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CHECKLIST

REVIEWER

1. JURAT
- PLEADING
2. ACKNOWLEDGEMENT
- CONTRACTS
3. AFFIRMATION OR OATH
4. AFFIDAVIT OF LOSS
5. COMPLAINT
6. SAMPLE CAPTIONS AND TITLES
7. COMBINED VERIFICATION WITH VERTIFICATE OF NON-FORUM SHOPPING
8. NOTICE OF HEARING
9. COMPLAINT BASED ON ACTIONABLE DOCUMENT
10. MOTION TO DISMISS
11. MOTION FOR BILL OF PARTICULARS
12. NOTICE OF APPEAL OR RECORD ON APPEAL
13. EXTRAJUDICIAL SETTLEMENT OF ESTATE OF A DECEASED PERSON
14. PROBATE OF WILL
15. PETITION FOR GUARDIANSHIP OF MINOR
16. CRIMINAL INFORMATION FOR QUALIFIED THEFT
17. CERTIFICATE OF PRELIMINARY INVESTIGATION
18. ARTICLES OF INCORPORATION
19. SALE OF REGISTERED LAND
20. CERTIFICATION OF BOARD RESOLUTION BY CORPORATE SECRETARY
21. COMPLAINT FOR RESCISSION OF CONTRACT
22. PROOF OF SERVICE
23. DEMAND LETTER
24. MOTION TO DECLARE IN DEFAULT WITH NOTICE OF HEARING
25. PROMISORY NOTE
26. JUDICIAL AFFIDAVIT
27. DACION EN PAGO
28. PRAYER
29. CONTRACT
30. SHAREHOLDERS AGREEMENT
31. MINUTES OF MEETING
32. CONTRACT (ATTY.)

THINGS YOU FORGET :

 WHEN THERE’S CNFS


 WHEN TO USE ACKNOWLEDGEMENT AND WHEN TO USE JURAT
DEED OF ABSOLUTE SALE
Republic of the Philippines )

City of Makati ) S.S

KNOW ALL MEN BY THESE PRESENTS

This Deed of Absolute Sale executed on May 1, 2011 in Makati City by and between:

Maisie Karissa Zabala Filipino, of legal age, married, and resident of 2938 Kuratong Street, Makati
City as VENDOR.

and

Kevin Jonathan Lumbre Corporation, a Philippine company with a business address in Makunat Street,
Makati City, represented by its President, Kevin Jonathan Lumbre as VENDEE.

WITNESSETH THAT:

WHEREAS, the property subject of this instrument is a parcel of land located in No. 99 Jijiwap St. Makati City
with a total area of 69,000 sqm and covered by TCT No. 6969.

WHEREAS, the VENDORS are registered owners of the parcel of land as described in TCT No. 6969.

WHEREAS, the VENDEE has expressed its desire to purchase the said property for an aggregate purchase price
of P250 million and the same has been accepted by the VENDORS.

NOW, WHEREFORE, premises considered, especially the P250 million purchase price, the VENDORS hereby
sell, transfer and convey the subject parcel of land to the VENDEE, its successors-in-interest and assigns.

The VENDORS further warrant that they are the absolute owner of the property and that the title is free from any
claims, liens and encumbrances.

IN WITNESS WHEREOF, the parties have signed this agreement on the date and place abovementioned.

(sgd.) Maisie Karissa Zabala (sgd) Kevin Jonathan Lumbre


VENDOR For Kevin Jonathan Lumbre Corp. (President)
VENDEE
Signed in the presence of:

(Sgd) Zeke Garcia (Sgd) Victoria Chang


WITNESS Witness
ACKNOWLEDGEMENT

BEFORE ME, a Notary Public for and in the City of Makati, the parties acknowledge that the above instruments
was their true and voluntary act and deed. They have exhibited competent proof of identity to wit:

Maisie Karissa Zabala - Passport No. 12312, expiry Feb 2024


Kevin Jonathan Lumbre - Driver’s license No. D-2342, expiry March 2022
Zeke Garcia - GSIS ID No 2431
Victoria Chang - Passport No. 2421, expiry March 2020

The Deed of Absolute Sale consists of 2 pages including the page wherein this acknowledgement is written and
has been signed by the parties on each page in the left hand corner.

