DEED OF DONATION OF PERSONAL PROPERTY

KNOW ALL MEN BY THESE PRESENTS: That I, Matt S. Reyes, of legal age, residing at 123, Ruby St., San Pablo City, in consideration of natural love and affection and as a pure ?H act of liberality, hereby donate to my sister, Nicole Reyes, my BMW car sedan Model 2003 with Plate No. XXX-111 and color silver, to have and to hold the same unto her said motor vehicle, forever and absolutely. She will start possession of said automobile on December 1, 2003, as I will be out of the country by that date for good; That I, Nicole S. Reyes, of legal age, residing at 123, Ruby St., San Pablo City accepts this donation and hereby extend my sincerest gratitude to my said brother for his generosity and liberality. IN WITNESS WHEREOF, the parties have hereunto set their hands this 13th day of August, 2003 at the City of San Pablo, Philippines.

Matt Reyes Donee

Nicole Reyes Donor

SIGNED IN THE PRESENCE OF:

Midas Marquez

Milo Henarez

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES} PROVINCE OF LAGUNA } SS CITY OF SAN PABLO } BEFORE ME, this 13th day of August, 2003 in the City of San Pablo, Philippines, personally appeared Matt Reyes, exhibiting his Drivers License with no D-16111 issued at San Pablo City, on June 11, 2001, and Nicole Reyes, exhibiting her GSIS ID with no. GB-234 issued AT Quezon City on May 11, 1998 known to me to be the same persons who executed the foregoing instrument, and they acknowledged to me that the same are their free act and deed. IN WITNESS WHEREOF, I have hereunto set my hand and affixed my notarial seal, the day, year, and place above written. Atty. Edmun C. Galvez NOTARY PUBLIC My Commission expires Dec. 31, 2003 IBP No. 1234, 1/2/2003, San Pablo City P.T.R. No. 4567, 2/2/2003, San Pablo City Doc. No. 1; Page No. 2; Book No. 3; Series of 2003.

CONTRACT OF LEASE KNOW ALL MEN BY THESE PRESENTS: This CONTRACT OF LEASE, made and entered into by and between: Nicanor R. Reyes, of legal age, married and residing at Brgy. Oval, Makati City, and hereinafter referred to as the LESSOR, and Oliver S. Banal, also of legal age, married and residing at Brgy. Batong Malake, Makati City, and hereinafter referred to as the LESSEE, WITNESSETH: That WHEREAS, the LESSOR is the registered and absolute owner of a house and lot situated at # 123 Opal St. Makati City; WHEREAS, the LESSOR is willing to lease said property from the LESSOR under the following terms and conditions: 1. That the lease shall be for a period of one year from December 17, 2002 up to December 17, 2003; 2. That the LESSEE shall pay a monthly rental of FIFTY THOUSAND PESOS (P50,000.00), Philippine Currency, payable every 16th day of the month; 3. That the LESSEE upon the signing of this contract shall pay the total amount of ONE HUNDRED FIFTY THOUSAND PESOS (P150,000.00) representing two (2) months deposit and one (1) month advance. That the deposit shall not be considered as payment for rental but will be reimbursed by the LESSOR upon the termination of this contract, unless the leased property suffers damages or the LESSEE has unpaid utility and water bills in which case, said bills and damages will be paid out of the deposit; 4. That electric and water bills shall be for the account of the LESSEE, the exact amount of which will be based on the electric and water reading for each month; 5. That the leased premises shall be devoted exclusively for residential purposes only; 6. That all improvements to be made or introduced on the premises shall require the prior consent of the LESSOR and that improvements that can no longer be removed by the LESSEE shall become the property of the LESSOR; 7. That any expenses for repair arising from damage willfully and knowingly caused by the LESSEE on the premises shall be shouldered by the LESSEE; 8. That under no circumstance will the leased premises be subleased to any other person or entity without the written consent and approval of the LESSOR; 9. That if said premises is not surrendered to the LESSOR at the expiration of the lease contract, the LESSEE shall be responsible to the LESSOR for all damages which the LESSOR may suffer by reason thereof; 10. That the LESSEE hereby agrees to return the leased premises at the expiration of the contract in as good a condition as reasonable wear and tear will permit without any delay whatsoever; 11. That in case the LESSEE shall have arrears in rental payments and unable to pay said arrears before vacating the premises, the LESSOR shall have the option to take possession of any tangible and valuable property to offset the amount of rental arrears without the need of judicial action; 12. That in case the leased premises shall be abandoned, vacated or deserted for a period of one (1) week, without any previous notice to the LESSOR and during the time the LESSEE is in default in the payment of the monthly rental, then under such circumstances the LESSOR can

