IV-90210/04-22-13

289
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------- x

JUDICIAL COMPLAINT-AFFIDAVIT OF
MARCUS N. ORPHEUS FOR ORAL DEFAMATION

I, MARCUS N. ORPHEUS, of legal age, Filipino citizen, a Licensed

Physical Therapist, with residence and postal address at 24 Aurora Hill,
Baguio City, Philippines, after having been sworn in accordance with law,
state that:

PURPOSE

This JUDICIAL COMPLAINT-AFFIDAVIT is being offered to prove:

1. That ORAL S. DEFANTO knowingly, wilfully, unlawfully, and

feloniously committed the crime of Slander under Article 263 of the
Revised Penal Code through the subsequent material allegations
stated;

2. That the allegations set forth herein are true by identifying and
marking supporting evidence attached herein as exhibits; and

3. All other matters, facts, and circumstances relevant and material

hereto.

PRELIMINARY STATEMENT

The person examining me is Assistant City Prosecutor JUAN DE LA

CRUZ JR. of the Baguio City Prosecutor’s Office. The examination is being
held at the same office.

I am answering his questions fully conscious that I do so under oath

and may face criminal liability for false testimony and perjury.

The following are the questions propounded by Assistant City

Prosecutor Juan de la Cruz Jr. These questions are numbered consecutively
and my answers are stated after each question.

290
1. Q: Please state your name and other personal circumstances for the
record.
A: I am Marcus N. Orpheus, 30 years old, a Licensed Physical
Therapist, residing at 24 Aurora Hill, Baguio City.

2. Q: What is the nature of your complaint?

A: I am filing a complaint for oral defamation committed against me
by Oral S. Defanto, a resident of 30 Aurora Hill, Baguio City.

3. Q: How did you know Oral S. Defanto?

A: Oral S. Defanto is my neighbor since I resided at Aurora Hill. At
times, his wife would ask for physical therapy services since she
suffered a broken leg from tumbling down their stairs. In fact, it was
Oral S. Defanto, on December 16, 2013, who initially asked for my
services. When I examined how bad his wife’s fall was, it needed
several therapy sessions over the course of three (3) months. I told
them these facts and they both agreed with these. They even gave
me the full payment for these services though I did not ask for it yet.
Oral S. Defanto also gave permission to conduct therapy sessions
even if he was not there. He assured me I do not have to worry about
anything.

4. Q: What happened on January 24, 2014?

A: On January 24, 2014 at around 5 PM, I was walking home from
work at Aurora Hill, Baguio City, when I met my neighbor, Oral S.
Defanto, who, without me saying anything, to my surprise
intentionally shouted, “PUTA KANG MAKATING KAPITBAHAY KA!
INAGAW MO ASAWA KO! PALAGI KAYONG NAGLALAMPUNGAN SA
ILALIM NG BAHAY NAMIN! MANG-AAGAW KA NG ASAWA! PUTA
KA!” It was shouted a lot of times and was heard by my neighbors
and my son who is only five (5) years old.

5. Q: What were the consequences of this act?

A: I received negative responses from my neighbors and they talk in
whispers whenever I pass by. My son is always crying as he is always
ridiculed by his playmates as the son of a whore. I have been morally
injured by this act and respect for me by my neighbors has
diminished since. I now have a very bad reputation in our barangay.
Due to this I believe I am entitled to moral damages in the amount of
at least Fifty Thousand Pesos (Php 50,000.00).

6. Q: Did you talk about this at the Lupon Tagapamayapa?

A: I tried to set a meeting at the Barangay with Oral S. Defanto but he
did not come on the scheduled dates. I have here the certificate to
file action from the Barangay.
291
7. Q: You gave me the Certificate to File Action from Aurora Hill
Barangay stating the nonappearance of Oral S. Defanto in the
meetings. I am marking this as Exhibit “A”. Do you agree with my
action?
A: Yes.

AFFIANT FURTHER SAYETH NAUGHT.

Baguio City, Philippines, this 14th day of February 2014.

MARCUS N. ORPHEUS
Affiant

SUBSCRIBED AND SWORN to before me in the City of Baguio,

Philippines this 14th day of February, 2014 by MARCUS N. ORPHEUS who
has satisfactorily proven his identity to me through his Professional
Regulations Commission License No. 09139576, valid until December 30,
2015, and that he is the same person who personally signed the foregoing
Judicial Complaint-Affidavit before me.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Baguio City
MCLE Compliance No. IV-90210/04-22-13

292
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------- x

JUDICIAL COMPLAINT-AFFIDAVIT OF
PRINCE Q. RUTHERFORD FOR RAPE

I, PRINCE Q. RUTHERFORD, of legal age, Filipino citizen, a Registered

Nurse, with residence and postal address at 43 Marcoville, Baguio City,
Philippines, after having been sworn in accordance with law, state that:

PURPOSE

This JUDICIAL COMPLAINT-AFFIDAVIT is being offered to prove:

1. That RUPERTO M. LASUA knowingly, wilfully, unlawfully, and

feloniously committed the crime of Rape through Sexual Assault
under Article 266-A(2) of the Revised Penal Code through the
subsequent material allegations stated;

2. That the allegations set forth herein are true by identifying and
marking supporting evidence attached herein as exhibits; and

3. All other matters, facts, and circumstances relevant and material

hereto.

PRELIMINARY STATEMENT

The person examining me is Assistant City Prosecutor JUAN DE LA

CRUZ JR. of the Baguio City Prosecutor’s Office. The examination is being
held at the same office.

I am answering his questions fully conscious that I do so under oath

and may face criminal liability for false testimony and perjury.

The following are the questions propounded by Assistant City

Prosecutor Juan de la Cruz Jr. These questions are numbered consecutively
and my answers are stated after each question.

293
1. Q: Please state your name and other personal circumstances for the
record.
A: I am Prince Q. Rutherford, 30 years old, a Registered Nurse,
residing at 43 Marcoville, Baguio City.

2. Q: What is the nature of your complaint?

A: I am filing a complaint for rape committed against me by Ruperto
M. Lasua, a resident of 200 Engineer’s Hill, Baguio City.

3. Q: How did you know Ruperto M. Lasua?

A: Ruperto M. Lasua was a friend of mine since I was six (6) years old.
Due to this, I know him very well. He was one of my drinking buddies
before I was employed as a nurse.

4. Q: What happened on January 31, 2014?

A: On January 31, 2014 at around 10 PM, I was walking home from
work at Marcoville, Baguio City, when I met Ruperto M. Lasua having
a drink at a friend’s house. I decided to stop by and catch things up
with him since it has been a while since we last talked. He offered me
beer which I declined. However, he insisted saying, “For good old
times, Dude.” He then gave me a glass of beer. I did not know the
beer was drugged. I drank the beer he gave. A few minutes later, I
felt dizzy so I had to sit. He asked me what was wrong and I told him I
was feeling dizzy maybe due to stress at work. He offered to bring me
home to which I acceded. I must have fallen asleep at that time
because I could not remember him taking me home.

5. Q: What do you remember when you woke up?

A: I woke up because there was something painful at my anus. I was
surprised that my hands and feet were tied at both ends of the bed
and a gag was put inside my mouth. I woke up at a different
bedroom, remembering it was Ruperto M. Lasua’s bedroom since I
had been at their house for so many times before. I saw Ruperto M.
Lasua inserting a full bottle of San Mig Light through my sphincter. It
was so painful. He did this at least five times. Then he removed the
bottle and opened it then inserted it through my sphincter again. I
was already crying at that time because I was violated and the beer
was painful. When he emptied the beer bottle and removed it, I
forcefully tried to remove all the beer inside my colon which I
succeeded. Upon seeing this, he slapped me at the face and told me,
“Dude, namiss kita ng sobra. Ang tagal na nating hindi nagkikita o
nagkakausap. Pasensya ka na pero ang linis mo kasi tignan kanina na
nakauniporme ng nurse. Nabakla ako Dude! Dapat ako ang makauna
sa iyo. Promise, hindi mo ito makakalimutan.” He then inserted his
erect penis through my sphincter and he raped me again and again
294
until he ejaculated inside me. I was crying and feeling helpless at that
time.

6. Q: How were you able to escape?

A: He set me free then he went to the bathroom. I then ran out of
their house and went straight to the police. The police escorted me
to Baguio General Hospital where I was examined. I have here a
sworn medical certificate by the medical examiner.

7. Q: You gave me the sworn medical certificate prepared by the

medical examiner at Baguio General Hospital stating among others
that sperm and traces of beer were found at your anus and found
also at an anal swab made by them. I am marking this as Exhibit “A”.
Do you agree with my action?
A: Yes.

8. Q: This case may cause you a lot of ridicule and disbelief. Will you be
able to take all of these?
A: Yes. I have considered everything. My friend violated me. He
raped me. I want him to suffer the consequence of his crime. I refuse
to be gagged further like how Ruperto M. Lasua gagged me when he
violated me.

AFFIANT FURTHER SAYETH NAUGHT.

Baguio City, Philippines, this 14th day of February 2014.

PRINCE Q. RUTHERFORD
Affiant

SUBSCRIBED AND SWORN to before me in the City of Baguio,

Philippines this 14th day of February, 2014 by PRINCE Q. RUTHERFORD who
has satisfactorily proven his identity to me through his Professional
Regulations Commission License No. 09173956, valid until January 30,
2016, and that he is the same person who personally signed the foregoing
Judicial Complaint-Affidavit before me.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Baguio City
MCLE Compliance No. IV-90210/04-22-13

295
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ------------------------------------------- x

JUDICIAL COMPLAINT-AFFIDAVIT OF
SIMON T. UMBRIEL FOR MURDER

I, SIMON T. UMBRIEL, of legal age, Filipino citizen, a Professional

Librarian, with residence and postal address at 95 Irisan, Baguio City,
Philippines, after having been sworn in accordance with law, state that:

PURPOSE

This JUDICIAL COMPLAINT-AFFIDAVIT is being offered to prove:

1. That PRIMITIVO M. BERDUGO knowingly, wilfully, unlawfully, and

feloniously killed my brother, Peter T. Umbriel, thereby committing
the crime of Murder under Article 248 of the Revised Penal Code
through the subsequent material allegations stated;

2. That the allegations set forth herein are true by identifying and
marking supporting evidence attached herein as exhibits; and

3. All other matters, facts, and circumstances relevant and material

hereto.

PRELIMINARY STATEMENT

The person examining me is Assistant City Prosecutor JUAN DE LA

CRUZ JR. of the Baguio City Prosecutor’s Office. The examination is being
held at the same office.

I am answering his questions fully conscious that I do so under oath

and may face criminal liability for false testimony and perjury.

The following are the questions propounded by Assistant City

Prosecutor Juan de la Cruz Jr. These questions are numbered consecutively
and my answers are stated after each question.

296
1. Q: Please state your name and other personal circumstances for the
record.
A: I am Simon T. Umbriel, 30 years old, a Professional Librarian,
residing at 95 Irisan, Baguio City.

2. Q: What is the nature of your complaint?

A: I am filing a complaint for murder committed against my brother,
Peter T. Umbriel, by Primitivo M. Berdugo, a resident of 150 Irisan,
Baguio City.

3. Q: How did you know Primitivo M. Berdugo?

A: Primitivo M. Berdugo is our neighbor since we resided at Irisan.

4. Q: What happened on January 31, 2014?

A: On January 31, 2014 at around 5 PM, Primitivo M. Berdugo had an
altercation with my brother Peter T. Umbriel about a loan that
Primitivo M. Berdugo owes my brother. Primitivo M. Berdugo still
refuses to pay his loan of Ten Million Pesos even if it had been long
overdue and several extensions were given by my brother. The
altercation ended with my brother shouting to Primitivo M. Berdugo,
“I’ll see you in court!”

