Beruflich Dokumente
Kultur Dokumente
COMPILATION
______________________________________________________________________________________________
ACKNOWLEDGMENT
SECRETARY’S CERTIFICATE
I, (name of Corporate Secretary), of legal age, Filipino, being the duly elected and
qualified Corporate Secretary of (name of applicant firm), a corporation duly organized and
existing under the laws of the Philippines, with office address at (office address of applicant
firm), under oath, do hereby certify that at the special meeting of the Board of Directors of the
Corporation held on (date of special meeting), the following resolution was unanimously
adopted:
____________________
Corporate
Secretary
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2. That I have not commenced any action or proceeding involving the same issue or subject
matter, and specifically the same check/s in the Supreme Court, the Court of Appeals or
any other tribunal or agency, particularly before the Office of the City Prosecutor of
_______________________; that to the best of my knowledge, no such action or
proceeding is pending in the Supreme Court, the Court of Appeals or any other tribunal or
agency, and that, if I should learn thereafter that a similar action or proceeding has been
filed or is pending before these courts or tribunal or agency, I undertake to report that fact
to the Court within five (5) days therefrom.
3. That the filing of this case is not in violation of the rule against splitting a single cause of
action or multiplicity of suits.
4. That I knowingly and voluntarily waive and forego the institution of any criminal
complaint for Violation of Batas Pambansa Blg. 22 against the defendant herein based on
the same check/s subject matter of this Small Claims Complaint.
__________________________
Affiant
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Iloilo City
PAOLO D. CRUZ,
Defendant.
x -----------------------x
COMPLAINT
Plaintiff, through the undersigned counsel unto this Honorable Court, hereby respectfully
avers:
1. That plaintiff is of legal age, Filipino, married, and a resident of Alta Tierra Village,
Jaro, Iloilo City, Philippines while the defendant is also of legal age, married, Filipino and a
resident of Brgy. Dungon A., Jaro, Iloilo City, Philippines where summons and court processes
may be served;
2. That on February 14, 2013, the defendant borrowed from the plaintiff a sum of money
amounting to One Million Pesos (PhP1,000,000.00) with an agreed interest of five percent (5%)
per month as evidenced by a promissory note herein attached as Annex “A” and form an integral
part of this complaint;
3. That as shown in the attached promissory note, the indebtedness of the defendant has
become due and demandable on February 14, 2014;
4. That despite plaintiff's repeated demands, both written and verbal, defendant failed,
neglected and refused to fulfill obligations without just and valid grounds to the continued
damage and prejudice of plaintiff, as evidenced by Annex “B” – Demand Letters;
5. That the plaintiff in order to enforce his rights and interests, has sought the services of
a legal counsel with attorney’s fees amounting to One Hundred Thousand Pesos (PhP
100,000.00) and an appearance fee of Two Thousand Pesos (PhP 2,000.00) per hearing as
evidenced by Annex “C” – Contract for Legal Services;
6. That the plaintiff has paid for litigation expenses amounting to Twenty Thousand Pesos
(PhP 20,000.00) as evidenced by Annex “D” – Official Receipt;
7. That the plaintiff has suffered moral damages at the sum discretion of the Honorable
Court;
a. the sum of One Million Pesos (PhP 1,000,000.00) plus interest at the rate of five
percent (5%) per month as stipulated in the promissory note;
Other reliefs and remedies deemed just and equitable under the foregoing premises are
likewise prayed for.
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I, MIA C. SANCHEZ, of legal age, Filipino, married, and a resident of Alta Tierra
Village, Jaro, Iloilo City, Philippines, after being sworn in accordance with law, hereby depose
and say:
(2) That I have caused the preparation of the above Complaint and I have read the
same and understood the contents thereof;
(3) That the allegations contained therein are true and correct of my own personal
knowledge and based on authentic records;
(4) That I further certify that: I have not theretofore commenced any other action or
proceeding or filed any claim involving the same issues or matter in any court, tribunal, or
quasi-judicial agency and, to the best of my knowledge, no such action or proceeding is pending
therein; if I should thereafter learn that the same or similar action or proceeding
has been filed or is pending before the Supreme Court, the Court of Appeals, or any other
tribunal or quasi-judicial agency, I undertake to report such fact within five (5) days therefrom
to the court or agency wherein the original pleading and sworn
certification contemplated herein have been filed.
IN WITNESS WHEREOF, I have hereunto set my hand this 6th day of December 2014
at Iloilo City, Philippines.
MIA C. SANCHEZ
Affiant
TIN 98765-003; Iloilo City
SUBSCRIBED AND SWORN to before me, this 6th day of December 2014, affiant
exhibiting to me his Tax Identification Card as shown above below his name as competent
evidence of his identity.
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ESTA PADORA,
Plaintiff,
MANGGA GANTSO,
Defendant.
x -------------------------- x
COMPLAINT
1. Plaintiff is a Filipino, of legal age, and resident of 6750 Forbes Park, Makati City;
defendant is also a Filipino, of legal age and resident of 6752, Forbes Park, Makati City, where
he may be served with summons and other processes.
2. Sometime in January 2005 and over a period of six (6) months, defendant borrowed
certain amounts from plaintiff. Defendant promised to pay these amounts on an installment basis
monthly. These amounts now total Nine Hundred Thousand Pesos (P900,000.00).
3. Despite repeated demands, both oral and written, defendant failed or has refused to
pay any amount to plaintiff as no installment payment has even been made. A copy each of
plaintiff’s two (2) demand letters is attached as ANNEX A and B.
