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Republic of the Philippines


Regional Trial Court
Baguio City

JAMAEL DIAMPUAN,
Petitioner, For:

Consignation or Judicial
Deposit
-versus-

MARK LOUIS CAYADANG TRINIDAD, SG-23,


Project Manager
Maharlika Livelihood Center
Human Settlements Development Corporation
Baguio City
Respondent.

CONSIGNATION
JAMAEL DIAMPUAN. through the undersigned counsel, most
respectfully submit this CONSIGNATION and in support thereof
state the following:
1. That petitioner has a standing contract of lease with the
Human Settlements Development Corporation, under its
project Maharlika Livelihood Center-Baguio City, with Project
Manager Mark Louis Cayadang Trinidad, attached herein is
the contract of lease accompanied by previous receipts of
payment;

2. That on __________, the payment for the period of __________


became due which the petitioner is the debtor;

3. That on __________, I tendered payment to the receiving office


of the Creditor-respondent, which was refused, affidavit of
tender is herein attached;

4. That the refusal appears to have been due to a tainted


relationship created by the cases filed by the petitioner against
the respondent in his official capacity before the Office of the
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Deputy Ombudsman for Luzon (OMB-L-C-17-0619, and OMB-


L-A-17-0673);

5. That the amount due totals ______________________;

6. That the petitioner is willing to deposit the same before the


court;

7. That due to the refusal of the respondent-creditor to accept


the lawful payment, the petitioner-debtor has been
constrained to file this Petition for Consignation and avail the
services of a member of the Philippine Bar;

PRAYER
WHEREFORE, premises all considered, it is most respectfully
prayed that the Honorable Court:
1. Receives the consignation as judicial deposit, amounting
to:___________________;

2. Deduct the amount of attorney’s fees of (Twenty five thousand


pesos) Php. 25,000.00 from the deposit or charge the same to
the respondent in his personal capacity, returnable or payable
to the Petitioner at the termination of the proceedings; and

3. Deduct the amount of cost of filing and proceedings from the


deposit or charge the same to the respondent in his personal
capacity, returnable or payable to the Petitioner at the
termination of the proceedings;

RESPECTFULLY SUBMITTED
Done this 27th day of July 2018, Baguio City, Philippines.

CAMTUGAN AND PARTNERS LAW OFFICES


306, Jose Miguel Building, Labsan Street cor., Yandoc Street,
Baguio City

By:

FRANCIS RAE G. CAMTUGAN II


IBP Rec No. 01863; January 6, 2018; Baguio City
PTR: 3435947; January 8, 2018; Baguio City
Roll No. 57998
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CP: 09175069483
MCLE Compliance No V-0000194; June 19, 2015
TIN: 257-993-811-000
Email Address: attycamtugan@gmail.com

NESTOR A. TAGULAO, JR.


IBP Lifetime No. 016687; Baguio-Benguet
MCLE No.VI - 0007645
PTR: 7899761; 2018
Roll No. 69280
CP: 09563609578
Email Address: tagulaonestor@gmail.com

NOTICE OF CONSIGNATION

Please take note that the court accepted the judicial deposit
amounting to ______________________ as consignation in relation to
the above petition.

Jamael Diampuhan
Consignor

COPY FURNISHED VIA REGISTERED MAIL

Mark Louis Cayading Trinidad, SG-23


Project Manager
Maharlika Livelihood Center
Human Settlements Development Corporation
Baguio City
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Republic of the Philippines)


BAGUIO CITY)Ss
x---------------------------x

VERIFICATION

I Jamael Diampuan, of legal age, Filipino citizen and a


resident of Baguio City after having been duly sworn to in
accordance with law do hereby state the following:
1) I am the movant and the complainant in the above-mentioned
case;

2) I have read and understood its contents which are true and
correct based on my personal knowledge and/or based on
authentic records;

IN WITNESS WHEREOF, we have hereunto set my hand this 27th


day of July 2018 at Baguio City, Philippines.

JAMAEL DIAMPUAN

SUBSCRIBED AND SWORN to before me this 27th day of JULY


2018, Baguio City, Philippines.

Doc No. ____


Page No. ____
Book No ____
Series of _____

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