WITNESS MY HAND AND SEAL, this 3rd day of May, 2011 in Makati City

(Sgd). Rem Guevarra


NOTARY PUBLIC
Appointment No. 242
Until August 2019-12-10
Roll no. 24213
IBP No. 1232
PTR No. 234
MCLE Compliance No. 4

Doc No. 32
Page No. 31
Book No. 12
Series of 2011
SECRETARY’S CERTIFICATE
Republic of the Philippines)

City of Makati ) S. S

SECRETARY’S CERTIFICATE

I, Sara Avillon, Filipino of Legal age, with office address in Samaguitta Street, Makati City, after having been
sworn to in accordance to the law do hereby state that:

1. I am the Corporate Secretary of Kevin Jonathan Lumbre Corporation, a Philippine Corporation with
office address at Makunat Street, Makati City;
2. I am the custodian of the books and records of the said company, including the Minutes of the Meeting
and Board Resolutions;
3. During the regular meeting of the Board of Directors on April 20, 2011, wherein a quorum was present,
the following resolution has been unanimously approved and adopted:

“RESOLVED, as it is hereby resolved that Kevin Jonathan Lumbre Corporation is authorized to


purchase from Maisie Karissa Zabala a 69,000 sqm parcel of land located in No. 99 Jijiwap St. Makati
City and covered by TCT No. 6969 for P250 million and that the President, Kevin Jonathan Lumbre is
authorized to sign, execute and deliver documents, instruments , including the Deed of Absolute Sale
and to perform such other acts as may be necessary to the foregoing transaction.

4. The said resolution have not been modified, altered, repealed or otherwise revoked and is still in force
and valid.
5. I am executing this instrument for whatever purpose it may serve

TO THE TRUTH OF THE FOREGOING, I have signed this document on May 15, 2011 in Makati City.

(Sgd.) Sara Avillon


Corporate Secretary
Attested to by:
(Sgd) Kevin Jonathan Lumbre
President
SUBSCRIBED AND SWORN TO BEFORE ME on May 15, 2011 in Makati City, affiant exhibiting her
passport no. 3243, expiry on November 2021
(Sgd). Rem Guevarra
NOTARY PUBLIC
Appointment No. 242
Until August 2019-12-10
Roll no. 24213
IBP No. 1232
PTR No. 234
MCLE Compliance No. 4

Doc No. 32
Page No. 31
Book No. 12
Series of 2011
COMPLAINT FOR RESCISSION OF CONTRACT

Republic of the Philippines


Regional Trial Court
National Capital Judicial Region
Makati City Branch 1
Kevin Jonathan Lumbre Corporation
Plaintiff
-versus - Civil Case No. 3423
For: Rescission of a Contract of Sale
Maisie Karissa Zabala
Defendant
x-----------------------------------------------------------------------------------x
COMPLAINT FOR RESCISSION OF CONTRACT

Plaintiff, through the undersigned counsel, respectfully state that:


1. Plaintiff is a Philippine Corporation with office address at Makunat Street, Makati City;
2. Defendant, is a Filipino Citizen, of legal age and resident of 2938 Kuratong Street, Makati City;
3. On May 1, 2011, plaintiff and defendant executed a Deed of Absolute Sale concerning a parcel of land
in Makati City covered by TCT No. 6969
4. The defendants represented that they had a clean title to the property and that the same was free from
any claims, liens or encumbrances
5. On May 20, 2011, upon the attempt of the plaintiff to register the Deed of Sale with the Registry of
Deeds of Makati City, it has been discovered that there was another complaint over the title to the
property subject of sale
6. Had the plaintiff known that there was another claimant, it would not have bought the property from the
defendants.
7. The consent of the plaintiff was obtained through a fraudulent misrepresentation and that the sale may
be annulled under the Civil Code.
WHEREFORE, it is respectfully prayed that a judgment ordering the rescission of the aforementioned deed of
absolute sale be rendered. Other just and equitable reliefs also prayed for.

City of Makati, June 19, 2011


(sgd.)
Luigi Canoneo
Counsel for Plainiff
No. 7 Ayala Avenue Makati City
Roll No. 3432
IBP No. 2342
PTR No. 2132
MCLE Compliance No. 1508
Verification & Certification of Non-forum shopping

VERIFICATION & CERTIFICATION OF NON-FORUM SHOPPING

I, Kevin Jonathan Lumbre, Filipino, of legal age, with office address at Makunat Street Makati City do hereby
state that:

1. I am the President of the plaintiff corporation and I am authorized to commence this action through
Board Resolution No. 17, dated June 1, 2011. (Annex B)
2. I have caused the preparation of the complaint above.
3. I have read and understood the contents of the same and attest that they are true based on my personal
knowledge.
4. I have not commenced any other action or claim involving the same issues in any other court, tribunal
or quasi-judicial agency.
5. There are no other case or claim pending involving the same issues.
6. Should I learn of any other pending case, I would report it to this Honorable Court within 5 days
therefrom.