5. Defendant’s obligation is due and demandable and plaintiff is entitled to the payment
of the entire amount of Nine Hundred Thousand Pesos (P900,000.00) plus legal interest.
6. By reason of defendant’s unreasonable failure or refusal to pay his due and
demandable obligation, plaintiff was forced to engage the services of counsel to vindicate his
rights thereby committing himself to pay legal expenses amounting to Fifty Thousand Pesos
(P50,000.00).
WHEREFORE, plaintiff respectfully prays for judgment in his favor through a Decision
directing defendant to pay him NINE HUNDRED THOUSAND PESOS (P900,000.00), with
legal interest, as ACTUAL DAMAGES and FIFTY THOUSAND PESOS (P50,000.00) as
Attorney’s Fees.
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ESTAFA DAMAGA,
Plaintiff,
Civil Case No. 000883
For: Sum of Money
- versus –
LIWANAG CORPORATION,
Defendant.
x -------------------------- x
COMPLAINT
1. Plaintiff is a Filipino, of legal age, and resident of 6750 Forbes Park, Makati City;
defendant is also a Filipino, of legal age and resident of 6752, Forbes Park, Makati City, where
he may be served with summons and other processes.
2. Sometime in January 2005 and over a period of six (6) months, defendant, a
corporation duly organized under the laws of the Philippines, borrowed certain amounts from
plaintiff through its president Antonio Liwanag. Defendant promised to pay these amounts on an
installment basis monthly. These amounts now total Nine Hundred Thousand Pesos
(P900,000.00).
3. Despite repeated demands, both oral and written, defendant failed or has refused to
pay any amount to plaintiff as no installment payment has even been made. A copy each of
plaintiff’s two (2) demand letters is attached as ANNEX A and B.
5. Defendant’s obligation is due and demandable and plaintiff is entitled to the payment
of the entire amount of Nine Hundred Thousand Pesos (P900,000.00) plus legal interest.
WHEREFORE, plaintiff respectfully prays for judgment in his favor through a Decision
directing defendant to pay him NINE HUNDRED THOUSAND PESOS (P900,000.00), with
legal interest, as ACTUAL DAMAGES and FIFTY THOUSAND PESOS (P50,000.00) as
Attorney’s Fees.
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Juan De la Cruz,
Defendant.
x---------------------------------------x
Plaintiff XYZ Company, Inc., is a corporation duly organized and existing under and by
virtue of the laws of the Philippines, with principal offices at 1234 Ayala Ave., Makati City,
where it may be served with summons and other legal processes.
XYZ Corporation,
Plaintiff,
David Fermosa,
Defendant.
x-------------------------------------x
Plaintiff XYZ Company, Inc., is a corporation with principal offices at 1234 Ayala Ave.,
Makati City, where it may be served with summons and other legal processes (keeping silent as
to the fact that the plaintiff corporation was not duly-registered as a corporation because the rule
is that where a corporation, not registered, is suing a third person on a contract the latter entered
into with it, he may not be heard to dispute the existence of said corporation, as he is stopped
from denying the corporate existence) ;
ESTAFA DAMAGA,
Plaintiff,
Civil Case No. 000883
For: Sum of Money
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______________________________________________________________________________________________
- versus –
COMPLAINT
1. Plaintiff is a Filipino, of legal age, and resident of 6750 Forbes Park, Makati City;
defendant is also a Filipino, of legal age and resident of 6752, Forbes Park, Makati City, where
he may be served with summons and other processes.
2. Sometime in January 2005 and over a period of six (6) months, defendant, a
corporation, through its president Antonio Liwanag, borrowed certain amounts from plaintiff
through its president Antonio Liwanag. Defendant promised to pay these amounts on an
installment basis monthly. These amounts now total Nine Hundred Thousand Pesos
(P900,000.00).
3. Despite repeated demands, both oral and written, defendant, said corporation has
refused to pay any amount to plaintiff, as no installment payment has even been made, alleging
that it was not liable as it did not register itself as a corporation. A copy each of plaintiff’s two (2)
demand letters is attached as ANNEX A and B.
4. Investigation shows that the persons who claimed to be president of said corporation
who were also the same person dealing with the plaintiff in connection with the loan and who
represented that the defendant Liwanag Corporation was duly registered with the Securities and
Exchange Commission, when in fact it was not.
5. Defendant’s obligation is due and demandable and plaintiff is entitled to the payment
of the entire amount of Nine Hundred Thousand Pesos (P900,000.00) plus legal interest.
WHEREFORE, plaintiff respectfully prays for judgment in his favor through a Decision
directing defendant to pay him NINE HUNDRED THOUSAND PESOS (P900,000.00), with
legal interest, as ACTUAL DAMAGES and FIFTY THOUSAND PESOS (P50,000.00) as
Attorney’s Fees.
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MIRANDA CURL
Affiant
Philippine Passport No. 123456
valid until January 13, 2018
SUBCRIBED AND SWORN TO before me this 30th day of January 2014 in Imus City,
Cavite, Philippines, affiant exhibiting to me her competent evidence of identity indicated below
his above- stated name.
Doc. No. _____;
Page No. _____;
Book No. _____;
Series of 2014.
RON JEREMY
Affiant (Father)
SUBCRIBED AND SWORN TO before me this 30th day of January 2014 in Imus City,
Cavite, Philippines, affiant exhibiting to me her Philippine Passport No. 123456 issued in Manila
on January 12, 2014 and valid until January 13, 2018.
