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REPUBLIC OF THE PHILIPPINES

Office of the Bar Confidant


SUPREME COURT
Manila
MANUEL N. CAMACHO,
Complainant,
-versusNo. ______

Admin. Matter

ATTY. ANTERO M. SISON,


ATTY.
ENRIQUE
DIMAANO, ATTY. IBARO
B. RELAMIDA,
Respondents.
x---------------------x

COMPLAINT
COMPLAINANT respectfully files this administrative
complaint against respondents and states that:
PREFATORY STATEMENT
Complainant comes before the Honorable Supreme
Court to file this complaint seeking perpetual disbarment
against three private lawyers who connived with judges and
public prosecutors in maliciously filing various harassment
cases against herein complainant and in delaying the
execution of a valid, final, and executory order previously
issued in complainants favor.
PARTIES

Complainant is a Filipino of legal age, a practicing


lawyer with offices at Suite 1605 Corporate 88 Center, Valero
corner Sedeno Streets, Salcedo Village, Makati City, where
he may be served with the processes of the Honorable
Supreme Court.
Respondents Attys. Antero M. Sison, Jr., Enrique
Dimaano, and Ibaro B. Relamida are private lawyers and/or
officers/members of the board of Marsman Drysdale Organic
Farm, Inc./Marsman Drysdale Agribusiness Holdings, Inc.,
with offices at the 45th Floor, 8767 Paseo de Roxas Ave.,
Makati City, Philippines, where they may be served with
summons and other processes of the Honorable Court.
GROUNDS FOR DISBARMENT AND DISMISSAL
Complainant files this administrative complaint for
perpetual disbarment against the respondents for violation
of Section 3(e), Republic Act No. 3019 for connived with
judges and public prosecutors in having caused undue injury
to the complainant as the accused in Criminal Case No. 131688, now pending before RTC Branch 146, Makati City, and
for again conniving with judges in causing the delay of the
execution of valid orders in Civil Case No. 05-655 which were
issued in complainants favor.
ATTACHMENTS TO THIS COMPLAINT
The following certified copies and/or duplicate original
copies of pertinent documents are attached in support of this
complaint:

Description

Attached As

ORDER dated 20 September 2013


issued by JUDGE ENCARNACION
JAJA G. MOYA, Presiding Judge, RTC
Branch 146, Makati City, in Criminal
Case No. 13-1688 (4 pages)

Annex A

INFORMATION filed on 18 July 2013


with the Makati RTC in Criminal
Case No. 13-1688, prepared by
SENIOR ASST. CITY PROSECUTOR
HANNIBAL V. SANTILLAN (2 pages)

Annex B

MOTION TO QUASH INFORMATION in


Crim. Case No. 13-1688, filed on 12
August 2013 (6 pages)

Annex C

COMMENT/OPPOSITION TO MOTION TO
QUASH INFORMATION in Crim. Case
No. 13-1688, dated 16 August 2013
(7 pages)

Annex D

REPLY TO COMMENT / OPPOSITION TO


MOTION TO QUASH INFORMATION
in Crim. Case No. 13-1688, filed on
30 August 2013 (4 pages)

Annex E

ORDER dated 6 July 2012 issued by


Judge Benjamin Pozon of Makati RTC
Branch 139 in Civil Case NO. 05-655 (6
pages)

Annex F

AGREEMENT dated 30 June 2005,


regarding Atty. Camachos attorneys
fees from Marsman Drysdale in Civil
Case No. 05-655

Annex G

LETTER FROM ATTY. ANTERO SISON


dated 24 August 2011, in connection
with Civil Case No. 05-655

Annex H

ORDER dated 12 April 2012, in Civil


Case No. 05-655

Annex I

CHECKS payable to Atty. Enrique


Dimaano, submitted as evidence in
Civil Case No. 05-655

Annex J
and series

PLUNDER COMPLAINT against Atty.


