Republic of the Philippines

NATIONAL CAPITAL REGION

METROPOLITAN TRIAL COURT
Branch 38, Quezon City

AIR MATERIEL WING SAVINGS

AND LOAN ASSOCIATION, INC.,
Plaintiff,
-versus- Civil Case No. 38-39390

MARTIN T. TERRE ET AL.,

Xx --------------------------------------xX

MANIFESTATION OF FULL COMPLIANCE WITH

COMPROMISE AGREEMENT AND MOTION TO
DIRECT PLAINTIFF TO EFFECT THE DELISTING OF
DEFENDANTS FROM CREDIT BLACKLIST

COME NOW the DEFENDANTS by the undersigned Attorney and

to the Honorable Court, most respectfully asseverate that:

1. In the Honorable Court’s Judgment dated 19 May 2011, which

precursor was the Compromise Agreement which the parties filed on
even date, parties fixed the total monetary obligation of the defendants
to the sum of TWO HUNDRED FORTY-ONE THOUSAND NINE HUNDRED
FORTY-FIVE PESOS and seventy centavos (P241,945.70);

2.That the payment of such sum shall be by down payment of

Php75,000.00 to be paid on or before July 29, 2011 while the balance of
Php166,945.70 shall be paid in twenty-four equal monthly instalments
of Php6,956.07 each month starting on August 30, 2011which is to end
on July 30, 2013;

3.That upon the arrival of July 30, 2013, defendants had already
fully paid their obligation as they had never faltered in the monthly
installments;

4.That most ruefully however, defendants had learned of late that

their credit standing in banking institutions had been tarnished as
plaintiff had caused the “blacklisting” of defendants’ names;

Page 1 of 4
 5. That because of the full payment of the obligation in this case,
as a principle of good faith and rudimentary elements of fairness dictate
that plaintiff should cause the reversal of the “blacklisting” by restoring
the good names of plaintiffs in the banking or financing industry.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed

of the Honorable Court that it will duly note defendants’ full payment of
the obligations stated in the Judgment dated 19 May 2011 and further
direct plaintiff to delist defendants from the blacklisting in banking or
financing institutions only AS A CONSEQUENCE of this case.
Iloilo City for Quezon City, Philippines, 03 September 2013.

REYES and REYES LAW OFFICE

Counsel for the Defendants
G/F Carmelita Bldg.,
Quezon St., Iloilo City
Tel Nos. (033) 300-0081; (033) 338-2869
E-mail Ad: etreyesiii@yahoo.com

By:

EDUARDO T. REYES, III

P.T.R. NO. 4033999/ Iloilo City/ 03 January 2013
IBP No. 891215/ Iloilo City/ 07 January 2013
Attorney’s Roll No. 44832
MCLE Certificate of Compliance No. IV-0001640
22 February 2011

REQUEST

The Hon. Clerk of Court

MTC, Br. 38, Quezon City

Sir/ Madam:

Please set the foregoing motion for the consideration and

approval of the Honorable Court on Friday 13 September 2013 at 8:30
o’ clock in the morning sans need for personal appearance by, nor
additional oral arguments from, undersigned counsel.

Page 2 of 4
 EDUARDO T. REYES, III

NOTICE OF HEARING

Atty. Leslie N. Taruc-Orencia

MADAME:

Please take notice that undersigned counsel will submit the

foregoing motion for the consideration and approval of the Honorable
Court on Friday 13 September 2013 at 8:30 o’ clock in the morning sans
need for personal appearance by, nor additional oral arguments from,
undersigned counsel.

EDUARDO T. REYES, III

Copy sent by registered mail to:

Atty. Leslie N. Taruc-Orencia

Counsel for the Plaintiff
Legal Department, Office of the AVP-SEA
Air Materiel Wing Savings and Loan
Association, Inc.,
6th Floor AMWSLAI Bldg., cor. 18th
And Boni Serrano Avenues, Murphy
Cubao, Quezon City

Registered Mail Matter No: ______________

Date: ____________

LBC Tracking No. _____________________

Date: __________________

Page 3 of 4
 EXPLANATION
(Per Sec. 11, Rule 13 of the 1997 Rules of Civil Procedure)

The filing to the Honorable Court as well as service of the motion

to counsel for the plaintiff were done by registered mail and LBC (a
private courier) to ensure timely receipt given the distance of the
address /location from the Office of the undersigned counsel which
renders personal filing and service rather impracticable.

EDUARDO T. REYES, III

Page 4 of 4