Doc. No. _____;
Page No. _____;
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Plaintiffs,
-versus- Civil Case No. ____
Derivative suit
Defendants.
x---------------------------------------x
Plaintiffs Juan de Bagyo and Pedro Pobre, both of legal age, are minority stockholders of
plaintiff ABC Corporation, a corporation duly-organized and existing under and by virtue of the
laws of the Philippines, with principal offices at 532 Ayala Ave., Makati City, and are suing in
this derivative suit in the name and as representatives of said corporation.
Defendants are members of the board of directors of said corporation, who in breach of
trust, committed acts inimical to the interests of the corporation, namely: allege facts showing
violations of Sec. 31 of the Corporate Code, to the damage and prejudice of the corporation.
Allege other requirements of derivative suit, as prescribed in Rule 8 of the Interim Rules
of Procedure for Intra-Corporate controversies, such as that plaintiffs exerted all reasonable
efforts, particularly describing such efforts, to exhaust all remedies available under the articles of
incorporation, by-laws or rules governing the corporation to obtain relief they desire; that no
appraisal rights nuisance or harassment suit.
Etc.
ANSWER
Administrator for the Estate of Miguelito Cruz in the above-entitled case, thru counsel, in answer
to the claim of Juan Dela Cruz in said estate, states:
That he denies the said claim on the ground that he has no knowledge of the claim to
enable him to deny or admit specifically since this was not communicated to him.
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THE PEOPLE OF
THE PHILIPPINES
Plaintiff,
Criminal Case No. ________________
- versus –
x---------------------x
INFORMATION
The undersigned Assistant Prosecutor, upon sworn complaint original filed by the
offended party, accuses Spouses Henry and Judith Cruz of the crime of CORRUPTION OF
MINORS, committed as follows:
That on or about December 21, 2017 in the city of Cebu, Philippines, within the
jurisdiction of this court, the said accused, did then and there, willfully, unlawfully, feloniously
and maliciously conceal their true name to police officer Ricardo Manggubat, duly-appointed,
qualified and acting as such, and while in the performance of his duties, asked the said accused
for their true name, and the said accused did then and there willfully, unlawfully, and feloniously
and with abuse of confidence and authority, promote and facilitate the prostitution and corruption
of a girl, named Juanita Delos Reyes, a minor of Nine years of age, for the purpose of satisfying
the carnal lust of others.
Contrary to law.
December 28, 2017, Cebu City
BAIL RECOMMENDED:
Certification
AFFIDAVIT OF GUARDIANSHIP
I, Daisy Baluyot,of legal age, widow, Filipino citizen, and presently residing at Maria
Luisa, Cebu City, after having been duly sworn to in accordance with law, do hereby depose and
say:
1. ThatI am the Mother and guardian of the following minors who have an interest in the estate
of the late Juan Baluyot payable by ___________;
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2. That the above mentioned minors are under my care and custody;
3. That I am competent to receive in behalf of the said minors any amount/s due them; and
5. ThatI am executing this affidavit to attest to the truth of all the foregoing statements and for
whatever legal purpose it may serve.
IN WITNESS WHEREOF, I have hereunto set my hand this 1st day of February 2018 at Cebu
City, Philippines.
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AA,BB,CC,DD,EE,FF
Plaintiffs,
- versus- Civil Case No. 432
Rough Riders Bus Co.
Defendant.
x-------------------------------x
Plaintiffs are of legal age and are the heirs of the passengers of the bus owned by the
defendant as common carrier, bound for Bogo City on July 15, 2010, when said bus turned turtle
due to its driver’s driving recklessly and negligently, resulting in the death of all passengers, and
causing plaintiffs to suffer damages in the amount of no less than 300,000 PHP each for medical
ses and loss of earnings, and involving questions of law and of fact common to all plaintiffs.
x-----------------------------x
Plaintiffs are of legal age and are members of the voluntary association, known as ACD
Voluntary Association, which is composed of over 500 members, who are required to contribute
P100.00 monthly, in return for the benefits extended to its members, Plaintiffs are suing on their
own behalf as members of said association and on behalf of all other members thereof, who are
so numerous that it is impracticable to implead them all as plaintiffs.
Defendants, as officers of said association, have mismanaged its affairs, did not render
any accounting to the members, and appropriated the members’ contribution unto themselves,
thereby compelling the members thereof to compel said officers to wind up the affairs of the
association and to require defendants as officers thereof to render an accounting of the money
and property of the association.
It has been held: “An action instituted by several hundred members of a voluntary
association against their officers to compel them to wind up the associations’ affairs and render
an accounting to the money and property in their possession has been held to be a class suit. In
that case there was in truth one single right of action sought to be enforced by the numerous
plaintiffs, not separate, individual, distinct rights pertaining independently to them.
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-Versus-
x-------------------------------------------------x
- This is an action for partition of a parcel of land consisting of 15,000 sq,m., located in
Quezon City, and which defendants inherited from their parents, when the latter died in an
accident on March 2, 2005, and since said date, defendant Samson dela Cruz, their elder
brother, has been occupying the same and reaping all its income to himself.
- The instant suit being a suit by and among members of the same family, plaintiffs exerted all
efforts to reach an amicable settlement of the case, by talking to defendant Samson dela
Cruz, convincing him to agree to extra-judicial partition of the property and even informing
him that plaintiffs are willing to forego any and even informing him that plaintiffs are
willing to forego any claim of accounting to convince him to settle the case amicably, but,
all such efforts proved useless.