IN WITNESS WHEREOF , I have signed this document on June 3, Makati City.

(Sgd.) Kevin Jonathan Lunbre


Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, this 19th of June 2011 in Makati City. Affiant presenting his
Driver’s License No 3243, expiry on December 2020

(Sgd). Rem Guevarra


NOTARY PUBLIC
Appointment No. 242
Until August 2019-12-10
Roll no. 24213
IBP No. 1232
PTR No. 234
MCLE Compliance No. 4

Doc No. 32
Page No. 31
Book No. 12
Series of 2011
MOTION TO DISMISS
Republic of the Philippines
Regional Trial Court
National Capital Judicial Region
Makati City Branch 1
Kevin Jonathan Lumbre Corporation
Plaintiff
-versus - Civil Case No. 3423
For: Rescission of a Contract of Sale
Maisie Karissa Zabala
Defendant
x-----------------------------------------------------------------------------------x
MOTION TO DISMISS

Defendants, through the undersigned counsel and to this Honorable Court respectfully state that:

1. Defendants is of legal age, Filipino and a resident of 2938 Kuratong Street, Makati City;
2. Plaintiff is a Philippine Corporation with an office address in Makunat Street, Makati City;
3. In the complaint filed by the plaintiffs there was a failure to state all the elements of fraudulent
representation;
4. There was no specific ac of fraud averred
5. Under the Rules of Court, the failure to State a cause of action is one of the grounds for the dismissal of
the same

WHEREFORE, it respectfully prayed that the Honorable Court dismiss the complaint for the failure to state a
cause of action and other just and equitable reliefs also prayed .

City of Makati: June 12, 2011.

(sgd.)
Minerva Timbang
Counsel for Defendant
No. 33 Ayala Avenue Makati
City
Roll No. 3432
IBP No. 2342
PTR No. 2132
MCLE Compliance No. 1508

COPY FURNISHED THROUGH PERSONAL SERVICE:


Luigi Canoneo
Counsel for Plaintiff
No 7 Ayala Avenue Makati
PROOF OF SERVICE

I, Katriona Karaka, messenger of the counsel for defendants personally served the counsel for plaintiff with this
motion to dismiss on June 12, 2011 at its office address in No. 7 Ayala Avenue Makati.

IN WITNESS WHEREOF, I have signed this document on June 13, 2011 in Makati.

Katriona Karaka
Affiant

SUBSRIBED AND SWORN TO BEFORE ME, this 13th day of June in Makati affiant exhibiting his SSS ID
No. 1234-21.

(Sgd). Rem Guevarra


NOTARY PUBLIC
Appointment No. 242
Until August 2019-12-10
Roll no. 24213
IBP No. 1232
PTR No. 234
MCLE Compliance No. 4

Doc No. 32
Page No. 31
Book No. 12
Series of 2011
INFORMATION WITH THE CERTIFICATE AS TO THE CONDUCT OF PRELIMINARY
INVESTIGATION
Republic of the Philippines
Regional Trial Court
National Capital Judicial Region
Makati City Branch 1
People of the Philippines
Plaintiff
-versus - Criminal Case No. 18-00
For: Qualified Theft
Porky Jefferson
Accused
x-----------------------------------------------------------------------------------x
INFORMATION

The undersigned prosecutor, pursuant to a complaint filed by Loki Koala, hereby accuses and charges the
accused with QUALIFIED THEFT committed as follows:

That on or about May 15,2019 within the territorial jurisdiction of this court, did then and there wilfully and
feloniously took the money entrusted to her worth P10,000 from the cash register, being the cashier in the
complaint store, breaching the trust reposed to her.

CONTRARY TO LAW.

(Sgd) Bryan Manzano


Assistant City Prosecutor

CERTIFICATE AS TO THE CONDUCT OF PRELIMINARY INVESTIGATION

I hereby certify that I have personally conducted the requisite preliminary investigation and personally examined
the witness, finding probable cause to file this information with authority from the City Prosecutor.

