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Republic of the Philippines

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
Office of the Secretary
Padre Faura St., Ermita, Manila

THE X-HABIT, INC. represented by


Anthony V. Miro,
Petitioner-Complainant,

NPS Docket No. XV-INV-18I-01781


FOR : COPYRIGHT
INFRINGEMENT
-versus-

EFREN ALCANTARA,
Respondent.
x--------------------------------------------x

PETITION FOR REVIEW

The petitioner-complainant, by and through the undersigned


counsel, respectfully requests this Honorable Office to review the
Resolution dated 14 November 2018 issued by the Office of the City
Prosecutor of Pasig City in the above case, dismissing the complaint
filed against the respondent therein for copyright infringement. The
undersigned counsel sought a reconsideration of the said dismissal
through a Motion for Reconsideration, which was denied in a
subsequent Resolution dated 7 February 2019.

THE PARTIES

Complainant-petitioner is a corporation duly organized and


existing under and by virtue of the laws of the Philippines, , with office
address at 1251 El Inventor Compound Amang Rodriguez Avenue,
Barangay dela Paz, Pasig City.

Respondent Efren Alcantara is a Filipino, of legal age, with


residence address at #25 Peru Street, Greenheights Subdivision,
Concepcion Uno, Marikina City.

Public respondent is the Office of the City Prosecutor for Pasig


City, with office address at the Hall of Justice, Pasig City .
Page 2 of 15

The petitioner-complainant, by and through the undersigned


counsel, respectfully requests this Honorable Office to review the
Resolution dated 19 July 2018 issued by the Office of the City
Prosecutor of Las Pinas City in the above case, dismissing the
complaint filed against the respondent therein for libel. The
undersigned counsel sought a reconsideration of the said dismissal
through a Motion for Reconsideration, which was denied in a
subsequent Resolution dated 10 October 2018.

COPYRIGHT OVER A CREATION IS


ACQUIRED BY THE CREATOR FROM THE
MOMENT OF CREATION WITHOUT NEED OF
REGISTRATION

DISCUSSION

The said Resolution dismissed the complaint for lack of copyright


registration by the complainant when such is not necessary in order for
copyright infringement to exist.

As held by the Supreme Court1:

The Intellectual Property Code is clear about the rights afforded


to authors of various kinds of work. Under the Code, "works are
protected by the sole fact of their creation, irrespective of
their mode or form of expression, as well as of their content,
quality and purpose. x x x."

Contrary to the old copyright law, the Intellectual Property


Code does not require registration of the work to fully
recover in an infringement suit. Nevertheless, both
copyright laws provide that copyright for a work is acquired
by an intellectual creator from the moment of creation.”
(Citations omitted, emphasis supplied)

It was therefore error for the investigating prosecutor to dismiss


the complaint, without an allegation on the part of the respondent, on
the basis of lack of registration over the subject images. Complainant
had alleged creation and ownership of the images, and is therefore
entitled to protection for his works under the Intellectual Property Code.
By using the said images without complainant’s permission,
respondent caused damage and violated complainant’s rights to the
1
G.R. No. 195956, March 11, 2015, ABS-CBN CORPORATION, Petitioner, vs.FELIPE GOZON,
GILBERTO R. DUAVIT, JR., MARISSA L. FLORES, JESSICA A. SORO, GRACE DELA PENA-
REYES, JOHN OLIVER T. MANALASTAS, JOHN DOES AND JANE DOES, Respondents.
Page 3 of 15

images as its lawful property. Respondent was bound to anser the


allegations in his defense but failed to do so.

A clear violation of complainant’s rights therefore exists, which


warrants the filing of the appropriate criminal action in court, and not
the dismissal of the complaint.

THE PARTIES

Complainant-petitioner is of legal age, Filipina, with residence


address at #27 CRM Aurora Street, BF Homes Almanza, Las Pinas
City.

Respondent is of legal age, Filipina, with office address at Stolt


Tankers B.V., 6th Floor V. Corporate Center, 125 L.P. Leviste St.,
Salcedo Village, Makati City.

Public respondent is the Office of the City Prosecutor for Las


Pinas City, with office address at the Hall of Justice, Las Pinas City.

