Republic of the Philippines

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
BRANCH______
Makati City

REPUBLIC OF THE PHILIPPINES , Civil Case No. ______

Plaintiff,
For: ESCHEAT
-versus-

B, E, M BANKS,
Defendants,
x------------------------------x

COMPLAINT FOR ESCHEAT

REPUBLIC OF THE PHILIPPINES, by counsel states:

1. Plaintiff RP is a political and juridical entity with legal capacity

to sue. It may be served with summons through the Office of the
Solicitor General, 134 Amorsolo Street, Legaspi Village, Makati City;

2. Defendants B, E, M Banks are duly organized banking

institutions within the meaning of Section 1 of Act No. 3936 as
amended by Presidential No. 679, and authorized to do business in the
Philippines. All have their offices in the __________ as indicated
above, where they may be served with summons in accordance with
Section 3 of Act No. 3936, as amended;

3. Pursuant to Section 2 of Act No. 3936, as amended, the

above-named defendant banks forwarded to the Treasurer of the
Philippines a statement prepared under oath by their respective
managing officers of all deposits and credits held by them in their favor,
or in their names, of such depositors known to be dead, or who have
not been heard from, or have not made further deposits or withdrawals
during the proceeding ten years or more since _______. These sworn
statements of deposit and credits as of ___________, 20__, are
attached hereto as Annexes _____ and made integral parts of this
complaint;

4. Said sworn statements reveal that, as of December 31, 1999,

the unclaimed balances in each defendant are as follows:
 NAME OF THE BRANCH AMOUNT
BANK
B P 1,000,000.00
E P 1,000,000.00
M P 2,000,000.00
TOTAL P 4,000,000.00

5. Pursuant to Section 3 of Act No. 3639, as amended, all the

depositors or creditors of the defendant banks aforementioned who are
listed in Annexes ____ are hereby made parties defendants. Said
Section 3, likewise provides that service of processes in this action be
made by delivery of a copy of the complaint and summons to the
president, cashier, or managing officer of each defendant bank and
buy publication of such summons in a newspaper of general circulation
in the locality where the defendant bank is situated, if there be any, and
in the case there is none, in the City of Manila, as such time as this
honorable Court may order. Said section 3 also requires that the clerk
of court shall issue a notice to be attached to in published with a copy
of said summons, directing all persons, other than those named as
defendants, to show cause, if they have any, why no judgment in favor
of plaintiff may be rendered in this case;

6. Said unclaimed balance for the year 2009 are subject to

escheat in favor of plaintiff under the terms of Act No. 3936 as
amended.

PRAYER

WHEREFORE, it is respectfully prayed of this Honorable Court

that, after the service of summons on defendant banks and its various
depositors listed in Annexes _______ and of the Notice to all
persons, other than those named defendants therein, to show cause,
if they have any, why no judgment in favor of plaintiff may be
rendered in accordance with Section 3, as amended, and after
hearing, judgment de rendered declaring that the deposits, credits
and unclaimed balances in questions be escheated to the Republic of
the Philippines and commanding defendant banks to forthwith deposit
the same with the Treasurer of the Philippines to the credit of the
Republic of the Philippines.

Plaintiff prays for such other reliefs as may be just and the
premises.

Makati City. July 06 2015.

 Chuck Perez
Solicitor General
Roll No. 7777
IBP LIFETIME Roll No. 000000
OFFICE OF THE SOLICITOR GENERAL
134, Amorsolo St. Legaspi Village
Makati City

VERIFICATION AD CERTIFICATE OF NON FORUM SHOPPING

I, CHUCK PEREZ, of legal age, do hereby state that I hereby certify

that there is no other case commenced or pending before any court
involving the same parties and the same issue and that, should I learn
of such a case, I shall notify the court within five (5) days from my
notice.

IN WITNESS WHEREOF, I have signed this instrument on 6th day of

July 2015.

CHUCK PEREZ
Affiant