(Sgd) Bryan Manzano


Assistant City Prosecutor

SUBSCRIBED AND SWORN TO BEFORE ME this 19th dya of May 2019 in Makati City.

APPROVED BY:
(Sgd) June Lim
City Prosecutor
WITNESSES:
A 21232 Hidalgo St.Makati
B 43 Hidalgo St. Makati
Bail recommended P100,000
AFFIDAVIT OF LOSS
Republic of the Philippines )

Makati City ) S.S

AFFIDAVIT OF LOSS

I, Tin Penalosa, Filipino, of legal age, resident of 234 Forbes Park, Taguig City after having been sworn
according to law do hereby state that.

1. I am issued by DFA with Passport No. 1298, which would expire on May 20,2021
2. While I was wondering around Rockwell Makati City, my bag was snatched by another person.
3. My passport was contained in the bag as I was about to go to the airport that same day for my flight to
Quatar.
4. I have diligently searched for my passport but to no avail.
5. I am executing this affidavit for the request for re-issuance of another passport that will file with DFA.

IN WITNESS WHEREOF, I have signed this affidavit on May 21,2019 in Makati.

Tin Penalosa
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, on May 22, 2019 in Makati, affiant exhibiting her driver’s
license no 1234 to expire on June 20,2022

(Sgd). Rem Guevarra


NOTARY PUBLIC
Appointment No. 242
Until August 2019-12-10
Roll no. 24213
IBP No. 1232
PTR No. 234
MCLE Compliance No. 4

Doc No. 32
Page No. 31
Book No. 12
Series of 2019
CONTENTS OF THE ARTICLES OF CORPORATION
REVISED CORPORATION CODE

SEC. 13. Contents of the Articles of Incorporation. –

All corporations shall file with the Commission articles of incorporation in any of the official languages, duly
signed and acknowledged or authenticated, in such form and manner as may be allowed by the Commission,
containing substantially the following matters, except as otherwise prescribed by this Code or by special law:

Names.Purpose.Place.Term.Incorporators.Number of Directors.NNR of Directors. ACS,S,Par,Orig Subscribers.


Non-stock.

(a) The name of the corporation;

(b) The specific purpose or purposes for which the corporation is being formed. Where a corporation has
more than one stated purpose, the articles of incorporation shall indicate the primary purpose and the
secondary purpose or purposes: Provided, That a nonstock corporation may not include a purpose which
would change or contradict its nature as such;

(c) The place where the principal office of the corporation is to be located, which must be within the
Philippines;

(d) The term for which the corporation is to exist, if the corporation has not elected perpetual existence;

(e) The names, nationalities, and residence addresses of the incorporators;

(f) The number of directors, which shall not be more than fifteen (15) or the number of trustees which may
be more than fifteen (15);

(g) The names, nationalities, and residence addresses of persons who shall act as directors or trustees until
the first regular directors or trustees are duly elected and qualified in accordance with this Code;

(h) If it be a stock corporation, the amount of its authorized capital stock, number of shares into which it is
divided, the par value of each, names, nationalities, and residence addresses of the original subscribers,
amount subscribed and paid by each on the subscription, and a statement that some or all of the shares
are without par value, if applicable;

(i) If it be a nonstock corporation, the amount of its capital, the names, nationalities, and residence
addresses of the contributors, and amount contributed by each; and

j)Such other matters consistent with law and which the incorporators may deem necessary and
convenient. An arbitration agreement may be provided in the articles of incorporation pursuant to Section 181 of
this Code.

The articles of incorporation and applications for amendments thereto may be filed with the Commission in the
form of an electronic document, in accordance with the Commission’s rules and regulations on electronic filing.
NOTICE OF HEARING

BRANCH CLERK OF COURT


Regional Trial Court of Makati
Branch 69

Dear Gentlemen:

The undersigned shall submit the foregoing motion to dismiss for approval and consideration of the
Honorable Court on June 4, 2009 at 10:00 am.

Porky Manchester
Counsel for Plaintiff
PRAYER

WHEREFORE, it is respectfully prayed that the Honorable Court render judgment dismissing the complaint and
granting the counterclaim by ordering the defendant to 1) pay moral damages in the amount of P200,000 and 2)
pay attorney’s fees in the amount of P50,0000

Other just and equitable reliefs are likewise prayed for.