STATEMENT OF MATERIAL DATES

Complainant-petitioner received the said Resolution last 26


September 2018. Last 8 October 2018, complainant-petitioner,
through the undersigned counsel filed a Motion for Reconsideration of
the said Resolution via private courier, which the Office of the City
Prosecutor received on 9 October 2018. Last 23 October 2018, the
undersigned counsel received his copy of the Resolution dated 10
October 2018, denying his Motion for Reconsideration of the dismissal
of the complaint for lack of merit.

Legible duplicate original copies of the Resolutions dated 19 July


2018 and 10 October 2018 are attached to the original copy of this
Petition as Annexes A and B thereof.

STATEMENT OF THE FACTS AND OF THE CASE

1. In her Complaint-Affidavit dated 23 February 20182, filed with the


Office of the City Prosecutor of Las Pinas City, complainant-
petitioner charged the respondent with libel, committed when she
filed with complainant-petitioner’s company at the time, Stolt
Tankers B.V., an unsworn statement detailing certain acts

2
A copy of which is attached hereto as Annex C.
Page 4 of 15

allegedly committed by complainant-appellant, particularly the


following:

a. Irregular conduct of respondent’s Performance Evaluation


for 2016 and 2017;
b. Forcing respondent to sell items like cosmetics, coffee,
frozen food, slimming tea, meals and snacks that,
according to her, damaged the image of our office;
c. Spreading malicious rumours about other employees and
gossiping about particular people in the company;
d. Incompetence and unprofessional behavior on
complainant-petitioner’s part, unbecoming an HR
manager;
e. Humiliating respondent in front of other employees;
f. “Practically doing nothing”, complainant-petitioner just
playing games and checking messages on the phone;
g. Lack of awareness on labor law issues;
h. Lack of skills to draft company policies and questioning
complainant-petitioner’s competency as an HR manager;
i. Complainant-petitioner’s lack of respect for other people’s
private lives;
j. Forcing respondent to work during her (respondent’s)
maternity leave;
k. Forcing respondent to do illegal and unethical acts on
complainant-petitioner’s whim;
l. Hiring a person in violation of company policies on
relatives; and
m. Alleged clear abuse of power on complainant-petitioner’s
part;

2. Respondent filed her Counter-Affidavit 3 , denying the charges


against her. She claims her unsworn statement was borne out
of a legal, moral and civic duty as an employee of the company,
that her statement was considered qualified communication,
hence no malice, and that there was no publicity of the said
statement;

3. In her Reply-Affidavit 4 , complainant-petitioner disputed the


defenses interposed by respondent, claiming that most of her
statements were hearsay and not of her own personal
knowledge, that they bordered on pure malice and cannot be
hidden under the guise of qualified privileged communication,
that one of the recipients, Lorben Chan, is not even respondent’s
3
A copy of which is attached hereto as Annex D.
4
A copy of which is attached hereto as Annex E.
Page 5 of 15

superior, thus the element of publicity where the defamatory


material is communicated to a third person who has no interest
in the matter;

4. To make matters worse, respondent, in her Counter-Affidavit,


intentionally misquoted Alonzo vs. Court of Appeals 5 . In
paragraph 27 of her Counter-Affidavit, respondent argued:

‘27. Publication in libel has been defined in Alonzo vs. Court of


Appeals as the “means making the defamatory matter, after it has
been written, known to someone other than the person to whom it
has been written. If the statement is sent straight to a person for
whom it is written there is no publication of it.” There is publication if
the material is communicated to a third person. What is material is
that a third person has read or heard the libellous statement, for “a
man’s reputation is the estimate in which others hold him, not the
good opinion which he has of himself.” ‘

(Highlight/emphasis supplied)

What the case of Alonzo actually says is:


Publication means "to make public; to make known to people in
general; to bring before the public." Specifically put, publication in
the law of libel means the making known of the defamatory
matter, after it has been written, to some person other than the
person of whom it is written. If the statement is sent straight to
a person whom it is written there is no publication of
it. (Emphasis supplied, citations omitted)

5. Respondent obviously mis-quoted the case to support her theory


that a letter intended for someone, though containing derogatory
material about another person, does not constitute publicity to
bring the same within the contemplation of libellous material;

6. Respondent then filed her Rejoinder-Affidavit 6 , supported by


affidavits of two witnesses, Lorben Chan and Rodello Ortiz, to
repeatedly bolster her argument against libel, and that Lorben
Chan was authorized to receive the statement respondent claims
to have filed out of a legal, moral duty. The affidavits of Lorben
Chan and Rodello Ortiz were filed without any attachments or
proof of their positions in the company, other than their self-
serving statements to that effect to help respondent in her case;
5
G.R. No. 110088 1 February 1995
6
A copy of which is attached hereto as Annex F.
Page 6 of 15

7. After the parties filed their pleadings, the case was submitted for
resolution, and the Office of the City Prosecutor of Las Pinas
eventually issued the Resolutions now up for review by this
Honorable Office.