- Plaintiffs had asked Myrna dela Cruz, being a co-owner to join plaintiffs as co-plaintiff, but
the latter refused, constraining plaintiffs to implead her as a defendant.
-Versus-
x-------------------------------------------------x
[1] On 1 June 2006, Plaintiff James Reid was made a party to the case although he
should have not been impleaded.
[2] That plaintiff is not a party in interest to the issue in the instant case since the actual
person in interest is a certain James Red.
[3] WHEREFORE, plaintiff respectfully prays that plaintiff James Reid be dropped as a
party to the case.
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COMPLAINT
COMES NOW, the Plaintiff, through the undersigned counsel, and to this
Honorable Court alleges:
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4. That on October 20, 2017, and for the next three (3) days
thereafter, plaintiff demanded from defendant the return of the said car;
but defendant avoided returning the car by giving one reason or another;
5. That said car has not been taken for a tax assessment or fine
pursuant to law, or seized on execution or attached;
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ZHIA CRUZ,
Plaintiff,
4. That on October 20, 2016, and for the next three (3) days
thereafter,the plaintiff upon going to office tried to turn on the
car but it wont start.
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Branch 54
Davao City
Fe Tuad,
Plaintiff, CIVIL CASE no.
1232143
FOR: Damages for
death, earning
capacity, Moral
Damages and
Attorney's fees
- versus –
x- - - - - - - - - - - -x
COMPLAINT
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any and all incidents that may occur while the said vehicle is in their
custody.
In driving back from the beach, Aurelio Laxa lost control of the
vehicle while negotiating a curve causing it to turn turtle resulting in the
death of one of its passengers Romeo Tuadles.
Due to the sudden death of Romeo Tuadles, his wife and children
suffered mental anguish and serious anxiety.
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PRAYER
WHEREFORE, the above premises considered, it is respectfully
prayed of this Honorable Court after hearing on the merits, that:
Other reliefs just and equitable under the premises are likewise
prayed for.
FORM NO. 21: Complaint for Ejectment with Damages
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X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - X
COMPLAINT
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For the grave injustice, the plaintiff suffered much from the
defendants. Defendants should be directed to desist from further
unlawfully and illegally possessing the subject lot with any color of
authority or lawful court order and for them to be ordered to vacate the
same.
Great and irreparable damage and injury has been suffered by the
plaintiffs and will continue to suffer unless a preliminary mandatory
injuction be issued directing the defendants to vacate the land and leave
the premises because their actions had no place in the civilized society
when they by force immediately grabbed the land, possessed it despite of
the fact that plaintiffs were in lawful possession of the same in the concept
of an owner for almost 50 long years, Defendants should not gad put the
law into their own hands.
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PR AY E R
WHEREFORE, premises considered, it is most respectfully prayed
of this Honorable Court that judgment be rendered in favor of the
plaintiffs and against the defendants,
a. By directing them to restitute and vacate the land subject of
this case
b. Defendants be ordered to pay the plaintiffs jointly and
severally the following:
Plaintiffs also pray for such other reliefs and remedies just and
equitable under the circumstances.
Bogo City, Cebu, Philippines, October 5, 2010.
ATTY. JOVEN
MONDIGO, JR.
MADEJA-MONDIGO LAW
OFFICE
PTR NO. 6412029 1/28/10
IBP ROLL NO. 813584
1/28/10
ROLL NO. 47853
MCLE NO. 0016617
Counsel for Plaintiffs
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CELIA D. DIGNOS
CTC NO.
Issued on
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At
ACKNOWLEDGMENT
BEFORE ME, Notary Public for and in the City of Bogo, Cebu,
Philippines, personally appeared CARMELITA D. URSABIA, MYRNA
D. LEQUIN and CELIA D. DIGNOS with their Community Tax
Certificates indicated below their names, known to me and to me known
to be the persons who executed and signed the foregoing instrument and
they acknowledged to me that the same is their free and voluntary act and
deed.
ATTY. CESAR M.
MADEJA
Notary Public
Until December 2010
Office Address: Cogon, Bogo
City, Cebu
Roll No. 59950
PTR 0647234, 12.08.10,
Bogo City, Cebu
IBP 0992242, 10.30.10, Cebu
MCLE Compliance No. IV-
0011872
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Doc No.
Page No.
Book No.
Series of
Zendrix Echavez,
Plaintiff,
Civil Case No. 16
-versus-
For: Ejectment
Marilyn Cosares,
Defendant.
XX - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - XX
COMPLAINT
PLAINTIFF, by counsel, respectfully states that:
The Parties
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The Facts
1. By virtue of a contract of lease, the plaintiff leased unto the
defendant the aforesaid apartment for a consideration of P5,000.00 a
month as rental to be paid within the first ten (10) days of each month
starting November 3, 2011;
2. The defendant failed to pay the agreed rental for several months
starting February 19, 2012 up to the present;
Prayer
WHEREFORE, plaintiff respectfully prays for judgement
in his favor by ordering defendant to vacate the property and
peacefully turn over possession to plaintiff and for defendant to
pay plaintiff the amount of One Million Two Hundred Thousand
Pesos (P 1, 200,000.00) representing rentals on the machineries for
eight (8) months and fifty thousand pesos (50,000.00) for
Attorney’s Fees
Other just and equitable reliefs are also prayed for.