Makati City, May 25,2019


NOTICE OF APPEAL
Republic of the Philippines
Regional Trial Court
National Capital Judicial Region
Makati City Branch 1
Troy Bulton
Plaintiff
-versus - Civil Case No. 3423
For: Sum of Money
Manolo Timbang
Defendant
x-----------------------------------------------------------------------------------x
NOTICE OF APPEAL

The Plaintiff, by counsel manifests its intention to appeal, as it hereby appeals the decision of the
Honorable Court dated April 15, 2019 assail decision which was served received on April 20,2019.

On April 22, 2019 a Motion for Reconsideration was filed questioning the Assailed Decision. The
Plaintiff received the Honorable Court’s order dated April 24, 2019 denying the Motion for Reconsideration on
April 29,2019. Thus the Notice of Appeal was timely filed. The Plaintiff manifests its intention to appeal to the
Court of Appeals.

Respectfully submitted.

Makati City, April 29,2019.

(sgd.)
Luigi Canoneo
Counsel for Plainiff
No. 7 Ayala Avenue Makati City
Roll No. 3432
IBP No. 2342
PTR No. 2132
MCLE Compliance No. 1508
COPY FURNISHED THROUGH PERSONAL SERVICE:
Tony Stark
Counsel for Defendant
No 9 Ayala Avenue Makati
DEED OF EXTRAJUDICIAL SETTLEMENT
Republic of the Philippines)
Makati City ) S. S

DEED OF EXTRAJUDICIAL SETTLEMENT

KNOW ALL MEN BY THESE PRESENTS:

The Deed of Extrajudicial Settlement “The Agreement is entered into this day May 25, 2019 at 123
Hidalgo St. Makati City between:

1.
Bugoy Buguyan , Filipino, of legal age, single and with residence at 234 Soy Gardens, Quezon
City
And
2. Manay Buguyan, Filipino of legal age, single and with residence at 123 Sauce Ser, Makati City
WITNESETH that:

WHEREAS, we are the sole heirs of deceased Baratingas Jusmi Buguyan who died on May 1, 2019 at Makati
City. A copy of his death certificate is attached herein as “Annex A”

WHEREAS, Baratingas Jusmi Buguyan died intestate and without any outstanding debts or obligations against
any person or entity.

WHEREAS, Baratingas Jusmi Buguyan is the absolute owner and registered owner of a parcel of land located in
Makati City covered by TCT No 12344 and with a total area of 69 sqm.

WHEREFORE premises considered, pursuant to Rule 74, Section 1 of the Revised Rules of Court, and with full
capacity, we adjudicate into ourselves the above mentioned parcel of land in equal shares.

IN WITNESS WHEREOF, we have affixed our signatures this May 29, 2019 at Makati City .

(sgd) (sgd)
Bugoy Buguyan Manay Buguyan
Republic of the Philippines)
Makati City ) S.S

Acknowledgement
Before me, a Notary Public in Makati City, personally appear

Name Competent Evidence of Identity CTC No.


Bugoy Buguyan Passport No 1231 2332
Manay Buguyan Passport No 113312 423

Who are identified by me through competent evidence of identity to be the same persons who presented the
foregoing instrument and acknowledged to me that the signatures in the instrument were voluntarily affixed by
them for the purpose stated therein, and that the instrument represents their free and voluntary act and deed.

Witness my hand and seal on this 1st day of June 2019.

(Sgd). Rem Guevarra


NOTARY PUBLIC
Appointment No. 242
Until August 2019-12-10
Roll no. 24213
IBP No. 1232
PTR No. 234
MCLE Compliance No. 4

Doc No. 32
Page No. 31
Book No. 12
Series of 2019
CONTRACT ** PRINT FILE FROM ATTY.PILARES

JURAT

SUBSCRIBED and sworn to before me, this 19 th day of April 2019 in the City of Makati Jhonny
Dalumping with Passport No. EEB323 issued on September 2,2018 at DFA San Fernando Papangga

(Sgd). Rem Guevarra


NOTARY PUBLIC
Appointment No. 242
Until August 2019-12-10
Roll no. 24213
IBP No. 1232
PTR No. 234
MCLE Compliance No. 4

Doc No. 32
Page No. 31
Book No. 12
Series of 2019

ACKNOWLEDGEMENT
Republic of the Philippines )
City of Makati ) S.S

BEFORE ME, this 19th day of April 2019 in the City of Makati, Jhonny Dalumping with Passport No.
EEB323 issued on September 2, 2018 at DFA San Fernando Pampanga, known to me to be the same person who
executed the foregoing instrument and acknowledged that the same are their free act and deed.