ISSUES

WHETHER OR NOT THE OFFICE OF THE CITY


PROSECUTOR OF LAS PINAS CITY ERRED IN
FINDING THAT THE STATEMENTS MADE BY
RESPONDENT AGAINST THE COMPLAINANT-
PETITIONER DID NOT CONSTITUTE ACTUAL MALICE,
AND WERE ALLEGEDLY DONE OUT OF DUTY TO THE
COMPANY

WHETHER OR NOT THE OFFICE OF THE CITY


PROSECUTOR OF LAS PINAS CITY ERRED IN
FINDING THAT THERE WAS NO PUBLICITY OF THE
DEROGATORY STATEMENTS

DISCUSSION

Statements made under a qualified privileged communication


only does away with a presumption of malice, but can be overturned
by showing actual malice committed by the author, and thus lead to a
prosecution for libel.

The pertinent portion of the Resolution states:

“Here evidence is wanting to prove the elements of malice and


publicity.

Respondent was motivated not by malice but by a sense of duty to


the company where she is employed. She was complaining about
her immediate supervisor who, in her eyes, was violating company
policies. Perusing the Formal Written Complaint itself, it refers solely
to the misconduct of the HR Manager (complainant herein)
committed during office hours. No mention of any condition, status
or circumstance of the personal life of complainant in her home or
elsewhere. Indeed it is the same document which the company
acted upon to convene a panel to conduct an investigation and to
place complainant under preventive suspension.

The Formal Written Complaint was not made public. Said document
was not circulated or publicized to third persons, but only to those
Page 7 of 15

involved in the investigation and/or directly supervised the


complainant’s work. Lorben Chan is the overall manager of the
Manila Office, the head of the management committee of which the
HR Department is a part of and a member of the panel instituted to
handle the Written Formal Complaint. It is but proper therefore that
the Formal Written Complaint be likewise addressed to him.

Wherefore, premises considered, it is respectfully recommended that


the Complaint against respondent Veronica Durias for Libel under
Art. 353 in relation to Art. 355 of the Revised Penal Code BE
DISMISSED.

July 19, 2018, Las Pinas City.”

First of all, respondent did not show proof that Lorben Chan was
in fact the person to whom such “complaint” should have been made.
While Lorben Chan submitted an affidavit to that effect, he did not even
attach his job description duly certified by the corporation that he,
Lorben Chan was the overall manager, what were his duties and
responsibilities, and that he was somewhat the superior of complainant
herein. The real person who had an interest and ability to provide relief
to the respondent as to the latter’s alleged complaints was Jean Toh,
who did not submit any affidavit in support of the claims of the
respondent as to the alleged qualified privileged nature of the
communication. The protection respondent hides behind, that her
complaint falls under qualified privileged communication so as to put it
beyond the scope of libel, was not justified at all.

“Section 25 of the Corporation Code provides:

Section 25. Corporate officers, quorum.--Immediately after their


election, the directors of a corporation must formally organize by the
election of a president, who shall be a director, a treasurer who may
or may not be a director, a secretary who shall be a resident and
citizen of the Philippines, and such other officers as may be
provided for in the by-laws. Any two (2) or more positions may be
held concurrently by the same person, except that no one shall act
as president and secretary or as president and treasurer at the same
time.

The directors or trustees and officers to be elected shall perform the


duties enjoined on them by law and the by-laws of the corporation.
Unless the articles of incorporation or the by-laws provide for a
greater majority, a majority of the number of directors or trustees as
fixed in the articles of incorporation shall constitute a quorum for the
transaction of corporate business, and every decision of at least a
majority of the directors or trustees present at a meeting at which
there is a quorum shall be valid as a corporate act, except for the
election of officers which shall require the vote of a majority of all the
members of the board.
Page 8 of 15

Directors or trustees cannot attend or vote by proxy at board


meetings.