5. Q: What happened next?

A: At around 11PM of the same night, my brother decided to buy
snacks since we were planning to have a movie marathon since it was
a weekend. He went out to a sari-sari store at the end of our street.
Two minutes later, I heard a shout so I went out to the street. I saw
Primitivo M. Berdugo hack my brother with a Japanese cleaver once
at the lower back. I froze with what I saw. People then started to
come out and called for help. It was only then that I was able to
move and run to my brother. He told me, “Primitivo M. Berdugo did
it.” He died in my arms.

6. Q: Thereafter, what happened?

A: We reported the incident to the police. My brother’s body was
taken by the police for autopsy. I later learned that my brother died
because his spinal cord was severed. They gave me an autopsy report
detailing the cause of death of my brother.

7. Q: You gave me the Autopsy Report made by the medical examiner

upon Peter T. Umbriel stating that the cause of death is a single hack
at the back with a sharp object severing the spinal cord. I am marking
this as Exhibit “A”. Do you agree with my action?
A: Yes.

297
AFFIANT FURTHER SAYETH NAUGHT.

Baguio City, Philippines, this 14th day of February 2014.

SIMON T. UMBRIEL
Affiant

SUBSCRIBED AND SWORN to before me in the City of Baguio,

Philippines this 14th day of February, 2014 by SIMON T. UMBRIEL who has
satisfactorily proven his identity to me through his Professional Regulations
Commission License No. 09150285, valid until March 30, 2016, and that he
is the same person who personally signed the foregoing Judicial Complaint-
Affidavit before me.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Baguio City
MCLE Compliance No. IV-90210/04-22-13

298
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- Criminal Case No.: 6543-R

FOR SERIOUS PHYSICAL INJURIES

VICTOR W. XAVIER,
Accused.
x---------------------------------x

APPLICATION FOR PROBATION

The accused, through the undersigned counsel, and unto this
Honorable Court, respectfully states that:

1. Accused is of legal age, single, Filipino citizen and a resident of 123

Buyagan, Poblacion, La Trinidad, Benguet;

2. On January 31, 2014, the Honorable Court rendered judgment on the

above-entitled case convicting the accused of the crime of serious
physical injuries and sentencing him to suffer the penalty of
imprisonment, the dispositive portion of which reads as follows:

“Wherefore, judgment is hereby rendered, finding the accused

guilty of serious physical injuries defined and penalized under Article
263 of the Revised Penal Code, who is hereby sentenced to suffer an
indeterminate penalty of two (2) months and one (1) day of Arresto
Mayor, as minimum and one (1) year and four (4) months of Prision
Correccional, as maximum.
On the Civil aspect, accused is hereby ordered to pay the
complainant the amount of Seventy Five Thousand pesos
(PhP 75,000.00) as reimbursement for actual expenses.
So ordered.”

3. In view of the foregoing judgment, the accused hereby most

respectfully applies before the Honorable Court for probation;

299
4. Accused further states that he is not one among those offenders
disqualified to avail of the benefits of probation, as provided under
Section 9, of Presidential Decree No. 968, as amended;

5. Accused has not perfected nor does he intend to perfect an appeal

from the aforementioned judgment of the Honorable Court;

6. Accused further undertakes to faithfully and religiously comply with

the conditions of the probation as provided for under P.D. 956
(Probation Law of 1976) or as may be ordered by the Honorable
Court should this application for probation be granted.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that this

pleading be noted and made part of the records of the above-entitled case
and that this Application for Probation filed by the accused VICTOR W.
XAVIER be granted.

Baguio City, Philippines, this 14th day of February 2014.

ATTY. MARIUS F. PONTMERCI

Counsel for the Accused
3F La Azotea Bldg., Session Road, Baguio City
(074) 422-0987
[email protected]
PTR No. 1999910/Baguio City/01-02-14
Roll of Atty. No. 81319/05-05-13
IBP OR No. 692876/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-99080/04-22-13

300
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, VICTOR W. XAVIER, of legal age, single, Filipino citizen, and a resident of

123 Buyagan, Poblacion, La Trinidad, Benguet, after having been duly sworn in
accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing application;

3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and on the basis of copies of documents
and records in my possession;

IN WITNESS WHEREOF, I have hereunto set my hand this 14 th day of

February 2014, at Baguio City, Philippines.

VICTOR W. XAVIER
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio, Philippines,

th
this 14 day of February 2014, by VICTOR W. XAVIER, who is personally known to
me, who is the same person who personally signed before me the foregoing
document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
PTR No. 1928374/Baguio City/01-02-14
Doc. No. 80; Roll of Atty. No. 67548/05-18-10
Page No. 16; IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014
301
Commission Serial No. 01-NC-11 (R)

REQUEST FOR AND NOTICE OF HEARING

ATTY. JEAN F. VALJEAN

Branch Clerk of Court
Regional Trial Court
Branch 7, Baguio City

Please submit the foregoing Application to the Court for its

consideration and approval immediately upon receipt thereof and kindly
include the same in the court’s calendar for hearing on 21 February 2014,
at 8:30 in the morning.

PROS. JOSE FERNANDO V. ALONZO

Office of the City Prosecutor
Justice Hall, Baguio City

Please take notice that counsel has requested to be heard on 21

February 2014, at 8:30 in the morning.

ATTY. MARIUS F. PONTMERCI

Counsel for the Accused

Copy Furnished:

PROS. JOSE FERNANDO V. ALONZO

Office of the City Prosecutor
Justice Hall, Baguio City

302
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

In the Matter of the Change of Name

and Correction of the Certificate of
Live Birth of TIM T. MCKEE

Spec. Proc. No.: _____

TIM T. MCKEE FOR CHANGE OF NAME
a.k.a. “Tim Mckee” or “TIMAK-KI”,
Petitioner,
-versus-

THE LOCAL CIVIL REGISTRAR

OF BAGUIO CITY,
Respondent.
x--------------------------------------------------x

PETITION

COMES NOW, the petitioner, through the undersigned counsel, and

unto this Honorable Court, most respectfully avers:

1. That the petitioner is a Filipino citizen, of legal age, single, and a

resident of 23 Engineer’s Hill, Baguio City;

2. That the Local Civil Registrar of Baguio City is a government entity

charged with the recording, registration, and custody of public
records and other matters, with postal address at T. Alonzo St, New
Lucban, Baguio City, Philippines;

3. That the petitioner has been a bona fide resident of the City of
Baguio since 1990, or for at least three (3) years prior to the date of
the filing of this petition;

4. That the petitioner’s present name is TIM T. MCKEE as evidenced by

his Certificate of Live Birth, hereto attached as Annex “A” and made
an integral part of this petition;

5. That such a name is ridiculous and has caused embarrassment to

petitioner through the years;

303
6. That petitioner prays and requests that his present name be changed
to TIMOTHY T. MCKEE and that his Certificate of Live Birth be
corrected to reflect such changes.

WHEREFORE, the petitioner respectfully prays that after due notice,

publication, and hearing, in accordance with the Rules of Court, this
Honorable Court, renders judgment:

1. Declaring petitioner’s name of TIM T. MCKEE be changed to

TIMOTHY T. MCKEE; and

2. Directing the Local Civil Registrar of Baguio City of effect the

corresponding correction in the entry appearing in petitioner’s
Certificate of Live Birth by changing his first name from “TIM” to
“TIMOTHY”.

Baguio City, Philippines, this 28th day of February 2014.

ATTY. MARIUS F. PONTMERCI

Counsel for the Petitioner
3F La Azotea Bldg., Session Road, Baguio City
(074) 422-0987
[email protected]
PTR No. 1999910/Baguio City/01-02-14
Roll of Atty. No. 81319/05-05-13
IBP OR No. 692876/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-99080/04-22-13

304
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, TIM T. MCKEE, of legal age, single, Filipino citizen, and resident of

23 Engineer’s Hill, Baguio City, Philippines after having been duly sworn in
accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing petition;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession;

4. I have not commenced any other action or proceeding involving the

same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;

5. To the best of my knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency; and

6. If I should thereafter learn that a similar action or proceeding has

been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that
fact within five (5) days therefrom to this Honorable Court.

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

February 2014, at Baguio City, Philippines.

TIM T. MCKEE
Affiant

305
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 28th day of February 2014, by TIM T. MCKEE, who is
personally known to me, who is the same person who personally signed
before me the foregoing document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
Doc. No. 80; PTR No. 1928374/Baguio City/01-02-14
Page No. 16; Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014 Commission Serial No. 01-NC-11 (R)

Copy Furnished:

OFFICE OF THE LOCAL CIVIL REGISTRAR

T. Alonzo Street, New Lucban, Baguio City

NATIONAL STATISTICS OFFICE

141 Abanao Extension, Baguio City

OFFICE OF THE CITY PROSECUTOR

Justice Hall, Baguio City

OFFICE OF THE SOLICITOR GENERAL

134 Amorsolo Street, Legaspi Village, Makati City

306
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

In the Matter of the Correction of

Date of Marriage of Parents in
the Certificate of Live Birth of
WOLFGANG AMADEUS A. MOZART
Spec. Proc. No.: _____
WOLFGANG AMADEUS A. MOZART, FOR CORRECTION OF ENTRY
herein represented by his father and IN A BIRTH CERTIFICATE
guardian, JOHANN LEOPOLD G. MOZART
Petitioner,
-versus-

THE LOCAL CIVIL REGISTRAR

OF BAGUIO CITY,
Respondent.
x------------------------------------------------------x

PETITION

COMES NOW, the petitioner, represented herein by his father and

guardian JOHANN LEOPOLD G. MOZART, through the undersigned counsel,
and unto this Honorable Court, most respectfully avers:

1. That the petitioner is a Filipino citizen, a minor, and a resident of 24

Aurora Hill, Baguio City, Philippines, while his representative, who is
his father and guardian is of legal age, Filipino citizen, married, and
with postal address at 24 Aurora Hill, Baguio City, Philippines, where
he may be served with summons and other processes of the
Honorable Court;

2. That the Local Civil Registrar of Baguio City is a government entity

charged with the recording, registration, and custody of public
records and other matters, with postal address at T. Alonzo St, New
Lucban, Baguio City, Philippines;

3. That petitioner WOLFGANG AMADEUS A. MOZART was born on

January 20, 2014, and is the natural child of Spouses JOHANN
LEOPOLD G. MOZART and ANNA MARIA A. MOZART. His birth was
duly registered with the Baguio City Local Civil Registry under Local
Civil Registry No. 2014-1035. A photocopy of the Certificate of Live

307
Birth of the said minor is hereto attached as Annex “A”, and made an
integral part hereof;

4. That in the said Certificate of Live Birth of the petitioner, the date
and place of marriage of his parents was entered as “MARCH 1, 2013
– BAGUIO CITY”. In all truth and honesty, the entry was furnished by
petitioner’s parents in good faith merely to avoid the stigma of
illegitimacy since they were not married at petitioner’s birth;

5. That the parents of petitioner eventually got married on February 25,

2014 in Baguio City. A photocopy of the Marriage Certificate is
hereto attached as Annex “B” and made an integral part hereof;

6. That petitioner seeks the correction of the erroneous entry in his

birth certificate setting forth the date and place of his parents’
marriage as “MARCH 1, 2013 - BAGUIO CITY”. The cancellation of
this entry would more accurately set forth the real circumstances
attendant to his birth;

7. That in order therefore to correct the entry in the Certificate of Live

Birth, an Order by the Honorable Court directing the Local Civil
Registrar is needed to effect the changes.

WHEREFORE, the petitioner respectfully prays that after due notice

and hearing, a decision be rendered in his favor, ordering the Local Civil
Registrar of Baguio City, to correct the erroneous entry in his Certificate of
Live Birth under paragraph 18 – Date and Place of Marriage of Parents,
which states “MARCH 1, 2013 – BAGUIO CITY” amending it to “FEBRUARY
25, 2014 - BAGUIO CITY”.

Baguio City, Philippines, this 28th day of February 2014.