IN WITNESS WHEREOF, I set unto my hand and seal on the date and place above written

(Sgd). Rem Guevarra


NOTARY PUBLIC
Appointment No. 242
Until August 2019-12-10
Roll no. 24213
IBP No. 1232
PTR No. 234
MCLE Compliance No. 4

Doc No. 32
Page No. 31
Book No. 12
Series of 2019
DEMAND LETTER

April 9,2019

MS. BHEA ALONSO


#123M, 1st Street, San Miguel
City of Manila

FINAL DEMAND

Madam:

We write in behalf of our client, Jhonny Dhepp, on the matter of your non-payment of your obligation.

Records disclose that you have an outstanding obligation with our client in the amount of P270,000.00 with
interest at 6% per annum, and despite repeated demands you have failed and continuously fail to pay the
aforesaid amount.

Accordingly, FINAL DEMAND is hereby made upon you to settle the amount of P270,000.00 within three (3)
days from the receipt of this letter. Otherwise we will be constrained to file the necessary legal action against
you to protect the interest of our client.

We trust that you will give this matter your prompt and preferential attention to avoid the expense and
inconvenience of litigation.

Truly yours,
(Sgd.) Atty. Luningnining Garutay
MOTION TO DECLARE DEFENDANT IN DEFAULT

Republic of the Philippines


Regional Trial Court
National Capital Judicial Region
Makati City Branch 1
Shinji Cruze
Plaintiff
-versus - Civil Case No. 3423
For: Sum of Money
Maling Akala
Defendant
x-----------------------------------------------------------------------------------x
MOTION TO DECLARE DEFENDANT IN DEFAULT

Plaintiff, by counsel respectfully states that:


1. Plaintiff filed this Complaint against defendant on March 3,2019, summons were served on
defendant on March 20,2019 as indicated by the Sheriff’s return, attached as “ANNEX A”
2. Defendant’s reglementary period to file answer ended on April 5, 2019 that no motion for
extension of such period was filed nor was any granted. Despite the lapse of time, Defendant
failed to answer the complaint against her. Plaintiff is entitled to a declaration of default and
the right to present. Plaintiff is entitled to a declaration of default and the right to present
evidence ex parte against the defendant.
WHEREFORE, Plaintiff respectfully prays that Defendant be declared in default and that the Plaintiff
be allowed to present evidence ex parte.

April 6, 2019, Makati Philippines.

(sgd.)
Luigi Canoneo
Counsel for Plainiff
No. 7 Ayala Avenue Makati City
Roll No. 3432
IBP No. 2342
PTR No. 2132
MCLE Compliance No. 1508
COPY FURNISHED THROUGH PERSONAL SERVICE:
Tony Stark
Counsel for Defendant
No 9 Ayala Avenue Makati
PROMISSORY NOTE

April 9, 2019

P10,000.00

10 days after date, I Potpot Maalam, promise to pay to the order of Maisie Karissa Zabala, the sum of
Ten Thousand Pesos (P10,000.00)

(Sgd.) Potpot Maalam


JUDICIAL AFFIDAVIT
Republic of the Philippines
Regional Trial Court
National Capital Judicial Region
Makati City Branch 1
PEOPLE OF THE PHILIPPINES
Plaintiff
-versus - Criminal Case No.
For: Estafa
Bato Pick
Accused
x-----------------------------------------------------------------------------------x
JUDICIAL AFFIDAVIT

Bato Pick, 22 years old, employed as a businessman, residing at #123, 1 st Street, San Miguel Manila,
after having been duly sworn in accordance with law, hereby dispose and state:

PRELIMINARY STATEMENT

That the person examining me is Atty. Kurutong Baleleng with law office at #123 Sketchy Street,
Makati City. My Judicial affidavit is being taken at the above mentioned place, in the presence of Judith
Makapili and my companions.

That the questions are asked in English language but are translated in Tagalog dialect which I speak and
fully understand and I am giving my answers fully conscious that I do so under oath and I am aware that I may
face criminal liability for false testimony or perjury for false made or given by me.

OFFER OF TESTIMONY

The testimony of the witness Bato Pick is being offered to prove that he is an eyewitness to the crime of
Estafa. He will testify what he saw the day of their transaction with the accused and what later transpired in their
agreement dated July 22, 2018. The witness will identify the accused in open court as the person who committed
the crime.