Conformably with Section 25, a position must be expressly


mentioned in the By-Laws in order to be considered as a
corporate office. Thus, the creation of an office pursuant to or
under a By-Law enabling provision is not enough to make a
position a corporate office. Guerrea v. Lezama,19 the first ruling
on the matter, held that the only officers of a corporation were
those given that character either by the Corporation Code or by
the By-Laws; the rest of the corporate officers could be
considered only as employees or subordinate officials. Thus, it
was held in Easycall Communications Phils., Inc. v. King:

An "office" is created by the charter of the corporation and the officer


is elected by the directors or stockholders. On the other hand, an
employee occupies no office and generally is employed not by the
action of the directors or stockholders but by the managing officer of
the corporation who also determines the compensation to be paid to
such employee.” (Underscoring and emphasis supplied)7

The litany of complaints submitted by respondent could not


therefore be qualified privileged communication, so as to bring it
beyond the scope of libelous material.

Further, a reading of the same would show that the supposed


complaint was tainted with actual malice, that would bring the writing
under libel. Even if the letter was considered qualified privileged
communication, such would only do away with the presumption of
malice, and can be overturned by showing actual malice by the author.

On the subject of actual malice, the Supreme Court held:


“Malice, however, does not necessarily have to be proven. There are
two types of malice – malice in law and malice in fact. Malice in law
is a presumption of law. It dispenses with the proof of malice when
words that raise the presumption are shown to have been uttered. It
is also known as constructive malice, legal malice, or implied
malice. On the other hand, malice in fact is a positive desire and
intention to annoy and injure. It may denote that the defendant
was actuated by ill will or personal spite. It is also called express
malice, actual malice, real malice, true malice, or particular malice.”8
(Emphasis supplied)

7
G.R. No. 157802, October 13, 2010, MATLING INDUSTRIAL AND COMMERCIAL
CORPORATION, RICHARD K. SPENCER, CATHERINE SPENCER, AND ALEX
MANCILLA, Petitioners, vs.RICARDO R. COROS, Respondent.

8
G.R. No. 184315, November 25, 2009, ALFONSO T. YUCHENGCO, vs.THE MANILA
CHRONICLE PUBLISHING CORPORATION, ROBERTO COYIUTO, JR., NOEL CABRERA,
Page 9 of 15

In the same case of Yuchengco, the Court went further to discuss what
is considered actual malice :

“Malice connotes ill will or spite and speaks not in response to duty
but merely to injure the reputation of the person defamed, and
implies an intention to do ulterior and unjustifiable harm. It is present
when it is shown that the author of the libelous remarks made such
remarks with knowledge that it was false or with reckless disregard
as to the truth or falsity thereof.”9

In another case, the Supreme Court held:

“In Disini v. The Secretary of Justice, the Court explained "actual malice" as
follows:

There is "actual malice" or malice in fact when the offender makes the
defamatory statement with the knowledge that it is false or with reckless
disregard of whether it was false or not. The reckless disregard standard
used here requires a high degree of awareness of probable falsity. There
must be sufficient evidence to permit the conclusion that the accused in fact
entertained serious doubts as to the truth of the statement he published.
Gross or even extreme negligence is not sufficient to establish actual
malice. (citations omitted)10

We repeat the ruling of the Supreme Court given during the


preliminary investigation in support of the contention that what the
respondent wrote falls under libel:

“In order to prove that a statement falls within the purview of a


qualified privileged communication under Article 354, No. 1, as
claimed by petitioner, the following requisites must concur: (1) the
person who made the communication had a legal, moral, or social
duty to make the communication, or at least, had an interest to
protect, which interest may either be his own or of the one to whom
it is made; (2) the communication is addressed to an officer or a
board, or superior, having some interest or duty in the matter, and
who has the power to furnish the protection sought; and (3) the
statements in the communication are made in good faith and without
malice.

While it would appear that the letter was written by petitioner out of
his social duty to a member of the association which he heads, and
was written to respondent as a reply to the latter’s demand letter sent
to a member, however, a reading of the subject letter-reply
GERRY ZARAGOZA, DONNA GATDULA, RODNEY P. DIOLA, RAUL VALINO and THELMA
SAN JUAN,Respondents.