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1. That on July 10, 2013, I have entered into a Deed of Conditional Sale which
was acknowledged on the same date before Notary Public Juan Tamad of
Makati City and entered in his Notarial Register as Doc. No. 2, Page 2,
Book II, Series of 2013. A copy of the said Deed is hereto attached as
ANNEX “A” and made an integral part of this Affidavit;
2. That in the said Deed of Conditional Sale, I was the VENDEE of a certain
parcel of land covered by Transfer Certificate of Title No. 111222, more
particularly described as follows:
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(Technical Description of Property)
4. That the VENDOR in the said Deed of Conditional Sale agreed that upon
its execution, said Deed shall be annotated in the Title with
the Office of the Register of Deeds of Makati City;
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X------------ ---------------X
1. AFFIDAVIT OF COMPLIANCE
I, Marjorie C. Echavez, of legal age, single, a resident of Escario
Extension C.F 120., Cebu, Philippines, after being sworn to in accordance
with law, depose and state:
That I am a graduate of Bachelor of Arts Major in Political Science
as my pre-law degree on March 18, 2013.
That I have submitted my transcript of records, 2 pcs. (1x1 picture)
for registrar and school I.D with royal blue background, 2 pcs. (2x2
picture) for student file, certificate of good moral character, and an NSO
authenticated birth Certificate on May 28, 2014 at University of Southern
Philippines Foundation, Salinas Drive Lahug. Cebu, Philippines.
That I have complied with all other requirements for student
admission set forth by the University of Southern Philippines Foundation,
College of Law.
AFFIANT FURTHER SAYETH NAUGHT. IN WITNESS WHEREOF, I
have here unto set my hand this 27th day of November, 2016 at
Cebu,City, Philippines.
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______________________________________________________________________________________________
Marjorie C. Echavez
Affiant
X-----------------------X
ACKNOWLEDGEMENT
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Zendrix Echavez,
Plaintiff,
Civil Case No. 16
-versus- For: Notice of Lis Pendens
Marilyn Cosares,
Defendant.
X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
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Respectfully submitted.
ATTY. MARJORIE
ECHAVEZ Counsel
for the Plaintiff
Copy Furnished:
Zendrix Echavez,
Plaintiff,
Civil Case No. 16
-versus- For: Motion to Cancel Lis Pendens
Marilyn Cosares,
Defendant.
XX - - - - - - - - - - - - - - - - - - - - - - - - - - - - - XX
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RELIEF
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That I hereby direct that the executor and administrator of this Last
Will and Testament or his substitute shall be excused from posting any
bond;
That I hereby revoke, set aside and annul any other will or
testamentary dispositions I have made, executed, signed or published.
MARJORIE C
ECHAVEZ
(Testator)
ATTESTATION CLAUSE
We, the undersigned attesting witnesses, do hereby affirm that the
foregoing is the Last Will and Testament of MARJORIE C ECHAVEZ and
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we certify that the testator executed this document while of sound mind
and memory. That the testator signed this document in our presence, at the
bottom of the last page and on the left hand margin of each and every
page, and we, in turn, at the testator’s behest have witnessed and signed
the same in every page thereof, on the left margin in the presence of the
testator and of the notary public, this 28 th day of July, 2016 at Bogo City,
Cebu, Philippines.
JOINT ACKNOWLEDGMENT
Witness Arlene Diaz Lim, with CTC No. 1234568B issued at Bogo
City, Cebu on January 14, 2016;
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all known to me to be the same persons who executed the foregoing Will,
the first as testator and the last three as instrumental witnesses, and they
respectively acknowledged to me that the same as their own free act and
deed.
This Last Will and Testament consists of three (3) pages, including
the page on which this acknowledgment is written, and has been signed on
the left margin of each and every page thereof by the testator and his
witnesses, and sealed with my notarial seal.
Doc. No._____;
Page No._____;
Book No. ____ ;
Series of 2016.
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______________________________________________________________________________________________
AFFIDAVIT
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______________________________________________________________________________________________
______________________
(Affiant)
1. That the said corporation has been duly organized and existing
under the laws of the Philippines, having its principal place of
business at Maguikay , Mandaue City, Cebu;
2. That the authorized capital stock of said corporation is ONE
MILLION PESOS (P 1,000,000) Philippine currency, divided
into 10,000 shares of per value of ONE HUNDRED PESOS (P
100) per share;
3. That in a meeting of the stockholders of the corporation held in
Maguikay, Mandaue City, Cebu on March 7, 2017, the
dissolution of the said corporation was resolved upon by the
affirmative vote of the stockholders holding or representing at
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______________________________________________________________________________________________
48
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______________________________________________________________________________________________
1. That petitioner is of legal age, married, Filipino citizen and residing at 222
Teresa Street, Valenzuela, Makati City; that respondent REGIE STER is
the Register of Deeds of Makati City where he may be served with
summons and other court processes;
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______________________________________________________________________________________________
3. That on April 5, 2013 the office of the register of Deeds of Makati City was
burned and all the Torrens Titles in said office including T.C.T. No. T-
123456 were burned;
Respectfully submitted.
15 August 2013
City of Makati.
ATTY. VX
YZ
Counsel for the Petitioner
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______________________________________________________________________________________________
MR. X,
Petitioner,
CIVIL CASE NO.