ATTY. MARIUS F. PONTMERCI

308
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, JOHANN LEOPOLD G. MOZART, of legal age, married, Filipino

citizen, and resident of 24 Aurora Hill, Baguio City, Philippines after having
been duly sworn in accordance with law, depose and state that:

1. I am the petitioner’s representative in the above-entitled case;

2. I have caused the preparation and the filing of the foregoing petition;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession;

4. I have not commenced any other action or proceeding involving the

same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;

5. To the best of my knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency; and

6. If I should thereafter learn that a similar action or proceeding has

been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that
fact within five (5) days therefrom to this Honorable Court.

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

February 2014, at Baguio City, Philippines.

JOHANN LEOPOLD G. MOZART

Affiant

309
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 28th day of February 2014, by JOHANN LEOPOLD G.
MOZART, who is personally known to me, who is the same person who
personally signed before me the foregoing document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
Doc. No. 81; PTR No. 1928374/Baguio City/01-02-14
Page No. 17; Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014 Commission Serial No. 01-NC-11 (R)

Copy Furnished:

OFFICE OF THE LOCAL CIVIL REGISTRAR

T. Alonzo Street, New Lucban, Baguio City

NATIONAL STATISTICS OFFICE

141 Abanao Extension, Baguio City

OFFICE OF THE CITY PROSECUTOR

Justice Hall, Baguio City

OFFICE OF THE SOLICITOR GENERAL

134 Amorsolo Street, Legaspi Village, Makati City

310
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

In the Matter of the Declaration

of Presumptive Death of
LUDWIG VAN BEETHOVEN
Spec. Proc. No.: _____
JOSEPHINE V. BEETHOVEN, FOR PRESUMPTIVE DEATH
Petitioner.
x-------------------------------------------x

PETITION

COMES NOW, the petitioner, through the undersigned counsel, and

unto this Honorable Court, most respectfully avers:

1. That the petitioner is a Filipino citizen, of legal age, and a resident of

25 Cabinet Hill, Baguio City, Philippines, where she may be served
with summons and other processes of the Honorable Court;

2. That the petitioner and her husband, LUDWIG VAN BEETHOVEN,

were married to each other, on November 28, 1992, before Cardinal
Joseph Ratzinger, at the San Agustin Church, Intramuros, Manila.
Attached herewith, marked as Annex “A” and made an integral part
of this petition is a copy of the marriage certificate;

3. That out of the said marriage, two (2) children were born, namely,
JOHANN V. BEETHOVEN, born on November 8, 1993, and MARIA V.
BEETHOVEN, born on November 8, 1995. Attached herewith are the
birth certificates of said children correspondingly marked as Annex
“B”, Annex “C”, and Annex “D”;

4. That the petitioner’s husband left the conjugal abode sometime in

2000 and no news about said respondent had been received since
then;

5. That the common children have since been legally adopted by the
petitioner’s parents who are U.S. citizens and have been living in the
United States since their respective adoptions were granted;

6. That the petitioner has exhausted all possible means as mandated by

law to ascertain the whereabouts of her husband but to no avail;

311
7. That given the lapse of time since the last news or sighting of the
petitioner’s husband, the latter may now be declared legally dead for
all intents and purposes.

WHEREFORE, the petitioner respectfully prays that after due notice

and hearing, a decision be rendered in her favor declaring her husband
LUDWIG VAN BEETHOVEN PRESUMPTIVELY DECEASED for all legal intents
and purposes.

Baguio City, Philippines, this 28th day of February 2014.

ATTY. MARIUS F. PONTMERCI

312
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, JOSEPHINE V. BEETHOVEN, of legal age, Filipino citizen, and

resident of 25 Cabinet Hill, Baguio City, Philippines after having been duly
sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing petition;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession;

4. I have not commenced any other action or proceeding involving the

same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;

5. To the best of my knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency; and

6. If I should thereafter learn that a similar action or proceeding has

been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that
fact within five (5) days therefrom to this Honorable Court.

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

February 2014, at Baguio City, Philippines.

JOSEPHINE V. BEETHOVEN
Affiant

313
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 28th day of February 2014, by JOSEPHINE V. BEETHOVEN,
who is personally known to me, who is the same person who personally
signed before me the foregoing document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
Doc. No. 82; PTR No. 1928374/Baguio City/01-02-14
Page No. 17; Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014 Commission Serial No. 01-NC-11 (R)

Copy Furnished:

OFFICE OF THE LOCAL CIVIL REGISTRAR

T. Alonzo Street, New Lucban, Baguio City

NATIONAL STATISTICS OFFICE

141 Abanao Extension, Baguio City

OFFICE OF THE CITY PROSECUTOR

Justice Hall, Baguio City

OFFICE OF THE SOLICITOR GENERAL

134 Amorsolo Street, Legaspi Village, Makati City

314
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

In the Matter of the Guardianship of the

Minor PYOTR ILYICH TCHAIKOVSKY
Spec. Proc. No.: _____
ALEXANDER I. TCHAIKOVSKY, FOR GUARDIANSHIP
Petitioner.
x-------------------------------------------x

PETITION

COMES NOW, the petitioner, through the undersigned counsel, and

unto this Honorable Court, most respectfully avers:

1. That the petitioner is a Filipino citizen, of legal age, and a resident of

26 Dominican Hill, Baguio City, Philippines, and the father of the
minor PYOTR ILYICH TCHAIKOVSKY, hereinafter referred to as
“MINOR”;

2. That the MINOR is presently a resident of the City of Baguio;

3. That the MINOR is ten (10) years of age;

4. That the MINOR is the owner of a parcel of land located in the City of
Baguio valued at One Million Pesos (Php 1,000,000.00) and as such
MINOR can make no transactions regarding the same;

5. That the nearest of kin of the MINOR are the following:

a. ALEXANDER I. TCHAIKOVSKY, 30 years old, MINOR’s father,

resident of 26 Dominican Hill, Baguio City;

b. ANASTACIA I. TCHAIKOVSKY, 18 years old, MINOR’s sister,

resident of 20 Panay Avenue, Quezon City;

c. VLADIMIR L. ROMANOV, 75 years old, MINOR’s great

grandfather, resident of St. Petersberg, Russia; and

d. ISABELLA T. ROMONOV, 74 years old, MINOR’s great

grandmother, resident of Siberia, Russia;

315
6. That due to the minority of MINOR, it is necessary and convenient
that a guardian over his person and property be appointed;

7. That petitioner is the person having MINOR in his care and that he
possesses all qualifications of a person to whom letters of
guardianship should issue.

WHEREFORE, the petitioner respectfully prays that after due notice

and hearing, and the furnishing of a bond set by the Honorable Court,
petitioner be issued letters of guardianship and be appointed guardian over
the person and property of the MINOR.

Baguio City, Philippines, this 28th day of February 2014.

ATTY. MARIUS F. PONTMERCI

316
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, ALEXANDER I. TCHAIKOVSKY, of legal age, widower, Filipino

citizen, and resident of 26 Dominican Hill, Baguio City, Philippines after
having been duly sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing petition;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession;

4. I have not commenced any other action or proceeding involving the

same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;

5. To the best of my knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency; and

6. If I should thereafter learn that a similar action or proceeding has

been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that
fact within five (5) days therefrom to this Honorable Court.

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

February 2014, at Baguio City, Philippines.

ALEXANDER I. TCHAIKOVSKY
Affiant

317
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 28th day of February 2014, by ALEXANDER I. TCHAIKOVSKY,
who is personally known to me, who is the same person who personally
signed before me the foregoing document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
Doc. No. 83; PTR No. 1928374/Baguio City/01-02-14
Page No. 17; Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014 Commission Serial No. 01-NC-11 (R)

Copy Furnished:

OFFICE OF THE LOCAL CIVIL REGISTRAR

T. Alonzo Street, New Lucban, Baguio City

NATIONAL STATISTICS OFFICE

141 Abanao Extension, Baguio City

OFFICE OF THE CITY PROSECUTOR

Justice Hall, Baguio City

OFFICE OF THE SOLICITOR GENERAL

134 Amorsolo Street, Legaspi Village, Makati City

318
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

In the Matter of the Petition for the

Writ of Habeas Corpus in favor of the
Minor JOHANN SEBASTIAN BACH
Spec. Proc. No.: _____
JOHANN SEBASTIAN BACH, herein FOR WRIT OF HABEAS CORPUS
represented by his mother,
MARIA ELIZABETH BACH,
Petitioner,
-versus-

JOHANN AMBROSIUS BACH and

ALEXANDRINA BACH,
Respondents.
x-----------------------------------------------x

PETITION

COMES NOW, the petitioner, represented by his mother MARIA

ELIZABETH BACH, through the undersigned counsel, and unto this
Honorable Court, most respectfully avers:

1. That the petitioner is a Filipino citizen, a minor being two years of

age, and under the legal custody of and residing with his mother
MARIA ELIZABETH BACH at 27 Quezon Hill, Baguio City, Philippines,
while the respondents are of legal age and residing at 53 Trancoville,
Baguio City where they may be served with summons and other
court processes;

2. That the petitioner is the legitimate child of MARIA ELIZABETH BACH

with JOHANN AMBROSIUS BACH;

3. That due to several attempts made by respondent JOHANN

AMBROSIUS BACH on the life of his wife MARIA ELIZABETH BACH, the
parties have separated with the minor child in the custody of his
mother;

4. That the legal custody of the said minor, being under five years of
age, is vested in MARIA ELIZABETH BACH;

319
5. That on February 20, 2014, at about 2:30 o’clock in the afternoon,
the respondent JOHANN AMBROSIUS BACH, resorting to ruse and
trickery, abducted the petitioner surreptitiously, leaving MARIA
ELIZABETH BACH in a mall at Magsaysay Avenue, Baguio City, without
returning petitioner to the custody of his mother;

6. That petitioner, in whose behalf this application is being made, is

actually restrained of his liberty by the respondent JOHANN
AMBROSIUS BACH at the residence of his mother ALEXANDRINA
BACH who has knowledge that her son is continuously restraining the
petitioner;

7. That petitioner is a child in a very delicate state of health and can

easily get sick without special care and attention;

8. That the petitioner has exhausted all means allowed by law, and that
he has no other plain, speedy or adequate remedy to protect his
rights except by petition for the issuance of the Writ of Habeas
Corpus.

WHEREFORE, the petitioner respectfully prays that a Writ of Habeas

Corpus be issued, directed to the respondents JOHANN AMBROSIUS BACH
and ALEXANDRINA BACH commanding them to have the body of the minor,
JOHANN SEBASTIAN BACH produced before this Court at the time and
place specified therein, and to summon the said respondents then and
there, to appear and to show the cause of the detention of the said
petitioner, and that after due proceedings, the said minor, JOHANN
SEBASTIAN BACH be discharged from restraint.

Baguio City, Philippines, this 28th day of February 2014.

ATTY. MARIUS F. PONTMERCI

320
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, MARIA ELIZABETH BACH, of legal age, Filipino citizen, and resident

of 27 Quezon Hill, Baguio City, Philippines after having been duly sworn in
accordance with law, depose and state that:

1. I am the petitioner’s representative in the above-entitled case;

2. I have caused the preparation and the filing of the foregoing petition;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession;

4. I have not commenced any other action or proceeding involving the

same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;

5. To the best of my knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency; and

6. If I should thereafter learn that a similar action or proceeding has

been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that
fact within five (5) days therefrom to this Honorable Court.

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

February 2014, at Baguio City, Philippines.