9 Ibid.

10
G.R. No. 170341, MANILA BULLETIN PUBLISHING CORPORATION AND RUTHER
BATUIGAS, Petitioners vs.VICTOR A. DOMINGO AND THE PEOPLE OF THE PHILIPPINES,
Respondents
Page 10 of 15

addressed to respondent does not show any explanation concerning


the status of Mrs. Quingco and why she is entitled to the premises
as against the claim of respondent’s client. The letter merely
contained insulting words, i.e, "lousy" and "inutile letter using
carabao English", "stupidity", and "satan", which are totally irrelevant
to his defense of Mrs. Quingco’s right over the premises. The words
as written had only the effect of maligning respondent’s integrity as
a lawyer, a lawyer who had served as legal officer in the Department
of Environment and Natural Resources for so many years until his
retirement and afterwards as consultant of the same agency and also
a notary public. The letter was crafted in an injurious way than what
is necessary in answering a demand letter which exposed
respondent to public ridicule thus negating good faith and showing
malicious intent on petitioner’s part.

Moreover, the law requires that for a defamatory imputation


made out of a legal, moral or social duty to be privileged, such
statement must be communicated only to the person or persons
who have some interest or duty in the matter alleged, and who
have the power to furnish the protection sought by the author
of the statement. A written letter containing libelous matter cannot
be classified as privileged when it is published and circulated among
the public. In this case, petitioner admitted that he dictated the letter
to one of her secretaries who typed the same and made a print out
of the computer. While petitioner addressed the reply-letter to
respondent, the same letter showed that it was copy furnished to all
concerned. His lack of selectivity is indicative of malice and is
anathema to his claim of privileged communication. Such publication
had already created upon the minds of the readers a circumstance
which brought discredit and shame to respondent’s reputation.” 11
(Emphasis supplied)

As mentioned earlier, respondent failed to prove that Lorben


Chan was in fact the person who she was duty bound to submit the
written complaint to. In the same vein, the affidavit of witness Rodello
Ortiz cannot be given any weight, in the absence of proof of his position
from the corporation itself, as required no less by the Corporation
Code.

Moreover, a cursory reading of the alleged complaint shows it is


nothing but a rant against the complainant-petitioner, without details or
proof of her personal knowledge of the same, nor is the alleged
complaint even verified by the respondent. Such clearly constitutes a
reckless disregard for the truth or falsity thereof, so as to bring the
same under libel. Simply stating, as she did in her Counter-Affidavit,
that she has personal knowledge of the said allegations will not suffice.
As stated in her complaint against complainant herein, how could she

11
G.R. NO. 142509, March 24, 2006, JOSE ALEMANIA BUATIS, JR., Petitioner,
vs. THE PEOPLE OF THE PHILIPPINES and ATTY. JOSE J. PIERAZ, Respondents.
Page 11 of 15

have personal knowledge of the following, which are not factual but
deductions/speculations on respondent’s part:

a. Irregular conduct of respondent Durias’ Performance


Evaluation for 2016 and 2017 (no details as to how it was
irregular);
b. Forcing respondent to sell items like cosmetics, coffee,
frozen food, slimming tea, meals and snacks that,
according to her, damaged the image of our office (no
details as to the damage);
c. Spreading malicious rumours about other employees and
gossiping about particular people in the company (no
details as to who, what, where, when);
d. Incompetence and unprofessional behavior on my part,
unbecoming an HR manager (no details as to what the
behaviour was and why it was considered incompetent and
unprofessional on the part of the complainant);
e. Humiliating her in front of other employees (no details as
to who, what, where and when this happened);
f. “Practically doing nothing”, just playing games and
checking messages on my phone (no details as to when
and how respondent knew this);
g. Lack of awareness on labor law issues (generalization on
respondent’s part, no details again);
h. Lack of skills to draft company policies and questioning
complainant’s competency as an HR manager (no details,
again);
i. No respect for other people’s private lives (accusatory,
conclusion, no details);
j. Forcing Durias to work during her (Durias’) maternity leave
(no details);
k. Forcing Durias to do illegal and unethical acts at my whim
(no details, surprisingly);
l. Hiring a person in violation of company policies on relatives
(no details as to who, what, where and when, again); and
m. Alleged clear abuse of power on complainant’s part (no
details);

(Italics supplied)

Being more of conclusions and blind accusations, respondent


could not hide behind a simple allegation of personal knowledge;
throwing such hurtful statements was clearly guided by a motive to
injure complainant-petitioner’s reputation in the company, and are
therefore considered libelous statements, for which respondent should
be liable for criminally.
Page 12 of 15

PRAYER

WHEREFORE, premises considered, complainant-petitioner


respectfully prays that the said Resolutions be reconsidered and
reversed, and that probable cause be found to exist against
respondent for the crime of libel, as defined under the Revised Penal
Code.