1. Q:
A:
2. Q:
A:
3. Q:
A:

Manifestation: May I request this honorable court a few words to ponder in the act of the client by mere hiding
this past 4 years constitutes abuse of confidence over my client. The mere fact that he ran and hid from his
obligation shows that the trust entrusted was violated.

THAT WILL BE ALL FOR THE WITNESS YOUR HONOR.

IN WITNESS WHEREOF, I have hereunto set my hand this 20 th day of August 2018 at Makati City.

(Sgd.) Bato Pick


ATTESTATION

I,Atty.Kurutong Baleleng, of legal age, with office address at #123 Sketchy Street, Makati City, do
hereby certify that:

I propounded question to Bato Pick and faithfully recorded or caused to be recorded the questions I
have asked and the corresponding answers that Bato Pick gave as above stated.

Neither I nor any other person then present or assisting the witness coached the latter regarding his
answers.

IN WITNESS WHEREOF, I have hereunto set my hand this 20 th day of August 2018 at Makati City.

(Sgd) Atty.Kurutong Baleleng


#123 Sketchy Street Makati City
Roll No. 324 1/10/19
IBP No. 1234: 1/3/19
PTR No. 1332: 1/1/19
MCLE NO. 323 : 9/1/19

SUBSCRIBED and sworn to before me, this 19 th day of April 2019 in the City of Makati Kuratong
Baleleng with Passport No. EEB323 issued on September 2,2018 at DFA San Fernando Papangga

(Sgd). Rem Guevarra


NOTARY PUBLIC
Appointment No. 242
Until August 2019-12-10
Roll no. 24213
IBP No. 1232
PTR No. 234
MCLE Compliance No. 4

Doc No. 32
Page No. 31
Book No. 12
Series of 2018
MOTION FOR BILL OF PARTICULARS

Republic of the Philippines


Regional Trial Court
National Capital Judicial Region
Makati City Branch 1
Shinji Cruze
Plaintiff
-versus - Civil Case No. 3423
For: Sum of Money
Maling Akala
Defendant
x-----------------------------------------------------------------------------------x
MOTION FOR BILL OF PARTICULARS

Defendant thru counsel and unto this Honorable Court respectfully avers:
1. That the plaintiff’s complaint in its par. 3 alleges
“Maling Akala, borrowed money from me on January 10,2010”
2. That said allegation was insufficient and defective in that it fails to specify the amount
3. That a more definite statement on the matter as above indicated is necessary in order to enable
the defendant to properly prepare his responsive pleading
WHEREFORE, defendant prays that plaintiff be ordered to file a bill of particulars of the facts and acts
constituting the conclusion alleged in the complaint.

(Sgd) Atty.Kurutong Baleleng


#123 Sketchy Street Makati City
Roll No. 324 1/10/19
IBP No. 1234: 1/3/19
PTR No. 1332: 1/1/19
MCLE NO. 323 : 9/1/19

NOTICE OF HEARING

BRANCH CLERK OF COURT


Regional Trial Court of Makati
Branch 69

Dear Gentlemen:

The undersigned shall submit the foregoing motion to dismiss for approval and consideration of the
Honorable Court on June 4, 2009 at 10:00 am.

Atty. Kuratong Baleleng


Counsel for Plaintiff
COPY FURNISHED THROUGH PERSONAL SERVICE:
Luigi Canoneo
Counsel for Defendant
No 7 Ayala Avenue Makati
PROOF OF SERVICE

I, Katriona Karaka, messenger of the counsel for defendants personally served the counsel for plaintiff with this
motion to dismiss on June 12, 2011 at its office address in No. 7 Ayala Avenue Makati.

IN WITNESS WHEREOF, I have signed this document on June 13, 2011 in Makati.

Katriona Karaka
Affiant

SUBSRIBED AND SWORN TO BEFORE ME, this 13th day of June in Makati affiant exhibiting his SSS ID
No. 1234-21.

