Beruflich Dokumente
Kultur Dokumente
Alabaster Graves,
Plaintiff-Appellant,
Criminal Case No. 01-975413
- versus Richter Belmont,
Defendant-Appellee,
x-----------------x
PRAYER
WHEREFORE, defendant most respectfully prays that an order be issued by this
Honorable Court requiring the plaintiff to make more definite statement as to the
particulars of the check mentioned in paragraph 5 of his complaint, particularly stating
its amount, check number, date, and the name of the drawee bank.
Quezon City, Philippines, January 23, 2014
ATTY. ROMMELITO FRANCISCO
MACARAYO
counsel for the defendant
13-69 Barracks Building, Marikina
IBP NO. 87123-7/19/12-AC
PTR NO. 669913/21/12-AC
Roll No. 99998
MCLE Exempt
(Admitted to the bar: April 6, 2012)
NOTICE OF HEARING
Atty. Ezekiel Razon
Counsel for the Plaintiff
12-26 Marina Arcade, Mabalacat City
Greetings! Please take notice that the foregoing Motion for Bill of Particulars shall
be submitted for the consideration and approval of the Honorable Court on Friday,
January 24, at 10:00 AM or as soon as counsel and matter may be heard.
Atty. Rommelito Francisco Macarayo
EXPLANATION
The foregoing Motion for a Bill of Particulars is being filed with this Honorable
Court and served on the opposing counsel by registered mail in view of the
impracticability of personal filing and service due to distance considering that the office
of this Honorable Court is at Quezon City and that of the opposing counsel is at
Mabalacat City, while undersigned counsel holds office in Marikina.
Atty. Rommelito Francisco Macarayo
COPY FURNISHED:
Atty. Ezekiel Razon
Counsel for the Plaintiff
12-26 Marina Arcade, Mabalacat City
-versusPEDRO CRUZ,
Accused.
x----------------------------------------------------x
URGENT MOTION FOR POSTPONEMENT
COMES NOW, the undersigned counsel for the defendant and unto this
Honorable Court, most respectfully manifests:
1.
That a notice of hearing for the above titled case was received by the
undersigned last November 7, 2007 informing the undersigned for the scheduled
hearing on November 21, 2007, 8:30 oclock in the morning. (Machine copy of the
notice duly received by the undersigned is hereto attached and marked as
annexA);
2.
That on November 6, 2007, a day prior to the date when the
abovementioned notice was received, the undersigned counsel also received a another
notice of hearing scheduled on the same date, November 21, 2007, 8:30 oclock in the
morning in a case for Theft entitled People of the Philippines vs. John Doe filed by
the City Prosecutor of Valencia City docketed as Criminal Case No. 001, for which case
the undersigned is a counsel for the defendant. (Machine copy of the notice of
hearing duly received by the undersigned is hereto attached and marked as
annex B);
3.
That there is therefore a conflict of schedule for the hearing scheduled on
November 21, 2007, 8:30 oclock in the morning, for the two (2) cases handled by the
undersigned counsel ;
4.
That the undersigned counsel is constrained to appear on the case cited
in paragraph 2 of this motion, the notice of which was received by the undersigned
ahead of the notice of the above titled case, on November 6, 2007.
WHEREFORE, premises considered, it is most respectfully prayed to this
Honorable Court that the scheduled hearing pf the above-entitled Criminal case on
November 21, 2007, 8:30 o clock in the morning be please cancelled and reset to
December 10, 2007 at 10:00 oclock in the morning.
Respectfully prayed for.
Malaybalay City, October 30, 2007
JENNY U. SALE, CPA
Counsel for the Defendant
Zone 4, Kalasungay, Malaybalay City
PTR No. 888888 - January 4, 2007
IBP No. 666666 - January 4, 2007
Roll No. 8080808
TIN 928-274-578
THE CLERK OF COURT
Municipal Trial Court in Cities
10th Judicial Region
Malaybalay City
Greetings:
Kindly submit the foregoing Motion for Postponement to the honorable Presiding
Judge immediately upon receipt hereof for the resolution of the same, sans oral
argument.
JENNY U. SALE, CPA
Notary Public
Zone 4, Kalasungay, Malaybalay City
PTR No. 888888 - January 4, 2007
IBP No. 666666 - January 4, 2007
Roll No. 8080808
TIN 928-274-578
Copy furnished:
ATTY. JAIME GARCI
City Prosecutors Office
Malaybalay City
Doc. No.
:
Page No.
:
Book No.