consider the leased premises as legally abandoned and may enter the premises and take possession thereof without prejudice to its right of action against the LESSEE; 13. The LESSOR reserves the right to increase the rental rate by ten (10%) per cent after one (1) year and the contract is renewed by mutual agreement of the parties; 14. That the LESSEE is obliged to observe cleanliness and maintain peaceful condition inside and outside the premises; 15. That the LESSEE hereby warrants that he read and understood all the foregoing provisions of this contract and shall abide by the same, otherwise, any violation will subject the LESSEE to ejectment and other legal sanctions. IN WITNESS WHEREOF, the parties have hereunto set their hands this 13th day of August 2002 in the City of Makati, Philippines.

Nicanor R. Reyes LESSEE SIGNED IN THE PRESENCE OF:

Oliver S. Banal LESSOR

Myla Reyes

Jorge Javier ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES} CITY OF MAKATI

} SS

BEFORE ME, this 13th day of August, 2002 in the City of Makati, Philippines, personally appeared Nicanor R. Reyes, exhibiting his Drivers License with no D-16111 issued at Makati City, on June 11, 2001, and Oliver S. Banal, exhibiting his GSIS ID with no. GB-234 issued at Quezon City on May 11, 1998 known to me to be the same persons who executed the foregoing instrument, and they acknowledged to me that the same are their free act and deed. This instrument, consisting of two (2) pages including the page on which this acknowledgement is written, has been signed on the left margin of each page thereof by Nicanor R. Reyes and Oliver S. Banal and their witnesses, and sealed with my notarial seal. IN WITNESS WHEREOF, I have hereunto set my hand and affixed my notarial seal, the day, year, and place above written.

Atty. Edmun C. Galvez NOTARY PUBLIC My Commission expires Dec. 31, 2002 IBP No. 1234, 1/2/2002, San Pablo City P.T.R. No. 4567, 2/2/2002, San Pablo City Doc. No. 1; Page No. 2; Book No. 3; Series of 2002.

CHATTEL MORTGAGE

KNOW ALL MEN BY THESE PRESENTS: This CHATTEL MORTGAGE, made and executed by Nicanor R. Reyes, Filipino, of legal age, single, with residence and post-office address at # 32 Brgy Anos, Los Baos, Laguna hereinafter called the MORTGAGOR, in favor of Ramon S. Galvez, Filipino, of legal age, single, with residence and post-office address at # 24 Diamond St. Batong Malake, Los Baos, Laguna hereinafter called the MORTGAGEE, witnesseth: That the MORTGAGOR does hereby convey by way of chattel mortgage unto the MORTGAGEE, the following described personal property, situated and ordinarily presently in the possession of the said MORTGAGOR, to wit: Car Model : Make: Plate No.: Engine No. 4 door sedan Toyota Altis model 2010 XXX-111 4g92-678

That this CHATTEL MORTAGE is given as security for the payment of the MORTGAGEE, of a certain promissory note, dated January 21, 2011 for the sum of Four hundred thousand PESOS (P400,000.00) with interest thereon at the rate of twelve % per centum (12%) per annum, according to the terms thereof.