123
-versus-
For: Sum of Money with pray
er
for the issuance of writ
of preliminary attachment
MR. Y,
Respondent
x------------------ -----------------------------------------------x
COMPLAINT
COMES NOW , the plaintiff, through the undersigned counsel, and
unto this honorable court, most respectfully avers:
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______________________________________________________________________________________________
5. That on its maturity date, the said checks was dishonored by the
drawee banks upon presentment for payment for reason
ACCOUNT CLOSED, as evidenced by the notice of dishonor
issued by the bank which is hereto attached as Annex “H” hereof;
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______________________________________________________________________________________________
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______________________________________________________________________________________________
6. Other reliefs which are just and equitable are likewise prayed for.
By :ABOGADO A.
ABOGADO
IBP No. 1231231/2-5-05
PTRNo.123/10-2203/
Leg.Roll No. 123123
FORM NO. 34: Petition for Naturalization
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______________________________________________________________________________________________
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______________________________________________________________________________________________
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______________________________________________________________________________________________
57
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______________________________________________________________________________________________
SERGEI D. IVANOVICH
Petirioner
Brgy.55-B Barit, Laoag City, Ilocos
Norte
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______________________________________________________________________________________________
That I have read the allegations therein and the same are true
and correct to the best of my knowledge and belief.
SERGEI D. IVANOVICH
CTC #0123456
Issued at: Laoag City
Issued on: July 25,
2014
ACKNOWLEDGEMENT
BEFORE ME, a Notary Public in the City of Laoag, Province of Ilocos
Norte, Philippines, personally appeared SERGEI DRAGUNOV
IVANOVICH for his execution of a PETITION FOR
NATURALIZATION with a CTC numbered 79134679.
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______________________________________________________________________________________________
The City Prosecutor of Cebu City and in behalf of the City of Cebu, unto
this Honorable Court, respectfully avers that:
1. Juan dela Cruz, a Filipino citizen, and resident of the City of Cebu,
Province of Cebu, died intestate in the said City on March 2, 2016.
2. At the time of his death, he left real property in the City of Cebu,
Province of Cebu to wit:
A parcel of land with an area of 893, 00 square meters, located at
Barangay Lahug, Cebu City covered by Transfer Certificate of Title No.
312445.
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______________________________________________________________________________________________
Marjorie C Echavez
City Prosecutor
For: Adultery
X______________________x
COMPLAINT
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______________________________________________________________________________________________
Marjorie C. Echavez
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______________________________________________________________________________________________
NOTARY PUBLIC
IBP No. 1290-109-1
MCLE No. 62710
PTR No. 125
Roll of Attorney No. 09288
Doc. No.I-09
Page No.4
Book No. _52
Series of 2016
Marjorie C. Echavez
NOTARY PUBLIC
IBP No. 12970-109-1
MCLE No. 62710
PTR No. 125
Roll of Attorney No. 09288
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______________________________________________________________________________________________
COMPLAINT
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______________________________________________________________________________________________
6. The contract also provides that the defendant should also take
care of the property and its premises” with the utmost
diligence”.
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______________________________________________________________________________________________
PRAYER
a. The defendant shall vacate the house unit owned by the plaintiff.
b. The defendant shall be ordered to pay P 120, 000 for the Attorney’s Fees.
Such other reliefs and remedies under the premises are likewise
prayed for.
Baguio City, Philippines, this 28th day of September 2008.
Poging Attorney
Counsel for the Plaintiff
PTR No. 18909595:1-04-07:B.C.
IBP No, 693095:1-04-07:B.C.
Roll No. 42481:5-10-97: Manila
Rm. 4 2/F Baguio Boating Center
180 Burnham Lake, Baguio City
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______________________________________________________________________________________________
Uzumaki Naruto
Complainant
Poging Attorney
Counsel for the Plaintiff
PTR No. 18909595:1-04-07:B.C.
IBP No, 693095:1-04-07:B.C.
Roll No. 42481:5-10-97: Manila
Rm. 4 2/F Baguio Boating Center
180 Burnham Lake,
Baguio City
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______________________________________________________________________________________________
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______________________________________________________________________________________________
Witnesses:
1. Vilma Gasul, Lawaan, New Washington, Antique
2. Antonio Gasul, Sitio Cantecson, Gairan, Bogo City, Cebu
3. Winda Bartolome, Sitio Cantecson, Gairan, Bogo City, Cebu
4. Many others.
CERTIFICATION
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______________________________________________________________________________________________
APPROVED:
ABBY A. MANUEL IRIS R.
SHOVEL
City Prosecutor Prosecutor II
MCLE Compliance No. V-6504 OCP, Bogo
City
dated 3/03/15
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______________________________________________________________________________________________
COMPLAINT
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______________________________________________________________________________________________
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______________________________________________________________________________________________
PETITION
2. That the said minor LOVE VALENTINE, who at the time of the
filing of this petition, is only eight (8) years of age, is a resident of
Pandan Heights, Bogo City, Cebu, Philippines;
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______________________________________________________________________________________________
3. That the said minor is seized of real and personal property located
in Cogon, Bogo City, Cebu, Philippines, of the probable value of
Two Million and Five Hundred Pesos (P2,500,000.00);
5. That the names, ages, and residences of the relatives of the said
minor, and the person having her in his care, are as follows, to wit:
VERIFICATION
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______________________________________________________________________________________________
That he has caused the above petition to be prepared and has read
and knows the contents thereof
RUDOLF VALENTINE
Affiant
ELECTION
CASE NO. 001
- Versus –
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______________________________________________________________________________________________
PEDRO MARCELO,
Respondent.