:
Series of 2013
THIAGO SILVA
NOTARY PUBLIC
Until December 31, 2013
PTR No. 906760 - Jan. 3, 2013
IBP No. 918300
Roll No. 13466
NOTARY PUBLIC
Commission Serial No. 12345
IBP No. 11111/01-04-16/Manila
PTR No. 22222/02-14-16/Manila
Roll of Attorneys No. XVII 123456
MCLE Compliance No. V 6789101
kevinjohnampuan@yahoo.com
No. 123, Brgy. Bon Bon St., Manila
0977-123-4567/ 02-123-4567
-versusMr. Y,
Defendant.
x---------------------x
COMPLAINT
COMES NOW, the plaintiff by the undersigned attorney, and unto this Honorable
Court, respectfully states:
1. That both the plaintiff and the defendant are of age, and residents of
_____________________;
2. That on _____________, the defendant, in order to secure the payment of the sum of
______________, acknowledged to have been received by him on said date, executed
in favor of the plaintiff a first mortgage on certain real property located in
________________________, a true copy of said mortgage contract is hereto attached
as Exh. A, and made an integral part of this complaint.
3. That the condition of said mortgage, as stated therein, is such, that if within the period
of _______________ from and after the execution of same, the defendant shall pay or
cause to be paid to the plaintiff, his heirs or assigns, the said sum of
________________ together with the stipulated interest of ________% per annum, then
the said mortgage shall be discharged; otherwise, it shall remain in full force and effect,
to be enforceable in the manner prescribed by law;
4. That the defendant has not paid or caused to be paid the mortgage debt of
_________ or any part thereof, in spite of the lapse of the stipulated period;
5. That the plaintiff has demanded of the defendant to pay the above sum of
_____________, plus the stipulated interest, but said defendant has failed to pay the
same;
6. That the defendant has also agreed in the mortgage contract that should the plaintiff
foreclose the mortgage, the latter is entitled to receive the further sum of __________%
of the total amount due as attorneys fees, expenses and costs.
7. That there are no other persons having or claiming an interest in the mortgaged
property.
WHEREFORE, it is respectfully prayed:
(a) That, upon due hearing, judgment be rendered:
(1) ordering the defendant to pay unto the court within the reglementary period of
ninety days the sum of _____________ together with the stipulated interest at
_______% per annum from and after _______________, plus the additional
sum of ______% of the total amount due as attorneys fees, expenses and
costs;
(2) and that in default of such payment, the above-mentioned property be
ordered sold to pay off the mortgage debt and its accumulated interest, plus
_____% of the total amount due as attorneys fees, expenses and costs,
(b) That plaintiff be granted such other relief in law and equity.
City of Manila, December 14, 2016.
__________________
(Attorney for the Plaintiff)
________________
(Address)
VERIFICATION AND CERTIFICATION FOR NON-FORUM SHOPPING
JURAT
-versusMEGAN VITUG,
Defendant.
x-----------------------------------x
COMPLAINT
COMES NOW, the plaintiff, through the undersigned counsel and unto this
Honorable Court, most respectfully avers:
1. That the plaintiff, KRUL ACOSTA, is of legal age, Filipino citizen, single, with
residence and postal address at 123 Benitez Street, Manila;
2. That the defendant, MEGAN VITUG, is of legal age, Filipino citizen, single, with
residence and postal address at 456 Modesto Street, Manila, where they may be served
with summons and other court processes;
3. The plaintiff is the owner of a land over which an apartment had been constructed
located 654 San Pedro Street, Manila;
4. By virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid
apartment for a consideration of P5,000.00 a month as rental to be paid within the first
ten (10) days of each month starting November 3, 2011;
5. The defendant failed to pay the agreed rental for several months starting February
19, 2012 up to the present;
6. On May 3, 2012, the plaintiff sent a letter of demand to vacate the apartment which
was received by the defendant as shown in the registry return receipt hereto attached
as Annex A;
7. Despite said letter of demand which was repeated by oral demands, the defendant
failed and still refused to pay the agreed amount of rentals and to vacated the
apartment;
8. By reason of failure of the defendant to vacate the premises and to pay the unpaid
rentals, the plaintiff was compelled to file this complaint engaging the services of
counsel in the amount of P10,000.00.
WHEREFORE, premises considered, it is most respectfully prayed unto this
Honorable Court that, after hearing, judgment be rendered ordering the defendant:
1. To vacate the subject premises;
2. To pay the amount of P5,000.00 per month as compensation for the reasonable use
of the subject premises until they finally vacate the said premises;
3. To pay the plaintiff the cost of the suit.
City of Manila, September 24, 2012.
REYES, TOLENTINO AND CRUZ LAW OFFICE
Counsel for the Plaintiff
Unit 123, Victoria Tower I
Taft Avenue, Manila
By:
Louise Reyes
Roll of Attorney No. 98765
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila
VERIFICATION/CERTIFICATION OF FORUM SHOPPING
Republic of the Philippines )
City of Manila
) S.S.