PROMISSORY NOTE PhP 400,000.00 FOR VALUE RECEIVED, I promise to pay to the order of Ramon S. Galvez the sum of Four Hundred Thousand (PhP 400,000.00), Philippine Currency, on or before December 31, 2011 at his residence at # 24 Diamond St., Batong Malake, Los Baos, Laguna. Failure on my part to comply with this promise on the date aforementioned shall subject the above principal to interest at the rate of 1 % per month and should the collection be made with the services of a lawyer, then the same shall further be subject to 20% attorney's fees. In the event that a case for collection of the sum of money above stated be filed, the principal shall earn further interest at the rate of 12%, plus cost of suit and other expenses. January 21, 2011 at Los Baos, Laguna, Philippines.

NICANOR R. REYES That the condition of this CHATTEL MORTGAGE is such that if the said MORTGAGOR, his heirs, executors, or administrators shall well and truly perform the full obligation above stated according to the terms thereof, this CHATTEL MORTGAGE shall be null and void, otherwise, it shall remain in full force and effect and shall be enforceable in the manner provided by law.

IN WITNESS WHEREOF, the MORTGAGOR has hereunto set his hand this 22 day of January, 2011, in Los Baos, Laguna, Philippines.
nd

__________________________ Nicanor R. Reyes

SIGNED IN THE PRESENCE OF:

_____________________________ Ramon S. Galvez

Myla Reyes

Jorge Javier ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES} PROVINCE OF LAGUNA } SS MUNICIPLAITY OF LOS BAOS} BEFORE ME, this 22nd day of January 2011, in the Municipality of Los Baos, Philippines, personally appeared Nicanor R. Reyes, exhibiting his Drivers License with no D16111 issued at Makati City, on June 11, 2001, and Ramon S. Galvez exhibiting his GSIS ID with no. GB-234 issued at Quezon City on May 11, 1998 known to me to be the same persons who executed the foregoing instrument, and they acknowledged to me that the same are their free act and deed. This instrument, consisting of two (2) pages including the page on which this acknowledgement is written, has been signed on the left margin of each page thereof by Nicanor R. Reyes and Ramon S. Galvez and their witnesses, and sealed with my notarial seal. IN WITNESS WHEREOF, I have hereunto set my hand and affixed my notarial seal, the day, year, and place above written.

Atty. Edmun C. Galvez NOTARY PUBLIC My Commission expires Dec. 31, 2011 IBP No. 1234, 1/2/2002, Los Baos P.T.R. No. 4567, 2/2/2002, Los Baos Doc. No. 1; Page No. 2; Book No. 3; Series of 2011.

AFFIDAVIT OF GOOD FAITH We, the undersigned MORTGAGOR and MORTGAGEE, severally swear that the foregoing chattel mortgage is made and executed for the purpose of securing the obligation specified therein, and for no other purpose, and that the same is a just and valid obligation, and one not entered into for the purposes of fraud.

__________________________ Nicanor R. Reyes

_____________________________ Ramon S. Galvez

SUBSCRIBED AND SWORN to before me this 22nd day of January 2011 in the Municipality of Los Baos, Laguna, Nicanor R. Reyes, exhibiting his Drivers License with
no D-16111 issued at Makati City, on June 11, 2001, and Ramon S. Galvez exhibiting his GSIS ID with no. GB-234 issued at Quezon City on May 11, 1998.

Atty. Edmun C. Galvez NOTARY PUBLIC My Commission expires Dec. 31, 2011 IBP No. 1234, 1/2/2002, Los Baos P.T.R. No. 4567, 2/2/2002, Los Baos Doc. No. 1; Page No. 2; Book No. 3; Series of 2011.

REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION REGIONAL TRIAL COURT Branch I, Manila Juan de la Cruz Plaintiff,vs John Doe Defendant. x--------------------------------X COMPLAINT COMES NOW, the Plaintiff, through the undersigned counsel, and to this Honorable Court alleges: 1. That Plaintiff is of legal age, single and a resident of 311 P. Casal St., Quiapo, Manila, while defendant is an American citizen, residing at Room 1024, Manila Hotel, where he may be served with Summons; 2. That plaintiff is the registered owner of a motor vehicle described as a Mitsubishi Lancer, model 1984, with Plate No. DAY-203; 3. That on October 11, 1986, defendant rented from plaintiff said Lancer car for a week from October 11 to 18, 1986; 4. That on October 20, 1986, 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; 6. That the value of the said car is P590,000; 7. That plaintiff is ready and willing to give bond executed to the defendant in double the value of the property for the return of the property to the defendant should be adjudged, or for the payment of such sum that defendant may recover from plaintiff in the action. WHEREFORE, plaintiff prays that: 1. The sheriff or other proper officer be ordered to take possession of the car and dispose of it in accordance with the Rules of Court; Civil case no. 11111 For replevin

2. After hearing, judgment be rendered declaring that plaintiff is entitled to the possession of the car or, should this prove unavailing, sentencing defendant to pay the value of the car. Manila, December 3, 1986.

ATTY. ASUNTO XYZ Building, Manila IBP No. 12345; 1/3/1986;Manila PTR No.61879; 2/2/1986; Manila Roll of Attorneys No. 12344 VERIFICATION AND CERTIFICATION JUAN DELA CRUZ subscribing under oath, hereby deposes and states that: He is a petitioner in this case. He has read the foregoing petition, and the allegations contained therein are true and correct of his own knowledge and/or based on authentic records. He attests to the authenticity of the annexes thereof. Petitioner has not commenced any other action or proceeding involving the same issues in the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency; No such action or proceeding is pending in the Supreme Court, the Court of Appeals or different Divisions thereof, or any other tribunal or agency; If petitioner should learn that a similar action or proceeding has been filed or is pending before the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency, he hereby undertakes to notify this Honorable Court within 5 days therefrom. _________________ JUAN DELA CRUZ SUBSCRIBED AND SWORN to before me this 3rd day of December 1986 in the City of Manila, affiant exhibiting to me his GSIS ID with no. GT 345 issued at Quezon City on January 12, 1980. _________________ MARIA A. SANTOS Notary Public My Commission Expires Dec. 31, 1986 IBP No. 111, 1/16/1986, Manila PTR No. 222, 1/2/1986, Manila Doc. No. 1 Page No. 2 Book No. 3 Series of 1986

REPUBLIC OF THE PHILIPPINES ) CITY OF MANILA ) SS

AFFIDAVIT FOR REPLEVIN I, JUAN DELA CRUZ, of legal, single, and resident of 311 P. Casal St., Quiapo, Manila, after being sworn in accordance with law depose and say: 1. That I am the plaintiff in an action for the delivery of personal property against the defendant, entitled JUAN DELA CRUZ versus JOHN DOE (Civil Case No. 11111) in the Regional Trial Court of Manila, Branch 1; 2. That I am the owner of said property, particularly described as follows, to wit: Mitsubishi Lancer model 1984, with Plate No. DAY-203; 3. That the said personal property is wrongfully detained by the defendant without any lawful cause whatsoever; 4. That the said personal property has not been taken for a tax assessment or fine pursuant to law, or seized under an execution, or an attachment against the property of the plaintiff; 5. That the actual value of the said property is FIVE HUNDRED NINETY THOUSAND (P 590,000.00). 6. That affiant is willing to file a bond double the actual market value of the property. FURTHER AFFIANT SAYETH NAUGHT. City of Manila, Philippines, December 4, 1986. JUAN DELA CRUZ Affiant

VERIFICATION JUAN DELA CRUZ, subscribing under oath, hereby deposes and states that: I am the petitioner in the instant case. I have read the foregoing Petition and the allegations therein are true and correct of my own knowledge and/or based on the records on hand. I attest to the authenticity of the annexes thereof. _________________ JUAN DELA CRUZ

SUBSCRIBED AND SWORN to before me this 4th day of December 1986 in the City of Manila, affiant exhibiting to me his GSIS ID with no. GT 345 issued at Quezon City on January 12, 1980.