MARIA ELIZABETH BACH

Affiant
321
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 28th day of February 2014, by MARIA ELIZABETH BACH,
who is personally known to me, who is the same person who personally
signed before me the foregoing document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
Doc. No. 84; PTR No. 1928374/Baguio City/01-02-14
Page No. 17; Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014 Commission Serial No. 01-NC-11 (R)

322
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

In the Matter of the Voluntary

Recognition of the Minor Child
ANTONIO C. VIVALDI
Spec. Proc. No.: _____
GIOVANNI B. VIVALDI and FOR VOLUNTARY RECOGNITION
CAMILLA C. VIVALDI, OF A MINOR CHILD
Petitioners.
x--------------------------------------------x

PETITION

COMES NOW, the petitioners, through the undersigned counsel, and

unto this Honorable Court, most respectfully aver:

1. That petitioners are of legal age, Filipino citizens, and residents of 28

Quirino Hill, Baguio City;

2. That GIOVANNI B. VIVALDI is the natural father of the child

ANTONIO C. VIVALDI, who is seven years of age and lives with him
and his wife CAMILLA C. VIVALDI, at the abovementioned address.
Petitioners have continuously recognized the child as their legitimate
child since his birth, introduced him to other persons as their child,
and enrolled him as their child in kindergarten and in the elementary
school. The child has been part of all family gatherings;

3. That the natural mother of the child, ANTONINA C. VIVALDI died

during giving birth to the child on January 30, 2007. Attached hereto
is a copy of the Death Certificate of ANTONINA C. VIVALDI marked as
Annex “A”;

4. That the petitioner, GIOVANNI B. VIVALDI was never legally married

to ANTONINA C. VIVALDI as there are no records in the Local Civil
Registrar that show that the petitioner was married prior to his
current marriage to CAMILLA C. VIVALDI. Attached hereto is a
certification by the Local Civil Registrar marked as Annex “B”;

5. That, as far as the petitioners know, no other persons acknowledged

the child as theirs, or are there any other relatives of the child.

323
WHEREFORE, the petitioner respectfully prays that after due notice
and hearing, the Honorable Court renders a judgment approving the
voluntary recognition of ANTONIO C. VIVALDI as the natural child of the
petitioners.

Baguio City, Philippines, this 28th day of February 2014.

ATTY. MARIUS F. PONTMERCI

Counsel for the Petitioners
3F La Azotea Bldg., Session Road, Baguio City
(074) 422-0987
[email protected]
PTR No. 1999910/Baguio City/01-02-14
Roll of Atty. No. 81319/05-05-13
IBP OR No. 692876/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-99080/04-22-13

324
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

We, GIOVANNI B. VIVALDI and CAMILLA C. VIVALDI, of legal ages,

married to each other, Filipino citizens, and residents of 28 Quirino Hill,
Baguio City, Philippines after having been duly sworn in accordance with
law, depose and state that:

1. We are the petitioners in the above-entitled case;

2. We have caused the preparation and the filing of the foregoing

petition;

3. We have read the contents thereof and the facts stated therein are
true and correct of our personal knowledge and on the basis of
copies of documents and records in our possession;

4. We have not commenced any other action or proceeding involving

the same issues in the Supreme Court, the Court of Appeals, or any
other tribunal or agency;

5. To the best of our knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency; and

6. If we should thereafter learn that a similar action or proceeding has

been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, we undertake to report that
fact within five (5) days therefrom to this Honorable Court.

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

of February 2014, at Baguio City, Philippines.

GIOVANNI B. VIVALDI CAMILLA C. VIVALDI

Affiant Affiant
325
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 28th day of February 2014, by GIOVANNI B. VIVALDI and
CAMILLA C. VIVALDI, who are personally known to me, who are the same
persons who personally signed before me the foregoing document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
Doc. No. 85; PTR No. 1928374/Baguio City/01-02-14
Page No. 17; Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014 Commission Serial No. 01-NC-11 (R)

Copy Furnished:

OFFICE OF THE LOCAL CIVIL REGISTRAR

T. Alonzo Street, New Lucban, Baguio City

NATIONAL STATISTICS OFFICE

141 Abanao Extension, Baguio City

OFFICE OF THE CITY PROSECUTOR

Justice Hall, Baguio City

OFFICE OF THE SOLICITOR GENERAL

134 Amorsolo Street, Legaspi Village, Makati City

326
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

In the Matter of the Adoption of

PEPITO ALAG SANCHEZ Spec. Proc. No.: _____
FOR DOMESTIC ADOPTION
JOHN SANCHEZ,
Petitioner.
x-----------------------------------------x

PETITION

COMES NOW, the petitioner, through the undersigned counsel, and

unto this Honorable Court, most respectfully avers:

1. That the petitioner is a dual citizen of the Philippines and Australia, of

legal age, single, and a currently a resident of Atok Trail, Baguio City
but for the purpose of this proceedings, he elects his Australian
citizenship;

2. That the petitioner has no children or descendants and hereby

desires to adopt his nephew PEPITO ALAG SANCHEZ, Filipino citizen,
52 years old, single, a resident of Session Road, Baguio City, who is
suffering from severe cerebral palsy and is unable to fend for himself,
therefore, an incompetent under the law for his inability to control
his limbs making him dependent upon someone else all his life;

3. That the parents of Pepito are now dead, and he is not under the
care of his brothers since he has been roaming the streets of Baguio
City and living off alms while his brothers enjoy the estate left by
their parents;

4. That the relatives of Pepito are the following:

a. Russell Alag Sanchez, 61 years old, his brother, resident of

Anda, Pangasinan;

b. Keith Alag Sanchez, 59 years old, his brother, resident of Anda,

Pangasinan;

c. Allan Alag Sanchez, 57 years old, his brother, resident of Anda,

Pangasinan;

327
d. Ben Alag Ilao Jr., 32 years old, his half-brother, resident of 23
Aurora Hill, Baguio City;

e. Jack Alag Ilao, 29 years old, his half-brother, resident of 23

Aurora Hill, Baguio City;

f. Michael Sanchez, 75 years old, his paternal uncle, resident of

Anda, Pangasinan; and

g. John Sanchez, 72 years old, his paternal uncle, resident of Atok

Trail, Baguio City;

5. That Pepito is the co-owner pro indiviso of a house and lot at 23

Aurora Hill, Baguio City he inherited from his deceased parents
together with his three brothers, covered by Transfer of Certificate of
Title No. T-45678 in the names of his deceased parents Pedro
Sanchez and Genoveva Alag;

6. That the petitioner possesses all the qualifications and none of the
disqualifications required of an alien adopter by Section 7 of the
Domestic Adoption Act of 1998, to wit: of legal age being 72 years
old, in possession of full civil capacity and legal rights, of good moral
character, has not been convicted of any crime involving moral
turpitude, emotionally and psychologically capable of caring for
Pepito, at least sixteen (16) years older than Pepito, and Pepito is his
relative within the third degree of consanguinity;

7. That the petitioner had attended pre-adoption seminars and

counselling sessions prepared and provided by the Department of
Social Welfare and Development in preparation for the adoption as
evidenced by certificates heretofore attached as Annex “A”;

8. That the petitioner, during his lifetime and beyond, will be able to
financially support Pepito as when Pepito becomes his legitimate son
and becomes an Australian citizen, he will be entitled support from
the Australian government due to his condition, and he also may
avail of survivorship benefits in case of petitioner’s demise;

9. That Pepito, though suffering from severe cerebral palsy, fully

understands the consequences of the adoption and was able to
communicate his eager consent to be adopted by petitioner which
was heard and now witnessed by two disinterested persons from the
Department of Social Welfare and Development with their sworn
affidavits heretofore attached as Annexes “B” and “C”;

328
10.That petitioner only wants to provide love, care, understanding, and
security to Pepito that his other relatives have failed to give and
petitioner wants to uphold and make paramount the best interests of
Pepito now and in the future which are also the policies of the
Domestic Adoption Act of 1998.

WHEREFORE, the petitioner respectfully prays that after due notice

and hearing, judgment be rendered declaring PEPITO ALAG SANCHEZ for all
intents and purposes, the legitimate child of petitioner JOHN SANCHEZ.

Baguio City, Philippines, this 28th day of February 2014.

ATTY. MARIUS F. PONTMERCI

329
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, JOHN SANCHEZ, of legal age, widower, Filipino citizen, and resident

of Atok Trail, Baguio City, Philippines after having been duly sworn in
accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing petition;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession;

4. I have not commenced any other action or proceeding involving the

same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;

5. To the best of my knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency; and

6. If I should thereafter learn that a similar action or proceeding has

been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that
fact within five (5) days therefrom to this Honorable Court.

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

February 2014, at Baguio City, Philippines.

JOHN SANCHEZ
Affiant
330
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 28th day of February 2014, by JOHN SANCHEZ, who is
personally known to me, who is the same person who personally signed
before me the foregoing document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
Doc. No. 86; PTR No. 1928374/Baguio City/01-02-14
Page No. 18; Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014 Commission Serial No. 01-NC-11 (R)

Copy Furnished:

OFFICE OF THE LOCAL CIVIL REGISTRAR

T. Alonzo Street, New Lucban, Baguio City

NATIONAL STATISTICS OFFICE

141 Abanao Extension, Baguio City

OFFICE OF THE CITY PROSECUTOR

Justice Hall, Baguio City

OFFICE OF THE SOLICITOR GENERAL

134 Amorsolo Street, Legaspi Village, Makati City

331
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

In the Matter of the Intestate Estate of

SPOUSES BEN ILAO SR. AND GENOVEVA ALAG
Spec. Proc. No.: _____
BEN ALAG ILAO JR., FOR: ADMINISTRATION
Petitioner.
x-----------------------------------------------------x

PETITION

COMES NOW, the petitioner, through the undersigned counsel, and

unto this Honorable Court, most respectfully avers:

1. That the petitioner is a Filipino citizen, of legal age, single, and a

resident of 23 Aurora Hill, Baguio City;

2. That the petitioner is the legitimate son of the deceased spouses Ben
Ilao Sr. and Genoveva Alag who died intestate in Baguio City on
March 25, 1999 and May 24, 2009, respectively;

3. That the spouses were survived by the following legal heirs, to wit:

a. BEN ALAG ILAO JR., son of the spouses, 32 years old, resident
of 23 Aurora Hill, Baguio City; and

b. JACK ALAG ILAO, son of the spouses, 29 years old, resident of

23 Aurora Hill, Baguio City;

4. That the deceased spouses left the following properties, to wit:

a. Residential Lot located at 23 Aurora Hill, Baguio City with an

assessed value of Five Thousand Pesos (Php 5,000.00) in 1981;
and

b. House located at 23 Aurora Hill, Baguio City with an assessed

value of Thirteen Thousand Four Hundred Pesos (Php
13,400.00) in 1981; and

5. That as far as petitioner knows, the deceased spouses were never

indebted to any person, natural or juridical.

332
WHEREFORE, the petitioner respectfully prays that after due notice
and hearing, and the giving of a bond in the amount fixed by this Honorable
Court, Letters of Administration of the Intestate Estate of the deceased
spouses Ben Ilao Sr. and Genoveva Alag be issued to Ben Alag Ilao Jr.

Baguio City, Philippines, this 28th day of February 2014.

ATTY. MARIUS F. PONTMERCI

333
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, BEN ALAG ILAO JR., of legal age, single, Filipino citizen, and
resident of 23 Aurora Hill, Baguio City, Philippines after having been duly
sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing petition;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession;

4. I have not commenced any other action or proceeding involving the

same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;

5. To the best of my knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency; and

6. If I should thereafter learn that a similar action or proceeding has

been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that
fact within five (5) days therefrom to this Honorable Court.

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

February 2014, at Baguio City, Philippines.

BEN ALAG ILAO JR.

Affiant
334
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
Philippines, this 28th day of February 2014, by BEN ALAG ILAO JR., who is
personally known to me, who is the same person who personally signed
before me the foregoing document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
Doc. No. 87; PTR No. 1928374/Baguio City/01-02-14
Page No. 18; Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014 Commission Serial No. 01-NC-11 (R)

335
ANSWERS

336
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

INDIRA M. SINGH,
Plaintiff,
-versus- Civil Case No.: 1001-R
FOR COLLECTION OF SUM OF MONEY
ALBERT L. GENUINO,
Defendant.
x------------------------------------x

ANSWER

COMES NOW, the defendant, through the undersigned counsel, in

answer to plaintiff’s complaint in the above-entitled case, and unto this
Honorable Court, most respectfully avers:

1. That defendant specifically denies under oath the genuineness and

due execution of the alleged promissory note (Annex B) attached to
said complaint; and

2. That said promissory note was executed through fraud, threats, and
intimidation, therefore it is void.

WHEREFORE, the defendant respectfully prays that the complaint be

dismissed.

Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 7th day of March 2014.

ATTY. MARIUS F. PONTMERCI

Counsel for the Defendant
3F La Azotea Bldg., Session Road, Baguio City
(074) 422-0987
[email protected]
PTR No. 1999910/Baguio City/01-02-14
Roll of Atty. No. 81319/05-05-13
IBP OR No. 692876/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-99080/04-22-13

337
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION

I, ALBERT L. GENUINO, of legal age, single, Filipino citizen, and

resident of 1 Engineer’s Hill, Baguio City, Philippines after having been duly
sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing answer;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession.

IN WITNESS WHEREOF, I have hereunto set my hand this 7 th day of

March 2014, at Baguio City, Philippines.

ALBERT L. GENUINO
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 7th day of March 2014, by ALBERT L. GENUINO, who is
personally known to me, who is the same person who personally signed
before me the foregoing document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
Doc. No. 88; PTR No. 1928374/Baguio City/01-02-14
Page No. 18; Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014 Commission Serial No. 01-NC-11 (R)

Copy Furnished: ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Plaintiff
45 Hotel, Leonard Wood Road, Baguio City
338
339
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

INDIRA M. SINGH,
Petitioner,
-versus- Civil Case No.: 1002-R
FOR INSOLVENCY
BRUCE E. GRATUITO,
Respondent.
x------------------------------------x

ANSWER

COMES NOW, the respondent, through the undersigned counsel, in

answer to petitioner’s petition in the above-entitled case, and unto this
Honorable Court, most respectfully avers:

That he denies that he has committed any of the acts of insolvency

set forth in said petition, or that he is insolvent.

WHEREFORE, the respondent respectfully prays that the petition be

dismissed.

Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 7th day of March 2014.

ATTY. MARIUS F. PONTMERCI

Counsel for the Respondent
3F La Azotea Bldg., Session Road, Baguio City
(074) 422-0987
[email protected]
PTR No. 1999910/Baguio City/01-02-14
Roll of Atty. No. 81319/05-05-13
IBP OR No. 692876/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-99080/04-22-13

340
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION

I, BRUCE E. GRATUITO, of legal age, single, Filipino citizen, and

resident of 2 Aurora Hill, Baguio City, Philippines after having been duly
sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing answer;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession.

IN WITNESS WHEREOF, I have hereunto set my hand this 7 th day of

March 2014, at Baguio City, Philippines.

BRUCE E. GRATUITO
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 7th day of March 2014, by BRUCE E. GRATUITO, who is
personally known to me, who is the same person who personally signed
before me the foregoing document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
Doc. No. 89; PTR No. 1928374/Baguio City/01-02-14
Page No. 18; Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014 Commission Serial No. 01-NC-11 (R)

Copy Furnished: ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Petitioner
45 Hotel, Leonard Wood Road, Baguio City

341
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

ANGELICA Y. SANTIBANYEZ,
Petitioner,
-versus- Civil Case No.: 1003-R
FOR CANCELLATION OF TITLE
FACUNDO S. ALIPIN,
Respondent.
x------------------------------------x

ANSWER

COMES NOW, the respondent, through the undersigned counsel, in

answer to petitioner’s petition in the above-entitled case, and unto this
Honorable Court, most respectfully avers:

1. That he admits the allegations in paragraph 1 of the petition

regarding the personal circumstances and addresses of the parties;

2. That he admits the allegations in paragraphs 2 to 5 of the petition,

subject to qualifications and affirmative defenses herein alleged;

SPECIAL AND AFFIRMATIVE DEFENSES

1. That the parcel of land in question is a conjugal property of

respondent and his wife, Betty Diyosa;

2. That the court in Civil Case No. 123-R has not acquired jurisdiction
over the person of his wife because she was not a party litigant
therein;

3. That the money judgment in Civil Case No. 123 arose from the
personal transaction of petitioner in connection with the
accommodation surety she executed to secure payment of the loan
extended by respondent to the corporation, X, which loan did not
benefit the conjugal property, and accordingly said conjugal property
is exempt from execution to satisfy said personal judgment of
respondent;

4. That the execution sale is invalid because there was no valid levy
made by the sheriff, as at the time the court in Civil Case No. 123 has

342
not acquired jurisdiction over the person of respondent’s wife, who
was not a party litigant in said case;

5. That the market value of the land in question far exceeds the amount
of money judgment rendered in favor of petitioner, as to unfairly and
unjustly enrich petitioner;

6. That the Supreme Court ruled in Padilla, Jr. v. Phil. Producers’

Cooperative Marketing Assn., G.R. No. 141256, July 15, 2005:

“It is clear that PD 1529 provides the solution to

respondent’s quandary. The reasons behind the law
make a lot of sense; it provides due process to a
registered landowner (in this case the petitioner) and
prevents the fraudulent or mistaken conveyance of land,
the value of which may exceed the judgment obligation.
Petitioner contends that only his interest in the subject
lots, and not that of his wife who was not a party to the
suit, should have been subjected to execution, and he
should have had the opportunity to prove as much.”

WHEREFORE, the respondent respectfully prays that the petition be

dismissed.

Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 7th day of March 2014.

ATTY. MARIUS F. PONTMERCI

343
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION

I, FACUNDO S. ALIPIN, of legal age, single, Filipino citizen, and

resident of 3 Cabinet Hill, Baguio City, Philippines after having been duly
sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing answer;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession.

IN WITNESS WHEREOF, I have hereunto set my hand this 7 th day of

March 2014, at Baguio City, Philippines.

FACUNDO S. ALIPIN
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 7th day of March 2014, by FACUNDO S. ALIPIN, who is
personally known to me, who is the same person who personally signed
before me the foregoing document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
Doc. No. 90; PTR No. 1928374/Baguio City/01-02-14
Page No. 18; Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014 Commission Serial No. 01-NC-11 (R)

Copy Furnished: ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Petitioner
45 Hotel, Leonard Wood Road, Baguio City
344
345
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

ANGELICA Y. SANTIBANYEZ,
Petitioner,
-versus- Spec. Proc. No.: 1004-R
FOR WRIT OF HABEAS CORPUS
THE CHIEF OF POLICE OF BAGUIO CITY,
Respondent.
x------------------------------------------------x

ANSWER

COMES NOW, the respondent, through the undersigned counsel,

hereby makes due return of the Writ of Habeas Corpus issued by this
Honorable Court on March 6, 2014, and by way of answer to petitioner’s
petition in the above-entitled case, and unto this Honorable Court, most
respectfully avers:

1. That the herein respondent has Angelica Y. Santibanyez under

restraint in the police detention cell at the Baguio City Police
Department Headquarters, pending completion of and transfer to
the city jail now under reconstruction;

2. That the herein respondent caused the apprehension of the said

Angelica Y. Santibanyez on February 14, 2014, and the authority, the
true, and the whole story and cause of the said restraint of the said
person are the following, to wit:

a. That said party, Angelica Y. Santibanyez, was

apprehended and placed under police custody on
suspicion of having smuggled unlicensed firearm found
abandoned in an army bag at Army Navy, Session Road,
Baguio City, reported by a person to have been carried
by said Angelica Y. Santibayez;

b. That in the evening of February 14, 2014, while

investigation of the detainee was being conducted, the
Warrant Section of the Baguio City Police Department
discovered among its files a warrant for the arrest of
said Angelica Y. Santibanyez issued by the Regional Trial
Court of this city, Branch 2, in Criminal Case No. 1234-R
entitled “People of the Philippines vs. Angelica Y.

346
Santibanyez” for the crime of Assault upon a Person in
Authority;

c. That in the above-mentioned criminal case, the detainee

has not posted a bond for her provisional liberty up to
the present time;

d. That said detainee has been detained temporarily in the

police detention cell of the Baguio City Police
Department in view of the destruction through fire of
the Baguio City Jail;

e. That a copy of the warrant of arrest issued against

Angelica Y. Santibanyez in Criminal Case No. 1234
entitled “People of the Philippines vs. Angelica Y.
Santibanyez” commanding her apprehension, is hereto
attached as Annex “1” and made an integral part of this
return and answer.

WHEREFORE, the respondent respectfully prays that the petition be

dismissed.

Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 7th day of March 2014.

JUAN DE LA CRUZ JR.

Counsel for Respondent
Assistant City Prosecutor
Baguio City
MCLE Compliance No. IV-90210/04-22-13

347
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION

I, CRISOSTOMO R. IBARRA, of legal age, single, Filipino citizen, and

Chief of Police of the City of Baguio, Philippines after having been duly
sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing answer;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession;

4. I have attached a certified photocopy of the warrant of arrest issued

against Angelica Y. Santibanyez in Criminal Case No. 1234 entitled
“People of the Philippines vs. Angelica Y. Santibanyez” for the crime
of Assault upon a Person in Authority and marked as Annex “1”.

IN WITNESS WHEREOF, I have hereunto set my hand this 7 th day of

March 2014, at Baguio City, Philippines.

CRISOSTOMO R. IBARRA
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 7th day of March 2014, by CRISOSTOMO R. IBARRA.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Baguio City
MCLE Compliance No. IV-90210/04-22-13

348
CERTIFICATION OF LEGAL COUNSEL

I, JUAN DE LA CRUZ JR. Assistant City Prosecutor, Baguio City,

Philippines, after having been sworn to in accordance with law, do hereby
depose and say:

That I hereby certify that I have personally examined the affiant and
that I am fully satisfied that that affiant read and fully understood the
answer and executed the same freely and voluntarily; and

IN WITNESS WHEREOF, I have hereunto affixed my signature this 7 th

day of March 2014 in the City of Baguio, Philippines.

JUAN DE LA CRUZ JR.

Counsel for the State

SUBSCRIBED AND SWORN to before me this 7 th day of March 2014 in

the City of Baguio, Philippines.

ATTY. MARIUS F. PONTMERCI

Public Attorney IV
Public Attorney’s Office
Baguio City
MCLE Compliance No. IV-99080/04-22-13

Copy Furnished:

ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Petitioner
45 Hotel, Leonard Wood Road, Baguio City

349
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

NAOMI O. PASANLANGIT,
Petitioner,
-versus- Civil Case No.: 1005-R
FOR LEGAL SEPARATION
NATHANIEL Q. PASANLANGIT,
Respondent.
x------------------------------------x

ANSWER

COMES NOW, the respondent, through the undersigned counsel, in

answer to petitioner’s petition in the above-entitled case, and unto this
Honorable Court, most respectfully avers:

1. That he admits the allegations in paragraphs 1 and 2 of the petition;

2. That he denies the allegations in the rest of the petition, the truth
being that he was forced to leave the conjugal home because
petitioner committed acts which are also grounds for legal
separation, such as sexual infidelity, attempt on the life of
respondent and abusive conduct against their two children.

WHEREFORE, the respondent respectfully prays that the petition be

dismissed.

Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 7th day of March 2014.

ATTY. MARIUS F. PONTMERCI

350
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION

I, NATHANIEL Q. PASANLANGIT, of legal age, single, Filipino citizen,

and resident of 4 Dominican Hill, Baguio City, Philippines after having been
duly sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing answer;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession.

IN WITNESS WHEREOF, I have hereunto set my hand this 7 th day of

March 2014, at Baguio City, Philippines.