Antero Sison, Jr., et al. filed before the
Office of the Ombudsman on June 21,
2012

Annex K

WRITE-UP by Vic Agustin in the


Philippine Daily Inquirer regarding the
plunder subject of the complaint
above-mentioned

Annex L

ORDER dated 5 June 2013 in Civil Case


No. 05-655

Annex M

BACKGROUND FACTS
1. In June 2005, Marsman Drysdale Agribusiness Holdings,
Inc. and Marsman Drysdale Organic Farms, Inc. filed a
complaint for recovery of sum of money (P14.86
million) against Union Insurance Society of Canton, Ltd.
(now Paramount Life & General Insurance Corp.) on the
ground of breach of contract. Herein complainant was
then Marsmans legal counsel in that case.
2. After trial, the court (RTC Branch 139, Makati City)
rendered a decision in favor of Marsman and against
Union Insurance. In compliance of said Decision, and

upon withdrawal of the appeal filed by Union, through


herein complainants efforts Marsman and Union
Insurance agreed to settle the claim in order to avoid
further litigation. Marsman agreed to accept P15 million
constituting full satisfaction of the trial courts
judgment, and soon thereafter received that amount
from Union Insurance.
3. It is noteworthy that while negotiations were going on
for the settlement of the P15 million from Union
Insurance, herein respondent Atty. Sison, an executive
officer of Marsman, vehemently opposed settlement
and wanted to pursue the case in court because he
wanted to claim a higher amount from Union Insurance.
Complainant, as counsel of record for Marsman in the
case, advised against going to trial because the case in
fact had nothing to stand on, as the complaint for
insurance claim had been filed out of time. But Atty.
Sison told complainant, I can pay everybodyeven all
the judges. He uttered these words in the presence of
herein complainant and respondent Atty. Dimaano.
4. Nevertheless, Marsman accepted the settlement.
Between Marsman and herein complainant as their
legal counsel, they had previously agreed to the
payment of attorneys fees equivalent to twenty
percent (20%) of the judgment award. A written
agreement to this effect was executed on June 30,
2005, a copy of which is attached as Annex G.
5. Subsequently however, respondent Atty. Sison refused
to honor the June 30, 2005 agreement regarding
attorneys fees, and offered complainant only P200,000,
as shown in Atty. Sisons letter dated August 24, 2011,
a copy of which is attached as Annex H.
6. Complainant did not accept the offer and instead filed a
motion in the trial court to determine the correct
attorneys fees.

7. The court, in an Order dated April 12, 2012 (copy


attached as Annex I), ruled in complainants favor. Said
Order stated that complainant was indeed entitled to
20% of the judgment award of P15 million, and
thereupon ordered the payment of said amount, minus
P300,000 that complainant had already received as
acceptance fee. But the court, in said Order, also
improperly deducted other sums allegedly received by
complainant from Marsman, leaving a balance of only
P1,111,740. Thus, complainant filed a motion for
reconsideration, alleging that he was entitled to the full
amount of attorneys fees of P3 million, deducting only
the P300,000 acceptance fee, and denying receipt of all
other sums alleged by Marsman.
8. Marsman likewise filed a motion for reconsideration of
the April 12, 2012 Order, falsely alleging that it had
already turned over to herein complainant P1.288
million in payments.
9. Upon review of both motions, the court, on July 6, 2012,
issued an Order (Annex F) in complainants favor,
modifying its April 12, 2012 Order and reinstating
P1,888,260 to the judgment award, stating that it was
part of the complainants attorneys fees due him.
10.
The court then ordered Marsman to pay herein
complainant his P3 million attorneys fee, deducting
only the P300,000 acceptance fee, for a balance of P2.7
million. In the same July 6, 2012 Order (Annex F), the
court stated that Marsman has not shown proof that
complainant received the other amounts alleged by
them to have already been paid to complainant.
11.

The July 6, 2013 Order further stated:

Plaintiffs claim of irregularity on the part of Atty.


Camacho is a bare and unsubstantiated allegation,
which will not justify the denial of the claim of
attorneys fee of Atty. Camacho. Plaintiff submitted no
proof to substantiate the claim of irregularity on the