Complainant-petitioner likewise prays for such other reliefs as


may be deemed just and equitable under the premises.

Parañaque City for Manila, 5 November 2018.

JOSEPH JOHN GERALD M. AGUAS


Counsel for the Complainant-Petitioner
28 Gonzales St., Sinag Tala Subdivision, BF
Homes, Paranaque City 1700
PTR No. 6367679 4 Jan 2018 Lucena City
IBP Lifetime No. 761/Roll No. 38313
MCLE Compliance VI no. 8203 until 14 April 2022
Tel. No. 09178422668

Copy furnished:

VERONICA DURIAS
STOLT TANKERS B.V.
6TH FLOOR V. CORPORATE CENTER
125 L.P. LEVISTE ST., SALCEDO VILLAGE, MAKATI CITY

OFFICE OF THE CITY PROSECUTOR


HALL OF JUSTICE
LAS PINAS CITY

EXPLANATION

Service of the foregoing pleading on the adverse parties to this case


was done via private courier/registered mail, due to lack of personnel
and time necessary to effect personal service thereof.
Page 13 of 15

JOSEPH JOHN GERALD M. AGUAS


Page 14 of 15

VERIFICATION AND CERTIFICATION OF


NON-FORUM SHOPPING

I, MA. SOCORRO C. BALMACEDA, of legal age, after having


been duly sworn in accordance with law, depose and state that:

1. I am the petitioner in the above-stated case;

2. I caused the preparation of the foregoing petition;

3. I have read the contents thereof and the facts stated therein
are true and correct of my personal knowledge and/or on the
basis of copies of documents and records in my possession;

4. I have not commenced any other action or proceeding


involving the same issues in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;

5. To the best of my knowledge and belief, no such action or


proceeding is pending in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;

6. If I should thereafter learn that a similar action or proceeding


has been filed or is pending before the Supreme Court, the Court
of Appeals, or any other tribunal or agency, I undertake to report
that fact within five (5) days therefrom to this Honorable Court.

MA. SOCORRO C. BALMACEDA


Affiant

SUBSCRIBED AND SWORN to before me this ___ day of __________


_ at _________________ affiant exhibiting to me his/her proof of
identity: _______________________ No.____________________
issued on ________________ 200_ at ______________ City.

Doc. No. ;
Page No. ;
Book No. ;
Series of 2018
Page 15 of 15

Republic of the Philippines )


Paranaque City ) s.s.

AFFIDAVIT OF FILING AND SERVICE

I, Atty. Joseph John Gerald M. Aguas, of legal age, Filipino, and a


resident of 28 Gonzales St., Sinagtala, BF Homes, Paranaque City,
after having been duly sworn to in accordance with law hereby depose
and say that:

1. I am the counsel for Ms. Ma. Socorro A. Balmaceda and caused


the preparation of a Petition for Review to be filed with the
Department of Justice on 5 November 2018, regarding NPS
Docket No. XV-04-INV-18C-00197;
2. In compliance with the requirements of the DOJ pertaining to
filing petitions for review, I served copies thereof by Registered
Mail to the public respondent therein, as well as to the private
respondent, by depositing a copy thereof, in the post office of
Manila , as evidenced by Registry Receipt Nos.
___________________ (for public respondent) and RD
_______________________ (for private respondent), the
original copies of which registry receipts were attached to the
original copy of said Petition filed with the Department of Justice,
with instructions to the post master to return the mail to the
sender after ten (10) days if undelivered.

IN WITNESS WHEREOF, I have hereunto affixed my signature this


_____ November 2018 at Manila, Philippines.

JOSEPH JOHN GERALD M. AGUAS

SUBSCRIBED AND SWORN to before me this _____________ 2018,


affiant exhibiting proof of identity: Drivers License no. N04-86-028780
issued February 2018.

Doc. No.
Page No.
Book No.
Series of 2018.