NATHANIEL Q. PASANLANGIT
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 7th day of March 2014, by NATHANIEL Q. PASANLANGIT,
who is personally known to me, who is the same person who personally
signed before me the foregoing document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
Doc. No. 91; PTR No. 1928374/Baguio City/01-02-14
Page No. 19; Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014 Commission Serial No. 01-NC-11 (R)

Copy Furnished: ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Petitioner
45 Hotel, Leonard Wood Road, Baguio City
351
352
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

INDIRA M. SINGH,
Plaintiff,
-versus- Civil Case No.: 1006-R
FOR COLLECTION OF SUM OF MONEY
MERRIAM W. DEFENSOR,
Defendant.
x------------------------------------x

ANSWER

COMES NOW, the defendant, through the undersigned counsel, in

answer to plaintiff’s complaint in the above-entitled case, and unto this
Honorable Court, most respectfully avers:

1. That defendant admits that portion of paragraph 1 of the complaint

regarding the names, residences and status of the parties, but denies
the rest thereof, for lack of knowledge sufficient to form a belief as to
the truth thereof;

2. That defendant denies under oath the execution and authentication

of the promissory note, Annex “A” of the complaint, the truth being
that the same is a forgery and that he did not execute nor sign the
same;

3. That assuming, arguendo, that the promissory is genuine and duly

executed; it was executed by a person on behalf of defendant,
without any authority from defendant;

4. That assuming, further, that the agent who signed the promissory
note on behalf is duly authorized to do so, the amount of
indebtedness therein stated represented payment of gambling losses
of defendant in favor of plaintiff; and

5. That assuming, finally, that the indebtedness shown in the

promissory note and the promissory note is legitimate, plaintiff has
been paid the amount thereof.

353
WHEREFORE, the defendant respectfully prays that the complaint be
dismissed.

Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 7th day of March 2014.

ATTY. MARIUS F. PONTMERCI

354
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION

I, MERRIAM W. DEFENSOR, of legal age, single, Filipino citizen, and

resident of 5 Quezon Hill, Baguio City, Philippines after having been duly
sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing answer;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession.

IN WITNESS WHEREOF, I have hereunto set my hand this 7 th day of

March 2014, at Baguio City, Philippines.

MERRIAM W. DEFENSOR
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 7th day of March 2014, by MERRIAM W. DEFENSOR, who is
personally known to me, who is the same person who personally signed
before me the foregoing document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
Doc. No. 92; PTR No. 1928374/Baguio City/01-02-14
Page No. 19; Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014 Commission Serial No. 01-NC-11 (R)

Copy Furnished: ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Plaintiff
45 Hotel, Leonard Wood Road, Baguio City

355
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

ISABELLA C. DE BASILAN,
Plaintiff,
-versus- Civil Case No.: 1007-R
FOR SPECIFIC PERFORMANCE
RYAN A. PERMISO,
Defendant.
x------------------------------------x

ANSWER

COMES NOW, the defendant, through the undersigned counsel, and

unto this Honorable Court, most respectfully avers:

1. That defendant pleads as permissive counterclaim that plaintiff and

defendant entered into a contract of sale of clothes on January 5,
2014, whereby defendant will deliver to plaintiff clothes worth
P2,000,000.00 and plaintiff would pay the same, upon delivery.”

2. That defendant having delivered said clothing materials on January

15, 2014 to plaintiff, the latter, notwithstanding repeated demands,
both oral and written, failed and refused to pay the same and still
fails and continues to refuse to pay, in breach of his obligation.

WHEREFORE, the defendant prays that the complaint be dismissed.

Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 7th day of March 2014.

ATTY. MARIUS F. PONTMERCI

356
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION

I, RYAN A. PERMISO, of legal age, single, Filipino citizen, and resident

of 6 Quirino Hill, Baguio City, Philippines after having been duly sworn in
accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing answer;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession.

IN WITNESS WHEREOF, I have hereunto set my hand this 7 th day of

March 2014, at Baguio City, Philippines.

RYAN A. PERMISO
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 7th day of March 2014, by RYAN A. PERMISO, who is
personally known to me, who is the same person who personally signed
before me the foregoing document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
Doc. No. 93; PTR No. 1928374/Baguio City/01-02-14
Page No. 19; Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014 Commission Serial No. 01-NC-11 (R)

Copy Furnished: ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Plaintiff
45 Hotel, Leonard Wood Road, Baguio City

357
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

INDIRA M. SINGH,
Plaintiff,
-versus- Civil Case No.: 1008-R
FOR COLLECTION OF SUM OF MONEY
DENNIS F. CONTRERA,
Defendant.
x------------------------------------x

ANSWER

COMES NOW, the defendant, through the undersigned counsel, in

answer to plaintiff’s complaint in the above-entitled case, and unto this
Honorable Court, most respectfully avers:

1. That defendant admits the averment in paragraphs 1, 2, and 3 of the

complaint;

2. That defendant specifically denies the allegation in paragraph 4 of

the complaint for lack of information and sufficient knowledge to
form a belief as to the truth thereof;

3. That defendant does not admit the allegations contained in

paragraphs 5 and 6 of the complaint as it lacks in form and substance
to support any cause of action against the defendant;

5. That defendant does not admit the allegation in paragraph 7 as it has

no basis in law and in facts;

SPECIAL AND AFFIRMATIVE DEFENSES

Defendants adopt and replead the foregoing allegations, and raise by

way of special and affirmative defenses the following:

358
1. That the complaint states no cause of action. The rule requires that
every action must be prosecuted or defended in the name of the real
party in interest. (Sec. 2, Rule 3 of 1997 Rules of Civil Procedure).
Only parties to a contract may sue or be sued upon that contract;

2. That in the instant case, it is plain in the verification/certification

appended to the complaint that A is suing in his own name by
stating, under oath, that he is the plaintiff in the case, not A&Z
Corporation. A is not a party to the contract, she has no cause of
action against herein defendant;

3. That A&Z Corporation has not authorized plaintiff to file the above-
entitled case;

COUNTERCLAIM

By way of counterclaim, defendant alleges:

That by virtue of this unwarranted suit initiated by plaintiff,

defendant was forced to engage counsel in the sum of ten thousand pesos
(Php10, 000.00).

WHEREFORE, the defendant respectfully prays that the complaint be

dismissed and be awarded the amount of ten thousand pesos
(Php10,000.00).

Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 7th day of March 2014.

ATTY. MARIUS F. PONTMERCI

359
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION

I, DENNIS F. CONTRERA, of legal age, single, Filipino citizen, and

resident of 7 Atok Trail, Baguio City, Philippines after having been duly
sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing answer;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession.

IN WITNESS WHEREOF, I have hereunto set my hand this 7 th day of

March 2014, at Baguio City, Philippines.

DENNIS F. CONTRERA
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 7th day of March 2014, by DENNIS F. CONTRERA, who is
personally known to me, who is the same person who personally signed
before me the foregoing document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
Doc. No. 94; PTR No. 1928374/Baguio City/01-02-14
Page No. 19; Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014 Commission Serial No. 01-NC-11 (R)

Copy Furnished: ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Plaintiff
45 Hotel, Leonard Wood Road, Baguio City

360
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

INDIRA M. SINGH,
Plaintiff,
-versus- Civil Case No.: 1009-R
FOR COLLECTION OF SUM OF MONEY
FRANCIS Y. PANUNUMPA,
Defendant.
x------------------------------------x

ANSWER

COMES NOW, the defendant, through the undersigned counsel, in

answer to plaintiff’s complaint in the above-entitled case, and unto this
Honorable Court, most respectfully and specifically denies under oath the
genuineness and due execution of the instrument, a copy of which is
attached to plaintiff’s complaint as Annex “A”, the truth being that his
signature thereon is forged and that he did not in fact sign the said
instrument.

WHEREFORE, the defendant respectfully prays that the complaint be

dismissed.

Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 7th day of March 2014.

ATTY. MARIUS F. PONTMERCI

361
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION

I, FRANCIS Y. PANUNUMPA, of legal age, single, Filipino citizen, and

resident of 8 Salud Mitra, Baguio City, Philippines after having been duly
sworn in accordance with law, depose and state that:

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

2. I have caused the preparation and the filing of the foregoing answer;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession.

IN WITNESS WHEREOF, I have hereunto set my hand this 7 th day of

March 2014, at Baguio City, Philippines.

FRANCIS Y. PANUNUMPA
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 7th day of March 2014, by FRANCIS Y. PANUNUMPA, who is
personally known to me, who is the same person who personally signed
before me the foregoing document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
Doc. No. 95; PTR No. 1928374/Baguio City/01-02-14
Page No. 19; Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014 Commission Serial No. 01-NC-11 (R)

Copy Furnished: ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Plaintiff
45 Hotel, Leonard Wood Road, Baguio City

362
363
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

JOHN M. PANINGIT,
Petitioner,
-versus- Civil Case No.: 1010-R
FOR PARTITION
JAMES M. PANINGIT,
Respondent,
JUDE M. PANINGIT,
Intervenor-Respondent.
x------------------------------------x

ANSWER-IN-INTERVENTION
COMES NOW, the intervenor-respondent, through the undersigned
counsel, in answer to petitioner’s petition in the above-entitled case, and
unto this Honorable Court, most respectfully avers:

1. That intervenor-respondent is one of the co-owners of the property,

subject matter of the petition for partition;

2. That intervenor-respondent admits that petitioner sold his undivided

share to respondent;

3. That intervenor-respondent sold his undivided share in the property

to petitioner as shown in the copy of the deed of sale attached as
Annex “A” in the petition;

4. That petitioner has not paid the full purchase of the property to
answering intervenor-respondent, as he has not paid the balance of
P2,000,000.00, which he refused and still continues to refuse to pay
the same, notwithstanding demands.

WHEREFORE, the intervenor-respondent respectfully prays that the

petition be dismissed.

Alternatively, petitioner be ordered to pay the balance of the

purchase price of P2,000,000.00 before the share of respondent may be
transferred to him, as purchaser of the undivided share.

364
Other just and equitable reliefs are likewise prayed for.

Baguio City, Philippines, this 7th day of March 2014.

ATTY. MARIUS F. PONTMERCI

365
366
REPUBLIC OF THE PHILIPPINES}
CITY OF BAGUIO } S.S.
x ---------------------------------------------- x

VERIFICATION

I, JUDE M. PANINGIT, of legal age, single, Filipino citizen, and

resident of 9 Military Cut-off, Baguio City, Philippines after having been duly
sworn in accordance with law, depose and state that:

1. I am the intervenor-respondent in the above-entitled case;

2. I have caused the preparation and the filing of the foregoing answer;

3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and on the basis of copies of
documents and records in my possession.

IN WITNESS WHEREOF, I have hereunto set my hand this 7 th day of

March 2014, at Baguio City, Philippines.

JUDE M. PANINGIT
Affiant

SUBSCRIBED AND SWORN to before me, in the City of Baguio,

Philippines, this 7th day of March 2014, by JUDE M. PANINGIT, who is
personally known to me, who is the same person who personally signed
before me the foregoing document.

ATTY. JUAN DE LA CRUZ JR.

Notary Public
Until December 31, 2014
100A Session Road, Baguio City
(074) 422-1234
[email protected]
Doc. No. 96; PTR No. 1928374/Baguio City/01-02-14
Page No. 20; Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/01-02-14
Book No. I; MCLE Compliance No. IV-90210/04-22-13
Series of 2014 Commission Serial No. 01-NC-11 (R)

Copy Furnished: ATTY. FERNANDO JOSE ALTAMIRANO DEL CASTILLO

Counsel for the Petitioner
45 Hotel, Leonard Wood Road, Baguio City

367
INFORMATIONS

368
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff, NPS Docket No.: 1001
-versus- Crim. Case No. _____
FOR ACTS OF LASCIVIOUSNESS
ADRIANO A. ALUGBATI,
Accused.
x-----------------------------------------x

INFORMATION

The undersigned, upon sworn complaint filed by the offended party,

copy of which is attached hereto, accuses ADRIANO A. ALUGBATI of the
crime of ACTS OF LASCIVIOUSNESS, committed as follows:

That on or about February 14, 2014, in the City of Baguio, Philippines,

and within the jurisdiction of this Honorable Court, the above-named
accused, actuated by lust, did then and there wilfully, unlawfully, and
feloniously commit acts of lasciviousness on the person of AGATONA A.
ALIMANGO by then and there embracing and kissing her and touching her
breasts and sexual organs, against her will and by means of force.

CONTRARY TO LAW.