X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
PETITION
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______________________________________________________________________________________________
x----------------------------------x
COMPLAINT AFFIDAVIT
JURAT
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______________________________________________________________________________________________
__________________
__________________
) S.S.
AFFIDAVIT OF LOSS
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______________________________________________________________________________________________
ELLEN ADARNA
Affiant
_____________________
WITNESS MY HAND AND SEAL this 8th day of January, 2014 in Imus
City, Cavite
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______________________________________________________________________________________________
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______________________________________________________________________________________________
SASHA GREY
Affiant
With Philippine Passport No. 123456
AFFIDAVIT OF AUTHORIZATION
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______________________________________________________________________________________________
2. Through this Affidavit, I hereby authorize Mr. Cedric Lee not only
to use and possess the said property but also to continue paying it
in the event there are still balances to be paid to the developer, and
have it consequently registered in his name.
3. I therefore have executed this Affidavit to attest to the truth I
mentioned herein and for whatever legal purposes it may serve.
SASHA GREY
Affiant
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______________________________________________________________________________________________
ALA TITULO,
Petitioner.
X-----------------------------X
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______________________________________________________________________________________________
Respectfully submitted.
15 August 2013
City of Makati.
FORM NO.48: Action to remove cloud on, or quiet title to, real
property
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______________________________________________________________________________________________
follows, to wit:
______________________________________;
3. That the said sale is forged and fictitious, and is therefore in truth
and in fact invalid;
4. That the existence of the said alleged deed of sale is prejudicial to
the title of the lawful heirs of the deceased upon the above-
described real property;
5. That nequity demands that the sadeed of sale be surrendered and
cancelled, as it is a cloud upon the title of the deceased and his
lawful heirs.
6. WHEREFORE, it is respectfully prayed that:
A. ____________
(Attorney for the Petitioner)
Address
ALEX BERMEJ
Plaintiff, Civil case No. 5524
-versus-
FOR: DAMAGES
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______________________________________________________________________________________________
NOTICE OF HEARING
Sir:
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______________________________________________________________________________________________
Ruben R. Padilla
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______________________________________________________________________________________________
Affiant
avowed under penalty of law to the whole truth of the contents of said
instrument
Copy furnished:
Atty. Marilen Saniel
Counsel for plaintiff
Bgy. San Pedro, PPcit
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______________________________________________________________________________________________
BRANCH 113
Pasay City
-versus-
CIVIL CASE NO. C-QTZ-24-25285-
D For: Declaration of Nullity
of
Marriage
ELLEN A. ADARNA,
Respondnt
X-----------------------------x
On the same date, a Protection Order with application for TPO and
Support Pendente Lite pursuant to Administrative Matter No. 04-10-11-
C or the Rules on Violence Against Women and Their Children Act
involving the above-mentioned parties was filed and raffled before the
Regional Trial Court of Pasay City Branch 113 with Civil Case no.
BCV 2013-84.
That the two petitions involve the same parties with intertwined
issues and subject matters.
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______________________________________________________________________________________________
which may tend to avoid unnecessary costs or delay and to serve the
best interests of the parties and to settle expeditiously the issues
involved
by:
Greetings:
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______________________________________________________________________________________________
NOTICE OF HEARING
Sir:
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______________________________________________________________________________________________
I, JOSEPH D. DAJAY, of legal age and having been duly sworn depose and say:
That I am the messenger of Atty. Fely Q. Baladad, Counsel for the defendant in the case
entitled Alexander Bermejo vs. Roel Ponce de Leon, Civi CA se No. 65448, and that such
messenger I served upon the counsel of adverse party and other parties, the Motion for
Consideration filed in said case, as follows:
Atty. Arnel Belarmino, counsel for the Defendant, by personal service by delivering
personally copy of said Motion upon said lawyer who acknowledged receipt there of as shown
by his signature or initial on the said pleading, this 23rd day of October 2013
IN WITNESS WHEREOF, I have signed this affidavit this 4th day of November 1 2013
at Puerto Princesa City.
JOSEPH D. DAJAY
Affiant
SUBSCRIBED AND SWORN TO BEFORE ME, A Notary public in and for the City of
Puerto Princesa and the Province of Palawan this 3rd day of November 2013. Affiant personally
came and appeared with Driver’s License ID No. D11-125477 issued by the Land Transportation
Office and valid until May 1, 2015, at Puerto Princesa City, bearing his photograph and
signature, known to me as the same person who personally signed the foregoing instrument
before me and avowed under penalty of law to the whole truth of the contents of said instrument
-versus-
CRIMINA CASE NO. C-QTZ-24-25285- For: Qualified
Theft
ELLEN A. ADARNA,
Respondnt
X-----------------------------x
MOTION TO RENDER JUDGMENT
Respondent should have filed his Answer on 21 May 2011 yet, to date, upon verification
with the court records, respondent Jasper Sol Cruz has not yet filed the aforesaid Answer.
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______________________________________________________________________________________________
Private Complainant prays for the speedy resolution of this case as provided for by the
Revised Rules of Court and in consonance with the timeless legal maxim that justice
delayed is justice denied.