(Sgd). Rem Guevarra


NOTARY PUBLIC
Appointment No. 242
Until August 2019-12-10
Roll no. 24213
IBP No. 1232
PTR No. 234
MCLE Compliance No. 4

Doc No. 32
Page No. 31
Book No. 12
Series of 2019
MINUTES OF MEETING
MARUPOK CORPORATION
Minutes of the Special Meeting of the Board of Directors
Held on 23 August 2017
In Las Piñas City

DIRECTORS PRESENT:

ALLAN PETER CAYETANO


JUN JUN BINAY
ROBERTO CASIMIRO
MALIBAY PEKS

ALSO PRESENT:

RHEA KARUNUNGAN

I. CALL TO ORDER

The Chairman, Allan Peter Cayetano , called the meeting to order and presided over the same. The
Corporate Secretary, Atty. Rhea Karunungan , recorded the minutes of the meeting.

II. CERTIFICATION OF QUORUM AND WAIVER OF NOTICE

The Corporate Secretary certified that a quorum was present for the transaction of business by the
Board. The directors consented to waive their right to notice of the meeting.

III. AUTHORIZATION TO TRANSACT WITH ALLIEDBANKERS INSURANCE


CORPORATION

Upon motion duly made and seconded, the Board passed and approved the following resolutions:

“RESOLVED, that the Corporation is hereby authorized to transact with


ALLIEDBANKERS INSURANCE CORPORATION (Insurer) and to avail of various
insurance policies and other offerings of the insurer ;

“RESOLVED FURTHER, that the Corporation’s Directors, MR.ROMEO P.


CALDERON, whose specimen signature appears below, be authorized to negotiate the terms
and conditions, and execute for and in behalf of the Corporation , any and all documents
necessary to avail of the insurance policies and other offerings of Insurer, to do or cause to be
done such other acts and deeds which may deem necessary, appropriate or advantageous to the
corporation :

ROMEO CALDERON __________________

“RESOLVED FINALLY, that the foregoing authorities shall remain in full force and
effect and binding on the Corporation until a written notice to the contrary is issued by the
Corporation revoking, amending or otherwise modifying the same;

IV. ADJOURNMENT
There being no other matters to discuss, the meeting was adjourned upon motion duly made and
seconded

CERTIFIED CORRECT:

RHEA KARUNUNGAN
Corporate Secretary

ATTESTED:

ALLAN PETER CAYETANO


Chairman

MINUTES READ AND APPROVED:

ALLAN PETER CAYETANO


JUN JUN BINAY
ROBERTO CASIMIRO
MALIBAY PEKS
PROBATE OF WILL
Republic of the Philippines
Regional Trial Court
National Capital Judicial Region
Makati City Branch 1
Petition for Probate of the last will and testament
of the late Kapuspalad Dela Cruz

Junakiz Dela Cruz in his capacity as the named


Executor in the last will and testament of the late
Kapuspalad Dela Cruz

Petitioner

SP. Proc No.____


x-----------------------------------------------------------------------------------x
PETITION
The Petitioner thru counsel respectfully avers the following:
1. On October 20,2015, deceased Kapuspalad Dela Cruz died in the City of Makati then residing at
28 San Lazaro Street Makati which was his residence at the time of his death, leaving a will, true
copy of which is attached hereto as Annex A and made an integral part hereof.
2. That petitioner, of legal age and resident of 111 Recto Ave. Manila is the executor in said will
3. The subscribing witnesses to the will are
Name Address
Vea Binenie 32 Legarda St.Sampaloc Manila
Bibi Nga 13 Kalatoy St. Manila
Semana Santa 213 Mabuhay St. Manila

4. The petitioner is legally qualified to act as executor and hereby consents to accept said trust;
5. The property left by the decedent consist of real and personal property, the gross value of which
is FIVE MILLION P5,000,000.00;
6. The testator at the time of the execution of the said will was 72 years old, of sound and disposing
mind, and not acting under duress, fraud or undue influence and was in every respect capacitated
to dispose of his estate
7. Petitioner as named executor, moves and prays that letters testamentary be issued to him; that he
is competent to serve as executor and is ready to give a bond as required by the Rules of Court.

WHEREFORE, it is respectfully prayed upon proper notice and hearing:

1. The above-mentioned will be admitted to probate ;


2. Letters testamentary (or of administration) be issued to herein
petitioners without bond;
3. Such other relief be granted as may be deemed just and equitable in
the premises

City of Makati, February 20, 2019

(Sgd) Atty.Kurutong Baleleng


#123 Sketchy Street Makati City
Roll No. 324 1/10/19
IBP No. 1234: 1/3/19
PTR No. 1332: 1/1/19
MCLE NO. 323 : 9/1/19

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