Baguio City, Philippines, this 14th day of March 2014.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

APPROVED:

JEAN F. VALJEAN
City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

369
CERTIFICATION

This is to certify that a preliminary investigation has been conducted

in the above-entitled case, wherein the accused was given a chance to
appear and that on the basis of the evidence presented, there is reasonable
ground to believe that the offense complained of has been committed and
the accused is probably guilty thereof.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor

SUBSCRIBED AND SWORN to before me this 14 th day of March 2014

in the City of Baguio, Philippines.

ATTY. MARIUS F. PONTMERCI

Public Attorney IV
Roll of Atty. No. 81319/05-05-13
MCLE Compliance No. IV-99080/04-22-13

BAIL RECOMMENDED: P 20,000.00

RECEIVED AND FILED: March 14, 2014

MADELEINE L. FAUCHELEVENT
Clerk of Court IV

370
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff, NPS Docket No.: 1002
-versus- Crim. Case No. _____
FOR ADULTERY
BRIGIDA B. BATAW and
BRAULIO B. BAWANG,
Accused.
x-----------------------------------------x

INFORMATION

The undersigned accuses BRIGIDA B. BATAW and BRAULIO B.

BAWANG of the crime of ADULTERY, committed as follows:

That on or about February 14, 2014, prior to and subsequent thereto,

and continuously up to the present time, in the City of Baguio, Philippines,
and within the jurisdiction of this Honorable Court, the above-named
accused BRIGIDA B. BATAW being then united in lawful wedlock with
BERNARDO B. BATAW, wilfully, unlawfully, and feloniously lay with and
have carnal knowledge with her co-accused BRAULIO B. BAWANG, who in
turn, knowing that said BRIGIDA B. BATAW was a married woman, willfully,
unlawfully and feloniously lay with and have carnal knowledge with her.

CONTRARY TO LAW.

Baguio City, Philippines, this 14th day of March 2014.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

APPROVED:
JEAN F. VALJEAN
City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

371
CERTIFICATION

This is to certify that a preliminary investigation has been conducted

JUAN DE LA CRUZ JR.

Assistant City Prosecutor

SUBSCRIBED AND SWORN to before me this 14 th day of March 2014

in the City of Baguio, Philippines.

ATTY. MARIUS F. PONTMERCI

Public Attorney IV
Roll of Atty. No. 81319/05-05-13
MCLE Compliance No. IV-99080/04-22-13

BAIL RECOMMENDED: P 20,000.00

RECEIVED AND FILED: March 14, 2014

MADELEINE L. FAUCHELEVENT
Clerk of Court IV

372
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff, NPS Docket No.: 1003
-versus- Crim. Case No. _____
FOR CONCUBINAGE
CRISTIPULO C. CORTINA and
CANDIDA C. CURACHA,
Accused.
x-----------------------------------------x

INFORMATION

The undersigned accuses CRISTIPULO C. CORTINA and CANDIDA C.

CURACHA of the crime of CONCUBINAGE, committed as follows:

That on or about February 14, 2014, and continuously up to the

present time, in the City of Baguio, Philippines, and within the jurisdiction
of this Honorable Court, the above-named accused CRISTIPULO C.
CORTINA being then united in lawful wedlock with CRISANTA C. CORTINA,
wilfully, unlawfully, and feloniously cohabit with CANDIDA C. CURACHA, a
woman not his wife, living with her as husband and wife at 28 Queen of
Peace, Baguio City, and the said CANDIDA C. CURACHA, knowing
CRISTIPULO C. CORTINA to be married, unlawfully and feloniously cohabit
with CRISTIPULO C. CORTINA, living with him as husband and wife at 28
Queen of Peace, Baguio City.

CONTRARY TO LAW.

Baguio City, Philippines, this 14th day of March 2014.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

APPROVED:
JEAN F. VALJEAN
City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

373
CERTIFICATION

This is to certify that a preliminary investigation has been conducted

JUAN DE LA CRUZ JR.

Assistant City Prosecutor

SUBSCRIBED AND SWORN to before me this 14 th day of March 2014

in the City of Baguio, Philippines.

ATTY. MARIUS F. PONTMERCI

Public Attorney IV
Roll of Atty. No. 81319/05-05-13
MCLE Compliance No. IV-99080/04-22-13

BAIL RECOMMENDED: P 20,000.00

RECEIVED AND FILED: March 14, 2014

MADELEINE L. FAUCHELEVENT
Clerk of Court IV

374
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff, NPS Docket No.: 1004
-versus- Crim. Case No. _____
FOR RECKLESS IMPRUDENCE
DESIDERIO D. DINATUTO, RESULTING IN DAMAGE

Accused. TO PROPERTY
x-----------------------------------------x

INFORMATION

The undersigned accuses DESIDERIO D. DINATUTO of the crime of

RECKLESS IMPRUDENCE RESULTING IN DAMAGE TO PROPERTY, committed
as follows:

That on or about February 14, 2014, at about 10:00 PM, in the City of
Baguio, Philippines, and within the jurisdiction of this Honorable Court, the
above-named accused, did then and there, while driving his Sarao jeepney
with Plate No. AYD 567 under the influence of liquor and in a reckless and
imprudent manner, bumped the said jeepney into the residential house of
DELILAH D. DIMAANO situated at 72 Marcos Highway, Baguio City, thereby
causing damage to the front wall of the said residential house to the
damage and prejudice of its owner, DELILAH D. DIMAANO, in the amount of
P 500,000.00.

CONTRARY TO LAW.

Baguio City, Philippines, this 14th day of March 2014.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

APPROVED:
JEAN F. VALJEAN
City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

375
376
CERTIFICATION

This is to certify that a preliminary investigation has been conducted

JUAN DE LA CRUZ JR.

Assistant City Prosecutor

SUBSCRIBED AND SWORN to before me this 14 th day of March 2014

in the City of Baguio, Philippines.

ATTY. MARIUS F. PONTMERCI

Public Attorney IV
Roll of Atty. No. 81319/05-05-13
MCLE Compliance No. IV-99080/04-22-13

BAIL RECOMMENDED: P 20,000.00

RECEIVED AND FILED: March 14, 2014

MADELEINE L. FAUCHELEVENT
Clerk of Court IV

377
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff, NPS Docket No.: 1005
-versus- Crim. Case No. _____
FOR ESTAFA
ELEUTERIA E. ELEFANTE,
Accused.
x-----------------------------------------x

INFORMATION

The undersigned accuses ELEUTERIA E. ELEFANTE of the crime of

ESTAFA, committed as follows:

That on or about February 14, 2014, at about 5:00 PM, in the City of
Baguio, Philippines, and within the jurisdiction of this Honorable Court, the
above-named accused having received from ELISEO E. ESMERALDA a
variety of jewelry valued at P 1,000,000.00 for the purpose of selling the
same on commission, under the express obligation of holding the same in
trust for ELISEO E. ESMERALDA and to remit the proceeds of the sale of the
said goods, if sold, or to return the same in case of non-sale, within ten (10)
days from receipt thereof, the said accused did then and there, wilfully,
unlawfully, and feloniously, misappropriate and convert the said goods or
their proceeds to her personal use and benefit to the damage and prejudice
of ELISEO E. ESMERALDA in the amount of P 1,500,000.00.

CONTRARY TO LAW.

Baguio City, Philippines, this 14th day of March 2014.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

APPROVED:
JEAN F. VALJEAN
City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

378
CERTIFICATION

This is to certify that a preliminary investigation has been conducted

JUAN DE LA CRUZ JR.

Assistant City Prosecutor

SUBSCRIBED AND SWORN to before me this 14 th day of March 2014

in the City of Baguio, Philippines.

ATTY. MARIUS F. PONTMERCI

Public Attorney IV
Roll of Atty. No. 81319/05-05-13
MCLE Compliance No. IV-99080/04-22-13

BAIL RECOMMENDED: P 20,000.00

RECEIVED AND FILED: March 14, 2014

MADELEINE L. FAUCHELEVENT
Clerk of Court IV

379
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff, NPS Docket No.: 1006
-versus- Crim. Case No. _____
FOR ATTEMPTED HOMICIDE
FLORANTE F. FLEURDELIZ,
Accused.
x-----------------------------------------x

INFORMATION

The undersigned accuses FLORANTE F. FLEURDELIZ of the crime of

ATTEMPTED HOMICIDE, committed as follows:

That on or about February 14, 2014, in the City of Baguio, Philippines,

and within the jurisdiction of this Honorable Court, the above-named
accused, armed with a jungle knife, and with evident intent to kill, did then
and there willfully, unlawfully, and feloniously attack FERNANDO F.
FLERIDA, with his said weapon, missing said FERNANDO F. FLERIDA by only
a fraction of an inch, and would have continued his criminal act had not the
said FERNANDO F. FLERIDA successfully resisted him with the help of some
bystanders who responded to the cry for help.

CONTRARY TO LAW.

Baguio City, Philippines, this 14th day of March 2014.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

APPROVED:
JEAN F. VALJEAN
City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

380
CERTIFICATION

This is to certify that a preliminary investigation has been conducted

JUAN DE LA CRUZ JR.

Assistant City Prosecutor

SUBSCRIBED AND SWORN to before me this 14 th day of March 2014

in the City of Baguio, Philippines.

ATTY. MARIUS F. PONTMERCI

Public Attorney IV
Roll of Atty. No. 81319/05-05-13
MCLE Compliance No. IV-99080/04-22-13

BAIL RECOMMENDED: P 20,000.00

RECEIVED AND FILED: March 14, 2014

MADELEINE L. FAUCHELEVENT
Clerk of Court IV

381
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff, NPS Docket No.: 1007
-versus- Crim. Case No. _____
FOR FRUSTRATED HOMICIDE
GERMINIO G. GORGONIO,
Accused.
x-----------------------------------------x

INFORMATION

The undersigned accuses GERMINIO G. GORGONIO of the crime of

FRUSTRATED HOMICIDE, committed as follows:

That on or about February 14, 2014, in the City of Baguio, Philippines,

and within the jurisdiction of this Honorable Court, the above-named
accused, armed with a jungle knife, and with evident intent to kill, did then
and there willfully, unlawfully, and feloniously assault, attack and wound
one GREGORIO G. GATDULA inflicting mortal wounds in different parts of
his body, which would have directly caused the death of said GREGORIO G.
GATDULA, thus performing all acts of execution which would have
produced the crime of homicide as a consequence, but nevertheless did not
produce the same by reason of cause independent of his will, that is,
because of the timely medical assistance rendered on the said wounds.

CONTRARY TO LAW.

Baguio City, Philippines, this 14th day of March 2014.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

APPROVED:
JEAN F. VALJEAN
City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

382
CERTIFICATION

This is to certify that a preliminary investigation has been conducted

JUAN DE LA CRUZ JR.

Assistant City Prosecutor

SUBSCRIBED AND SWORN to before me this 14 th day of March 2014

in the City of Baguio, Philippines.

ATTY. MARIUS F. PONTMERCI

Public Attorney IV
Roll of Atty. No. 81319/05-05-13
MCLE Compliance No. IV-99080/04-22-13

BAIL RECOMMENDED: P 20,000.00

RECEIVED AND FILED: March 14, 2014

MADELEINE L. FAUCHELEVENT
Clerk of Court IV

383
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff, NPS Docket No.: 1008
-versus- Crim. Case No. _____
FOR LESS SERIOUS PHYSICAL
HERMINIGILDO H. HANDUSAY, INJURIES
Accused.
x-----------------------------------------x

INFORMATION

The undersigned accuses HERMINIGILDO H. HANDUSAY of the crime

of LESS SERIOUS PHYSICAL INJURIES, committed as follows:

That on or about February 14, 2014, at about 9:00 PM, in the City of
Baguio, Philippines, and within the jurisdiction of this Honorable Court, the
above-named accused did there and then willfully, unlawfully and
feloniously, and without justifiable cause therefor, attack, assault, and beat
one HARRY H. HORTALEZA, punching and kicking him in different parts of
his body, thereby inflicting on the latter wounds in different parts of his
body, which have required and will require medical attention for a period of
not less than ten (10) days but not more than (30) days, and have
incapacitated and will incapacitate him from labor for the same period of
time.