part
of
Atty. Camacho, as such, the Court is not inclined to give
credence on such allegation.
12.
Marsman received the July 6, 2012 Order on July
18, 2012 and did not file any other motion or
manifestation in reference thereto. Thus, said Order
became final and executory.
13.
Despite the courts authoritative ruling on the
matter which has become final, respondent Atty. Sison
continued to insist that Marsman had already paid
complainant P1.288 million, and accused him of using
the money to bribe the trial judge in that case (Judge
Benjamin Pozon, RTC Branch 139, Makati), and for
paying spurious docket fees. Thus, on July 11, 2012,
complainant filed a libel case against respondent Atty.
Sison and other officers and members of the board of
Marsman.
14.
In a ploy to have complainant withdraw the libel
case, Marsman, through its in-house legal counsel,
herein respondent Atty. Dimaano, offered complainant a
compromise wherein they would pay complainant P1.5
million. They paired the monetary offer with the
assurance that complainant would continue to act as
counsel for respondent corporations. This, in exchange
for complainants withdrawal of the libel complaint
against them. Complainant agreed to withdraw the libel
complaint, except as to respondent Atty. Sison.
Complainant then signed a quitclaim to that effect, but
still retaining Atty. Sison as respondent in the libel case.
15.
Thus, Marsman and complainant filed an Urgent
Joint Motion with the trial court for the issuance of an
order approving their compromise agreement. Said
motion was thereafter granted by the court, and
complainant duly withdrew the libel case that he had
filed against Marsmans executives and board
members, except as to respondent Atty. Sison.

16.
Shortly thereafter, on September 10, 2012, Atty.
Sison, with the full approval and authority of the other
officers and board members of Marsman, filed an estafa
case against complainant, insisting that they had
already previously paid over to the latter the total sum
of P1.288 million, which was allegedly used as bribe
money for Judge Pozon in Civil Case No. 05-655 and for
spurious docket fees. The Information in the estafa case
Criminal Case No. 13-1688), which was prepared and
filed by herein respondent public prosecutor Hannibal
Santillan, is attached as Annex B.
17.
The allegations of estafa however are utterly
baseless, as complainant had already shown evidence
proving that the P1.228 million disbursed by Marsman
was not received by the complainant but by Marsmans
own in-house legal counsel, herein respondent Atty.
Dimaano. This evidence was accepted by the court in
Civil Case No. 05-655 and was in fact the basis for its
July 6, 2013 Order.
18.
In the documentary evidence submitted by
respondent Atty. Sison himself before the prosecutors
office during the filing of the estafa case against herein
complainant, the subject checks were clearly payable to
respondent Atty. Enrique Dimaano (copies of the checks
are hereto attached as Annexes J and series). Yet Atty.
Dimaano, in utter bad faith, executed an affidavit in the
estafa case pinning the blame on herein complainant.
19.
To understand Atty. Sisons vindictive actuations
toward complainant, it is necessary to explain that
sometime in late 2012, complainant filed a plunder
complaint before the Office of the Ombudsman against
herein respondent Atty. Antero M. Sison, Jr. along with
some government officials. That case involved the
improper payment of U.S. $4.8 million by the Philippine
government to a foreign claimant (Fidelity Partners)
through the machinations of respondent Atty. Sison who
had connections with high officials of the government of
then president Gloria Macapagal-Arroyo and her
husband Atty. Mike Arroyo. Respondent Atty. Sison
pocketed more than $3 million of that amount and paid

only $1.5 million to Fidelity Partners. Herein


complainant was then the principal counsel in the case
filed by Fidelity Partners against the Philippine
government (then pending before the Supreme Court)
but herein respondent Atty. Sison manipulated matters
to get complainant out of the way. A copy of the
plunder complaint against Atty. Sison, et al. with its
attachments is hereto attached as Annex K.
20.
The case involving the dirty work that Atty. Sison
did for Fidelity Partners in bilking millions of dollars from
the Philippine Government is well-known and has been
widely publicized. An informative write-up written by
columnist Vic Agustin for the Philippine Daily Inquirer
tells of these machinations that led to the loss of U.S.
$4.8 million in public funds. A copy of the write-up is
attached as Annex L.
21.
With the malicious filing of the estafa case,
complainant moved for the recall of the Order dated
September 14, 2012 in Civil Case No. 05-655, which
approved his compromise agreement with Marsman
regarding his attorneys fees. Instead, complainant
asked for the immediate issuance of a writ of execution
of the Order dated July 6, 2012 which ordered Marsman
to pay complainant P2.7 million in attorneys fees.
22.
In asking for the nullification of the compromise
agreement, complainant cited Article 2041 of the Civil
Code and argued that the filing of the estafa case
against him has voided the compromise agreement
because the filing of the estafa case was an act which
constituted an open repudiation of the compromise
agreement by the reneging party.
23.
On June 5, 2013, the court in Civil Case No. 05-655
issued an Order (copy attached as Annex M) granting
complainants motion to nullify the compromise
agreement, stating the following:

the court is inclined to rule that the


plaintiff (herein private respondents) reneged
on its obligation under the compromise
agreement that was approved by the court
xxx
As correctly pointed out by Atty. Camacho,
the plaintiff has openly repudiated the
compromise agreement when Atty. Antero
Sison, Jr. filed a complaint for estafa against
Atty. Camacho in order to collect the said
amount of P1,288,260
xxx
Therefore, as correctly invoked by Att.
Camacho in his memorandum, the quitclaim
signed by Atty. Camacho became inoperative
and without any legal effect, pursuant to
Article 2041 of the New Civil Code and the
ruling of the Supreme Court in the case of
Miguel vs. Montanez citing Leonor vs. Sycip
xxx
Accordingly, the Order dated 14 September
2012 treating the plaintiffs urgent motion for
approval of the compromise agreement as a
motion to dismiss is hereby recalled and
reconsidered, and let a writ of execution be
instead issued directing the plaintiff to pay
Atty. Camacho the sum of P1.2 million
representing the balance of his attorneys
fees.
(Emphases supplied)
24.
Thus, on 12 August 2013, complainant filed a
motion to quash the Information in Crim. Case No. 131688, arguing that the controversy over the amount
subject of the estafa case had already been threshed
out in Civil Case No. 05-655, which findings have
become final and executory. Complainant argued that

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res judicata has set in, which precludes the re-litigation


of a particular fact or issues in another action between
the same parties on a different claim or cause of
action.1 A copy of the Motion to Quash is attached as
Annex C of this complaint.
25.
Public prosecutor Leilia Llanes in Crim. Case No.
13-1688 filed a comment/opposition to the motion to
quash, arguing that not all of the requisites of red
judicata are present and that the estafa case has no
relation to Civil Case No. 05-655. A copy of the
Comment/Opposition is attached as Annex D of this
complaint.
26.
Complainant then filed a reply to the opposition,
and argued that Civil Case No. 05-655 is pivotal to the
estafa case because the two Orders in Civil Case No.
05-655 dated July 6, 2012 and June 5, 2013 settled with
finality the matter of the amount subject of the estafa
case, in that it is the very same amount that has been
adjudicated to be part of herein complainants
attorneys fees and therefore due and demandable by
him.
27.
Complainant in his reply further stated that: If in
the civil case, which requires only a preponderance of
evidence, the accused was favored by not just one but
two Orders adjudging him to be blameless and in fact
entitled to the amount involved, what foundation then
is the prosecution building this criminal case on, which
requires the heavier burden of proof beyond reasonable
doubt?
28.
Nonetheless, despite the obvious lack of basis of
the criminal complaint and the Information for estafa,
Judge Moya, in the Order dated 20 September 2013
(Annex A of this complaint), denied the motion to
quash information reasoning out that res judicata is not
a ground to quash Information and that the termination
of a civil case will not bar a criminal case.
1

Lopez vs, Reyes, G.R. No. L-29498, 31 march 1977, 76 SCRA 179.

11

DISCUSSION
As complainant has repeatedly stressed in his pleadings
and various motions filed before the courts concerned, res
judicata is a doctrine that encompasses all cases where
there is identity of the parties and the facts.
Res judicata is defined as "a matter adjudged; a thing
judicially acted upon or decided; a thing or matter settled by
judgment. It also refers to the rule that a final judgment or
decree on the merits by a court of competent
jurisdiction is conclusive of the rights of the parties
or their privies in all later suits on points and matters
determined in the former suit."2 (Emphasis supplied)
According to case law, this doctrine is a rule which
pervades every well-regulated system of jurisprudence and
is founded upon the following precepts of common law,
namely: (1) public policy and necessity, which makes it to
the interest of the State that there should be an end to
litigation, and (2) the hardship on the individual that he
should be vexed twice for the same cause. A contrary
doctrine would subject the public peace and quiet to the will
and neglect of individuals and prefer the gratification of the
litigious disposition on the part of suitors to the preservation
of the public tranquility and happiness. 3
In this jurisdiction, the concept of res judicata is
embodied in Section 47 (b) and (c) of Rule 39 of the Rules of
Court, thus:
SEC. 47. Effect of judgments or final orders. The
effect of a judgment or final order rendered by a
court of the Philippines, having jurisdiction to
pronounce the judgment or final order, may be as
follows:
2

Gutierrez v. CA, G.R. No. 82475, January 28, 1991, 193 SCRA 437.