I, KRUL ACOSTA, of legal age, Filipino citizen, single and resident of 123
Benitez Street, Manila, after having been duly sworn to in accord Nance with law do
hereby depose and say:
1. That I am the plaintiff in the above-entitled case;
2. That I have caused the preparation of the foregoing complaint and have read the
allegations contained therein;
3. The allegations in the said complaint are true and correct of my own knowledge and
authentic records;
4. I hereby certify that I have not commenced any other action or proceeding involving
the same issues in any court, tribunal or quasi-judicial agency and, to the best of my
knowledge, no such other action or claim is pending therein;
5. That if I should learn thereafter that a similar action or proceeding has been filed or is
pending, I hereby undertake to report that fact within five (5) days therefrom to the court
or agency where the original pleading and sworn certification contemplated herein have
been filed.
ATTY. NO CASE
Notary Public
My Commission Expires Dec. 31, 2012
Roll of Attorney No. 34567
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila
-versusVAN SHELDON,
Defendant.
x-----------------------------------------x
NOTICE OF HEARING
VAN SHELDON
Defendant
GREETINGS:
Please submit the foregoing motion for the consideration and approval of the
Honorable Court on September 9, 2012 at 2:00 PM.
CHARLES ARUM
Copy furnished:
VAN SHELDON
345 Nakpil Street, Manila
EXPLANATION
Copy of the Motion to Serve Summons by Publication was served to defendant by
registered mail due to time and distance constraints, and for lack of the undersigneds
staff who can serve the same in person.
CHARLES ARUM
YYY,
Respondent.
x -----------------------------x
PETITION
NOW COMES, ____________, the Petitioner, by the undersigned counsel, to
this Honorable Court and respectfully represents:
That he is the mother of X, who is presently in the custody of Y, the maternal
grandmother of X, who forcibly abducted X and until now actually restraints him of his
liberty;
That despite demands, Y refuses to turn over the custody of X to the petitioner;
WHEREFORE, it is respectfully prayed that an order be issued to Y to bring the minor X
to this Honorable Court at the hour and date to be set by this Honorable court, and
thereafter that the custody of the minor X be turned over to the petitioner.
Quezon City, Philippines, this ___ day of March 2013.
NAME OF COUNSEL
Verification
Certification of Non-Forum Shopping
Civil Case
No. 111222
ELLA CORPUZ MAPA,
Defendant.
x-------------------------------------------x
MOTION FOR JUDGMENT ON THE PLEADINGS
Plaintiff, by counsel, respectfully alleges that:
1. On May 5, 2013, plaintiff sued defendant for a sum of money in the amount of
Two Hundred Thousand Pesos (P200,000.00);
2. In his Answer, defendant admitted the obligation and merely stated that he was
asking to be given an extension of time to pay his obligation but that plaintiff instead
filed the Complaint;
3. Said Answer has not tendered any issue and in fact it can be read therefrom
that defendant admitted the obligation; consequently, a judgment on the pleadings
may be rendered.
WHEREFORE, it is respectfully prayed that this Honorable Court render
a judgment on the pleadings.
Makati City, Philippines. August 5, 2013.
ATTY. VX YZ
Counsel for Plaintiff
NOTICE OF HEARING
THE BRANCH CLERK OF COURT
MeTC - Branch 62
Makati City
ATTY. AB CD
Counsel for the Defendant
1234 Zamora Street, Pasay City
Greetings!
Please take notice that the undersigned counsel will submit the foregoing Motion
to the Honorable Court on August 27, 2013 at 8:30 in the morning for its favorable
consideration and approval.
VX YZ
Copy furnished by registered mail:
ATTY. AB CD
Counsel for the Defendant
2233 Zamora Street, Pasay City
EXPLANATION
Due to lack of messengerial services to effect personal service, a copy of the
foregoing motion was sent to defendant's counsel through registered mail.
VX YZ
BBB,
Defendant.
x------------------x
MOTION TO DISMISS
Defendant, by his undersigned attorney, respectfully moves that the complaint be
dismissed on the following grounds:
(state one or more grounds provided for in Rule 16, Rules of Court)
ARGUMENTS
(state the reasons in support of the ground/s mentioned)
Atty. Y
Counsel for Defendant
BBB,
Defendant/s,
x--------------------x
MOTION FOR APPROVAL OF
COMPROMISE AGREEMENT
The parties respectfully allege that:
1. Plaintiff filed this claim against defendant for:
_____________ collection of sum of money
_____________ liquidated damages
_____________ enforcement of barangay agreement
2. The parties have come to an amicable settlement and have executed a
compromise agreement with the following terms and conditions.)
(copy terms and condition here)
The parties agree that the approval of this agreement by the Court shall put an end
to this litigation, except for purposes of execution in case of default.
WHEREFORE, premises considered, the parties respectfully pray that the court
approve this agreement and render judgment on the basis thereof.
SO ORDERED.
(place)
(date)
AAA
BBB
Plaintiff
Defendant