CONTRARY TO LAW.

Baguio City, Philippines, this 14th day of March 2014.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

APPROVED:
JEAN F. VALJEAN
City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

384
CERTIFICATION

This is to certify that a preliminary investigation has been conducted

JUAN DE LA CRUZ JR.

Assistant City Prosecutor

SUBSCRIBED AND SWORN to before me this 14 th day of March 2014

in the City of Baguio, Philippines.

ATTY. MARIUS F. PONTMERCI

Public Attorney IV
Roll of Atty. No. 81319/05-05-13
MCLE Compliance No. IV-99080/04-22-13

BAIL RECOMMENDED: P 20,000.00

RECEIVED AND FILED: March 14, 2014

MADELEINE L. FAUCHELEVENT
Clerk of Court IV

385
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff, NPS Docket No.: 1009
-versus- Crim. Case No. _____
FOR ILLEGAL DETENTION
ISIDORO I. INGRONE,
Accused.
x-----------------------------------------x

INFORMATION

The undersigned accuses ISIDORO I. INGRONE of the crime of

ILLEGAL DETENTION, committed as follows:

That within the period of February 14, 2014 to February 15, 2014, in
the City of Baguio, Philippines, and within the jurisdiction of this Honorable
Court, the above-named accused, actuated by lust, did then and there
wilfully, unlawfully, and feloniously did then and there, wilfully, unlawfully
and feloniously detain IRENE I. INDIGO in the following manner: When
IRENE I. INDIGO was visiting the accused at his house, the accused
forcefully tied her hands with wire on her back and covered her head with a
knapsack and coerced her to sign a document for the withdrawal of a civil
case; and as a consequence thereof said IRENE I. INDIGO was deprived of
her liberty against her will for a period aforestated.

CONTRARY TO LAW.

Baguio City, Philippines, this 14th day of March 2014.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

APPROVED:
JEAN F. VALJEAN
City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13
386
CERTIFICATION

This is to certify that a preliminary investigation has been conducted

JUAN DE LA CRUZ JR.

Assistant City Prosecutor

SUBSCRIBED AND SWORN to before me this 14 th day of March 2014

in the City of Baguio, Philippines.

ATTY. MARIUS F. PONTMERCI

Public Attorney IV
Roll of Atty. No. 81319/05-05-13
MCLE Compliance No. IV-99080/04-22-13

NO BAIL RECOMMENDED

RECEIVED AND FILED: March 14, 2014

MADELEINE L. FAUCHELEVENT
Clerk of Court IV

387
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff, NPS Docket No.: 1010
-versus- Crim. Case No. _____
FOR MALVERSATION
KINTERO K. KUNDOL,
Accused.
x-----------------------------------------x

INFORMATION

The undersigned accuses KINTERO K. KUNDOL of the crime of

MALVERSATION, committed as follows:

That on or about February 14, 2014, at about 5:00 PM, in the City of
Baguio, Philippines, and within the jurisdiction of this Honorable Court, the
above-named accused, then being the Treasurer of the City of Baguio, did
then and there wilfully, unlawfully, and feloniously, and with grave abuse of
confidence, misappropriate, take, withdraw, and convert for his own
personal use and benefit, the total amount of P 1,500,000.00 which are
public funds belonging to the City of Baguio, to the damage and prejudice
of the public interest.

CONTRARY TO LAW.

Baguio City, Philippines, this 14th day of March 2014.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

APPROVED:
JEAN F. VALJEAN
City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

388
CERTIFICATION

This is to certify that a preliminary investigation has been conducted

JUAN DE LA CRUZ JR.

Assistant City Prosecutor

SUBSCRIBED AND SWORN to before me this 14 th day of March 2014

in the City of Baguio, Philippines.

ATTY. MARIUS F. PONTMERCI

Public Attorney IV
Roll of Atty. No. 81319/05-05-13
MCLE Compliance No. IV-99080/04-22-13

NO BAIL RECOMMENDED

RECEIVED AND FILED: March 14, 2014

MADELEINE L. FAUCHELEVENT
Clerk of Court IV

389
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff, NPS Docket No.: 1011
-versus- Crim. Case No. _____
FOR PARRICIDE
LIZARDO L. LABANOS,
Accused.
x-----------------------------------------x

INFORMATION

The undersigned accuses LIZARDO L. LABANOS of the crime of

PARRICIDE, committed as follows:

That on or about February 14, 2014, at about 10:00 AM, in the City of
Baguio, Philippines, and within the jurisdiction of this Honorable Court, the
above-named accused, motivated by extreme jealously, and while armed
with a .38 caliber pistol, did then wilfully, unlawfully, and feloniously,
suddenly, unexpectedly, and treacherously fired several shots at LIBRADA L.
LABANOS, his lawfully wedded wife, which caused the instantaneous death
of his said wife while she was walking along Session Road with her friend,
LARRY L. LUYA.

CONTRARY TO LAW.

Baguio City, Philippines, this 14th day of March 2014.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

APPROVED:
JEAN F. VALJEAN
City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

390
CERTIFICATION

This is to certify that a preliminary investigation has been conducted

JUAN DE LA CRUZ JR.

Assistant City Prosecutor

SUBSCRIBED AND SWORN to before me this 14 th day of March 2014

in the City of Baguio, Philippines.

ATTY. MARIUS F. PONTMERCI

Public Attorney IV
Roll of Atty. No. 81319/05-05-13
MCLE Compliance No. IV-99080/04-22-13

NO BAIL RECOMMENDED

RECEIVED AND FILED: March 14, 2014

MADELEINE L. FAUCHELEVENT
Clerk of Court IV

391
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff, NPS Docket No.: 1012
-versus- Crim. Case No. _____
FOR RAPE
MERCUDITO M. MUSTASA,
Accused.
x-----------------------------------------x

INFORMATION

The undersigned, upon sworn complaint filed by the offended party,

copy of which is attached hereto, accuses MERCUDITO M. MUSTASA of the
crime of RAPE, committed as follows:

That on or about February 14, 2014, in the City of Baguio, Philippines,

and within the jurisdiction of this Honorable Court, the above-named
accused, actuated by lust, did then and there wilfully, unlawfully, and
feloniously, had carnal knowledge against her will and by means of force,
violence, intimidation, and threats on the person of MELISSA M. MERCADO.

CONTRARY TO LAW.

Baguio City, Philippines, this 14th day of March 2014.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

APPROVED:

JEAN F. VALJEAN
City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

392
CERTIFICATION

This is to certify that a preliminary investigation has been conducted

JUAN DE LA CRUZ JR.

Assistant City Prosecutor

SUBSCRIBED AND SWORN to before me this 14 th day of March 2014

in the City of Baguio, Philippines.

ATTY. MARIUS F. PONTMERCI

Public Attorney IV
Roll of Atty. No. 81319/05-05-13
MCLE Compliance No. IV-99080/04-22-13

NO BAIL RECOMMENDED

RECEIVED AND FILED: March 14, 2014

MADELEINE L. FAUCHELEVENT
Clerk of Court IV

393
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff, NPS Docket No.: 1013
-versus- Crim. Case No. _____
FOR ROBBERY
NICASIO N. NAGOYO,
Accused.
x-----------------------------------------x

INFORMATION

The undersigned accuses NICASIO N. NAGOYO of the crime of

ROBBERY, committed as follows:

That on or about February 14, 2014, at about 11:00 PM, in the City of
Baguio, Philippines, and within the jurisdiction of this Honorable Court, the
above-named accused did then and there, willfully, unlawfully, feloniously,
with intent to gain and with intimidation upon the person of NATHANIEL N.
NATANAEL by threatening him with a .38 caliber pistol, took and carry away
the latter's SONY XPERIA Z mobile phone valued at P 30,000.00, Philippine
Currency, to the to the damage and prejudice of the said NATHANIEL N.
NATANAEL in the said amount.

CONTRARY TO LAW.

Baguio City, Philippines, this 14th day of March 2014.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

APPROVED:
JEAN F. VALJEAN
City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

394
CERTIFICATION

This is to certify that a preliminary investigation has been conducted

JUAN DE LA CRUZ JR.

Assistant City Prosecutor

SUBSCRIBED AND SWORN to before me this 14 th day of March 2014

in the City of Baguio, Philippines.

ATTY. MARIUS F. PONTMERCI

Public Attorney IV
Roll of Atty. No. 81319/05-05-13
MCLE Compliance No. IV-99080/04-22-13

BAIL RECOMMENDED: P 20,000.00

RECEIVED AND FILED: March 14, 2014

MADELEINE L. FAUCHELEVENT
Clerk of Court IV

395
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff, NPS Docket No.: 1014
-versus- Crim. Case No. _____
FOR SEDUCTION
PRIMITIVO P. PATOLA,
Accused.
x-----------------------------------------x

INFORMATION

The undersigned, upon sworn complaint filed by the offended party,

copy of which is attached hereto, accuses PRIMITIVO P. PATOLA of the
crime of SEDUCTION, committed as follows:

That on or about February 14, 2014, at about 11:00 PM, in the City of
Baguio, Philippines, and within the jurisdiction of this Honorable Court, the
above-named accused did then and there, willfully, unlawfully, feloniously,
and by means of deceit, have sexual intercourse with PRECIOUS P.
PASTILLES, an unmarried girl over twelve but under eighteen years of age.

CONTRARY TO LAW.

Baguio City, Philippines, this 14th day of March 2014.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

APPROVED:

JEAN F. VALJEAN
City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

396
CERTIFICATION

This is to certify that a preliminary investigation has been conducted

JUAN DE LA CRUZ JR.

Assistant City Prosecutor

SUBSCRIBED AND SWORN to before me this 14 th day of March 2014

in the City of Baguio, Philippines.

ATTY. MARIUS F. PONTMERCI

Public Attorney IV
Roll of Atty. No. 81319/05-05-13
MCLE Compliance No. IV-99080/04-22-13

BAIL RECOMMENDED: P 20,000.00

RECEIVED AND FILED: March 14, 2014

MADELEINE L. FAUCHELEVENT
Clerk of Court IV

397
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff, NPS Docket No.: 1015
-versus- Crim. Case No. _____
FOR VIOLATION OF R.A. 9262
SUBAS S. SIBUYAS,
Accused.
x-----------------------------------------x

INFORMATION

The undersigned accuses SUBAS S. SIBUYAS of VIOLATION OF R.A.

9262 (ANTI VIOLENCE AGAINST WOMEN AND THEIR CHILDREN ACT),
committed as follows:

That on or about February 14, 2014, in the City of Baguio, Philippines,

and within the jurisdiction of this Honorable Court, the above-named
accused did then and there, willfully, unlawfully, feloniously, and with
intent to manipulate the conduct of his wife and children to beg money
from him, commit acts of economic abuse against his wife, SILVANA S.
SIBUYAS and their minor children, by refusing to give them any financial
support, which is legally due them under the law, to their damage and
prejudice.

CONTRARY to Section 5 par. e(2) in relation to Sec 3 sub. par. d, of

R.A. 9262 (Economic Abuse).

Baguio City, Philippines, this 14th day of March 2014.

JUAN DE LA CRUZ JR.

Assistant City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

APPROVED:
JEAN F. VALJEAN
City Prosecutor
Roll of Atty. No. 67548/05-18-10
MCLE Compliance No. IV-90210/04-22-13

398
CERTIFICATION

This is to certify that a preliminary investigation has been conducted

JUAN DE LA CRUZ JR.

Assistant City Prosecutor

SUBSCRIBED AND SWORN to before me this 14 th day of March 2014

in the City of Baguio, Philippines.

ATTY. MARIUS F. PONTMERCI

Public Attorney IV
Roll of Atty. No. 81319/05-05-13
MCLE Compliance No. IV-99080/04-22-13

BAIL RECOMMENDED: P 20,000.00

RECEIVED AND FILED: March 14, 2014

MADELEINE L. FAUCHELEVENT
Clerk of Court IV

399

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