_________________ MARIA A. SANTOS Notary Public My Commission Expires Dec. 31, 1986 IBP No. 111, 1/16/1986, Manila PTR No. 222, 1/2/1986, Manila Doc. No. 2 Page No. 3 Book No. 3 Series of 1986

REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION METROPOLITAN TRIAL COURT Manila, Branch 1 Juan dela Cruz Plaintiff, -versusJose Reyes Defendant. x---------------------------x COMPLAINT COMES NOW the Plaintiff in the above entitled case, through counsel, and to this Honorable Court alleges; I That the plaintiff is of legal age and a resident of the City of Manila; that defendant is likewise of legal age, residing at No. 2 Cruz Street, Manila and may be served with summons at said address; II That defendant on January 7, 2001, leased from the plaintiff the premises located at No. 7 Cruz Street, Manila, agreeing to pay monthly rental of P 1, 000.00 III However, defendant failed to pay the aforesaid monthly rentals on their due dates, such that as of the date hereof, his arrearages have accumulated up to P 3,000; IV That on March 7, 2001, demands was made on defendant to pay his rental in arrears and vacate the premises, but despite said demands, written and oral, defendant failed and refused to pay the rentals in arrears and vacate the premises leased by him; V As a result, plaintiff was constrained to institute this case, incurring in the process obligations for litigation expenses and attorneys fees in the amount of 10,000.00 Pesos CIVIL CASE NO. 1234 For: Ejectment

PRAYER WHEREFORE, it is respectfully prayed that judgment be rendered against the defendant ordering him: 1. To vacate the premises leased by him; 2. To pay the monthly sum of P1,000.00 beginning with the month of January 7, 2001, with interest thereon at the legal rate until fully paid until the defendant vacates said premises; 3. To pay the sum of PhP 10,000.00 as litigation expenses and attorneys fees. 4. Plaintiff further prays for such other reliefs as this Court may deem just and equitable. Manila, Philippines, May 1, 2001. ATTY. ASUNTO XYZ Building, Manila IBP No. 12345; 1/3/1986;Manila PTR No.61879; 2/2/1986; Manila Roll of Attorneys No. 12344

VERIFICATION AND CERTIFICATION JUAN DELA CRUZ subscribing under oath, hereby deposes and states that: He is a petitioner in this case. He has read the foregoing petition, and the allegations contained therein are true and correct of his own knowledge and/or based on authentic records. He attests to the authenticity of the annexes thereof. Petitioner has not commenced any other action or proceeding involving the same issues in the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency; No such action or proceeding is pending in the Supreme Court, the Court of Appeals or different Divisions thereof, or any other tribunal or agency; If petitioner should learn that a similar action or proceeding has been filed or is pending before the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency, he hereby undertakes to notify this Honorable Court within 5 days therefrom. ________________ JUAN DELA CRUZ

SUBSCRIBED AND SWORN to before me this 2nd day of May 2001 in the City of Manila, affiant exhibiting to me his GSIS ID with no. GT 345 issued at Quezon City on January 12, 1980. _________________ MARIA A. SANTOS Notary Public My Commission Expires Dec. 31, 2001 IBP No. 111, 1/16/1986, Manila PTR No. 222, 1/2/1986, Manila Doc. No. 1 Page No. 2 Book No. 3 Series of 2001

REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION METROPOLITAN TRIAL COURT Quezon City, Branch 1

Juan dela Cruz Plaintiff, -versusJose Reyes Defendant. x---------------------------x COMPLAINT COMES NOW the plaintiff, by the undersigned counsel, and to this Honorable Court, respectfully alleges: 1. That the plaintiff is of legal age, Filipino citizen and resident of No.7 Agoo Street, Quezon City and the defendant is also of legal age, Filipino citizen and a resident of No. 19 Dagupan Street, Quezon City where he may be served with summons; 2. That on or about January 1, 1983, defendant obtained a loan of P 20,000.00 from the plaintiff payable within 90 days from date of receipt at 12% per annum; 3. That said loan, now overdue, is evidenced by a promissory note signed by the defendant, a copy of which is hereto attached as annex A and made part of this complaint; 4. That despite repeated demands, both written and oral, defendant has failed and refused to apply said loan; 5. That due to the unjust and unlawful act of the defendant to comply with the said demands, the plaintiff was compelled to institute this action engaging the services of counsel in the amount of P10,000.00 WHEREFORE, it is respectfully prayed that judgment be rendered against the defendant to pay the plaintiff the sum of P20,000.00 plus interest of 12% from the date of the instrument until full amount is paid and attorneys fees in the amount of P10,000.00 and costs of the suit. Other equitable reliefs are likewise prayed for. CIVIL CASE NO. 1234 For: Collection of sum of money