PRAYER
by:JEFFREY PARIL
IBP#941296, Sampaloc Chapter, 12-27-2010
PTR#176413, Sampaloc, Manila, 1-2-2012
Attorney’s Roll No. 48000
MCLE Compliance No. II- 0009569
MCLE Compliance No. III- 0000923
MCLE Compliance No. IV- 0007733
Copy furnished:
CLERK OF COURT
Branch 21, Imus City
Greetings:
In view of the nature of the foregoing motion, the undersigned is requesting the Clerk of
Court to submit the same to the Honorable Court immediately upon receipt thereof, for its
consideration and resolution.
JEFFREY PARIL
Notice:
CLERK OF COURT
Regional Trial Court
Branch 21, Imus City
Explanation: Copy of the pleading was furnished to the defendant by registered mail due to the
distance of the undersigned from the said parties, making personal service thereof nopracticable.
JEFFREY PARIL
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______________________________________________________________________________________________
MARIA LOZANO-GARCIA,
Plaintiff, Civil Case No. 622208
For: Unlawful Detainer
-versus-
EUNELDISAN NUNEZ,
Defendant.
X------------------------------------------/
POSITION PAPER
Defendant, through counsel, and unto this Honorable Court respectfully submits this
position paper and in support thereof alleges as follow:
2. On June 1, 2016, Euneldisan Nunez offered to buy the parcel of land, subject in this case,
located at 83 C. Cabantan Street, Barangay Guadalupe, Cebu City owned then by Johnny
Quijada, as it appears in Original Certificate of Title No. OP-41162 as hereto attached as
“ANNEX C”.
3. Due to the the improvements introduced by Euneldisan Nunez, Johnny Quijada agreed to
sell the land particularly described as - a portion of Lot 128-A-2 (LRC) Psd-09—
0064688 LRC Cad. Rec. No. 8467); containing an area of SIX HUNDRED (600)
SQUARE METERS, more or less, for a consideration of Two Million Pesos (Php
2,000,000.00). Johnny Quijada absolutely transferred the above-described land together
with the buildings and improvements existing thereon, more particularly described in
Transfer Certificate Title No. T-157.001, as hereto attached as “ANNEX D”.
4. On October 16, 2018, Euneldisan Nunez received a formal letter from Marie Lozano-
Garcia asking her to immediately vacate the premises and remove all his possessions
found thereat.
5. Efforts at the Lupong Tagapamayapa proved futile on the ground that Euneldisan Nunez,
who is in actual physical possession of the subject property and claims to be the
registered owner thereof, refuses to grant any order to vacate.
6. The Lupong Tagapamayapa was constrained to issue a certificate to file the instant
complaint.
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______________________________________________________________________________________________
DISCUSSION
The plaintiff in this case has no cause of action for an ejectment case for unlawful
detainer.
Without a doubt, the registered owner of real property is entitled to its possession.
However, the owner cannot simply wrest possession thereof from whoever is in actual
occupation of the property. To recover possession, he must resort to the proper judicial
remedy and, once he chooses what action to file, he is required to satisfy the conditions
necessary for such action to prosper.
PRAYER
Other reliefs that are just and equitable under premises are likewise prayed for.
Respectfully Submitted:
Copy Furnished:
(By Registered Mail)
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______________________________________________________________________________________________
MARIA LOZANO-GARCIA,
Plaintiff, Civil Case No. 622208
For:Unlawful Detainer
-versus-
EUNELDISAN NUNEZ,
Defendant.
X------------------------------------------/
PRE-TRIAL BRIEF
I.2 Pursuant to Rule 18 of the 1997 Rules of Civil Procedure, defendant respectfully submits that
the desired terms of any amicable settlement would involve, first, a clarification of the actual
extent of any obligation due and owing to the plaintiff in as much as there is nothing to indicate
defendant’s obligation to plaintiff and second, a schedule of payments.
II.2 Defendant resists plaintiff’s claims based on the failure to state a cause of action because of:
II.2.1 A Deed of Sale entered into by the parties; that there was no right of the plaintiff
violated by the defendant, therefore, lacking in the requisite as to have a cause of action
pursuant to Section 2 of Rule 2 of the 1997 Rules of Civil Procedure.
II.3 Defendant also interposed a compulsory counterclaim for Two Hundred Thousand Pesos
(P200, 000.00)for moral damages and Sixty Three Thousand Pesos (P63, 000.00) for Attorney’s
fees and costs of suit.
b. Paragraph 6 is admitted but only with regard to the receipt of the letter;
c. Paragraph 7 is admitted but only with regard to refusing to vacate the property
III.2 Subject to concrete proposal for stipulation of additional facts from plaintiff during pre-trial
or even thereafter, defendant admits no other facts from the Complaint.
IV.ISSUES TO BE RESOLVED
IV.1 Defendant submits that the following issues put forward by plaintiff are subject to proof:
V. EVIDENCE
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______________________________________________________________________________________________
V.2.1 Defendant himself, who will testify on the true circumstances leading to the filing
of the suit against him;
V.3 Defendant reserves the right to present any and all documentary evidence which shall
become relevant to rebut plaintiff’s claims in the course of trial as well as any other witness
whose testimony will become relevant to belie plaintiff’s witnesses, if necessary.
VI.2 Subject however, to concrete and reasonable request for discovery from plaintiff, defendant
reserved the right to discovery before trial.
RESPECTFULLY SUBMITTED.
Cebu City, January 15, 2019.
By:
Copy Furnished:
(By Registered Mail)
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______________________________________________________________________________________________
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____________________________________________________________________________________________
__
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______________________________________________________________________________________________
100