Cruz v. CA, G.R. No. 164797, February 13, 2006, 482 SCRA 379, quoting Heirs of the Late Faustina
Adalid v. Court of Appeals, G.R. No. 122202, May 26, 2005, 459 SCRA 27.

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(a) In case of a judgment or final order against a


specific thing or in respect to the probate of a will,
or the administration of the estate of a deceased
person, or in respect to the personal, political, or
legal condition or status of a particular person or
his relationship to another, the judgment or final
order is conclusive upon the title to the thing, the
will or administration, or the condition, status or
relationship of the person; however, the probate of
a will or granting of letters of administration shall
only be prima facie evidence of the death of the
testator or intestate;
(b) In other cases, the judgment or final order is,
with respect to the matter directly adjudged or as
to any other matter that could have been raised in
relation thereto, conclusive between the parties
and their successors in interest by title
subsequent to the commencement of the action or
special proceeding, litigating for the same thing
and under the same title and in the same
capacity; and,
(c) In any other litigation between the same
parties or their successors in interest, that
only is deemed to have been adjudged in a
former judgment or final order which
appears upon its face to have been so
adjudged, or which was actually and
necessarily included therein or necessary
thereto.
(Emphasis supplied)
The above provision outlines the dual aspect of res
judicata.4 Section 47 (b) pertains to it in its concept as "bar
by prior judgment" or "estoppel by verdict," which is the
effect of a judgment as a bar to the prosecution of a second
action upon the same claim, demand or cause of action.
On the other hand, Section 47 (c) pertains to res
judicata in its concept as "conclusiveness of judgment" or
otherwise known as the rule of auter action pendant
4

NHA v. Baello, G.R. No. 143230, August 30, 2004, 437 SCRA 86.

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which ordains that issues actually and directly resolved in a


former suit cannot again be raised in any future case
between the same parties involving a different cause of
action.5
The background of this case clearly and effectively
precludes a charge of estafa.
The Information reads in its pertinent portion:
On March 4, 2011 and subsequent thereto,
in the city of Makati, Philippines, accused,
with intent to gain and with abuse of
confidence, did and there wilfully, unlawfully
and
feloniously
defraud
complainant
Marsman Drysdale Agribusiness Holdings,
Inc., Marsman Drysdale Organic Farm, Inc.,
represented by Atty. Enrique Dimaano in the
following manner, to wit: the said accused
who was then counsel of complainant fees
(sic) for Civil Case No. 05-655, pending
before RTC Branch 139,Makati in the amount
of
Php
1,288,260,
entitled
Marsman
Drysdale
Agribusiness
Holdings,
Inc.
Marsman Drysdale Organic Farm, Inc.,
Plaintiff vs. Union Insurance Society of
Canton, Ltd. (now Paramount Life & General
Insurance Corporation), Defendant, but
accused once in possession of the said
amount misappropriated, misapplied, and
converted the same, to the damage and
prejudice of the complainant in the amount
of P1,288,260.
Note however that, in the Order dated July 6, 2012 in
Civil Case No. 05-655 (Annex F), the trial Court there ruled
that herein complainant (therein counsel for the
respondents) is entitled to receive from Marsman the
amount of P3 million as his rightful attorneys fees,
deducting only the P300,000 that the accused had already
received as acceptance fee. In said Order, the Court said
5

Spouses Rasdas v. Estenor, G.R. No. 157605, December 13, 2005, 477 SCRA 538.

14

herein respondents have not shown proof that herein


complainant had received the other amounts alleged by
them to have already been paid to the latter, and that
includes the P1,288,260 subject of the estafa case. In said
Order, the Court said:
As correctly stated by Atty. Camacho, the
deduction of P1,888,260.00, as allegedly for
amounts already received by him, have not
been proven by plaintiff to have been
actually received by the said counsel, except
for the P300,000.00 by way of acceptance
fee. Aside from the bare allegation of plaintiff
that Atty. Camacho had received the
amounts deducted by the Court, it presented
no proof to substantiate the same. The
burden to prove that the said amounts were
received by Atty. Camacho lies on the
plaintiff, and its failure to prove its allegation
leaves this Court without recourse but to
reinstate the amount deducted, except the
acceptance fee of P300,000.00 which is
reflected on the retainer agreement.
As complainant has repeatedly stressed before the
courts, the above ruling has never been reversed, modified,
nullified, or set aside, and it has never been challenged on
appeal. Thus, it has become the law of the case as between
the accused and the private complainants in Crim. Case No.
13-1688 with respect to the controversy at issue.
Judge Moya must surely know these legal principles
because she is a judge of the Regional Trial Court. But even
though herein complainant keeps belaboring the point that,
since the amount of P1,288,260 subject of the estafa case
has already been ruled by a court of competent jurisdiction
to be due him as his attorneys fees, and that there can be
no estafa because he is entitled to that money on his own
right, Judge Moya, with manifest partiality and evident bad
faith, denied the motion to quash on shaky reasoning. For
this, complainant charged Judge Moya in another case with:

15

1. Gross ignorance of the law;


2. Violation of Article 206, Revised Penal Code for
knowingly rendering unjust and interlocutory orders;
6

3. Violation of Section 3(e) of Republic Act No. 3019


(The Anti-Graft and Corrupt Practices Act) for having
caused undue injury to herein complainant and
giving unwarranted benefits to the adverse parties in
Criminal Case No. 13-1688 and Civil Case No. 05-655;
and
7

4. Rule 1.02 , Canon I, Code of Judicial Conduct for


failure to administer justice impartially.
8

Herein respondents Atty. Sison, Atty. Dimaano, and Atty.


Relamida, having connived with one another and with Judge
Moya and the public prosecutors in pressing the unfounded
estafa case against complainant, must therefore also be
investigated for violation of Section 3 (e) of RA 3019.
6

Article 206. Unjust Interlocutory Order. - Any judge who shall knowingly
render an unjust interlocutory order or decree shall suffer the penalty of
arresto mayor in its minimum period and suspension; but if he shall have
acted by reason of inexcusable negligence or ignorance and the
interlocutory order or decree be manifestly unjust, the penalty shall be
suspension. (Article 206, Revised Penal Code, Article 206)

Section 3. Corrupt practices of public officers. In addition to acts or


omissions of public officers already penalized by existing law, the following
shall constitute corrupt practices of any public officer and are hereby
declared to be unlawful:
xxx
(e) Causing any undue injury to any party, including the

Government, or giving any private party any unwarranted benefits,


advantage or preference in the discharge of his official
administrative or judicial functions through manifest partiality,
evident bad faith or gross inexcusable negligence. This provision
shall apply to officers and employees of offices or government
corporations charged with the grant of licenses or permits or other
concessions. (Anti-Graft and Corrupt Practices Act, Republic Act No.
3019, Section 3(e))
8

A judge should administer justice impartially and without delay.

16

PRAYER
WHEREFORE, premise considered, complainant
most respectfully prays of the Honorable Supreme Court
that after due proceedings, judgment be rendered finding
respondents guilty of the charges and ordered
PERPETUALLY DISBARRED.
COMPLAINANT further prays for such other just reliefs.
Makati City for Manila, 9 December 2013.

MANUEL N. CAMACHO
Complainant
Suite 1605 Corporate 88 Centre
Valero corner Sedeno Streets
Salcedo Village, Makati City

VERIFICATION and CERTIFICATION OF


NON-FORUM SHOPPING
REPUBLIC OF THE PHILIPPINES )
MAKATI CITY
)

S.S.

I, MANUEL N. CAMACHO, a Filipino of legal age with


offices at Suite 1605 Corporate 88 Centre, Valero corner
Sedeno Streets, Salcedo Village, Makati City, Philippines,
under oath state that:
1. I am the complainant the above-entitled case;
2. I have caused the filing of the foregoing COMPLAINT,
and I verify that its contents are true and correct of my

17

own personal knowledge and based on authentic


records;
3. I hereby certify that I have not commenced any similar
action or filed any claim involving the same
respondents in relation to the same in any court,
tribunal or quasi-judicial agency, and to the best of my
knowledge, no such other action or claim is pending;
and
4. I hereby undertake that should I hereafter learn of any other such
action or proceeding, whether pending or terminated, with any court, tribunal or
agency, I shall notify this Honorable Court of its status within five (5) days from
notice.

MANUEL N. CAMACHO
Affiant

SUBSCRIBED AND SWORN to before me in Makati City


this ________________, affiant exhibiting to me his IBP ID Card
bearing Attorneys Roll No. 14108, which ID is competent
evidence of his identity, and on which his picture and
signature both appear.

Page No. _______


Doc. No. _______
Book No. _______
Series of 2013.

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