January 11, 1991, Quezon City.

ATTY. ASUNTO XYZ Building, Manila IBP No. 12345; 1/3/1986;Manila PTR No.61879; 2/2/1986; Manila Roll of Attorneys No. 12344

VERIFICATION AND CERTIFICATION JUAN DELA CRUZ subscribing under oath, hereby deposes and states that: He is a petitioner in this case. He has read the foregoing petition, and the allegations contained therein are true and correct of his own knowledge and/or based on authentic records. He attests to the authenticity of the annexes thereof. Petitioner has not commenced any other action or proceeding involving the same issues in the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency; No such action or proceeding is pending in the Supreme Court, the Court of Appeals or different Divisions thereof, or any other tribunal or agency; If petitioner should learn that a similar action or proceeding has been filed or is pending before the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency, he hereby undertakes to notify this Honorable Court within 5 days therefrom. _________________ JUAN DELA CRUZ SUBSCRIBED AND SWORN to before me this 12th day of January 1991 in the City of Quezon, affiant exhibiting to me his GSIS ID with no. GT 345 issued at Quezon City on January 12, 1980. _________________ MARIA A. SANTOS Notary Public My Commission Expires Dec. 31, 1991 IBP No. 111, 1/16/1986, Quezon City PTR No. 222, 1/2/1986, Quezon City Doc. No. 1 Page No. 2 Book No. 3 Series of 1991

REPUBLIC OF THE PHILIPPINES National Capital Judicial Region METROPOLITAN TRIAL COURT Branch 39, Quezon City LAKI ASSEST COMPANY, Plaintiff, Civil case no. 3333 For sum of money -versusDAMI UTANG CORPORATION, Defendant. x------------------------------------------x MOTION TO DISMISS DEFENDANT, by counsel, respectfully moves to dismiss the Complaint on the ground that the Complaint fails to state any cause of action as (1) THE OBLIGATION TO BE ENFORCED BY PLAINTIFF IS NOT YET DUE AND DEMANDABLE, as shown by the following: 1. Alleged, plaintiff has failed to reach the quotas agreed upon under the Marketing Agreement dated 1 January 2012; defendant now seeks to collect the sum of TWO HUNDRED THOUSAND PESOS (P 200,000.00), representing the balance of the proceeds due plaintiff under the said marketing agreement. 2. The contract is for one (1) year and defendant is given the same period to reach the quota specified therein; the period of one (1) year has not expired. Consequently, plaintiffs claim is premature as there is yet no breach of the Marketing Agreement until the period expires and the quota is not attained. For this reason, plaintiffs complaint states no cause of action and must be dismissed. WHEREFORE, defendant respectfully prays that the complaint be DISMISSED for failure to state a cause of action. Other just and equitable reliefs are also prayed for. Quezon City: 13 April 2012 ATTY. ASUNTO XYZ Building, Manila IBP No. 12345; 1/3/1986;Manila PTR No.61879; 2/2/1986; Manila Roll of Attorneys No. 12344

Request for notice of hearing THE BRANCH CLERK OF COURT METROPOLITAN TRIAL COURT Branch 39, Quezon City Please submit the foregoing Motion to the Court for its consideration and approval; immediately upon receipt hereof and kindly include the same in the courts calendar for hearing on Friday, 27 April 2012 at 8:30 in the morning ATTY. ASUNTO XYZ Building, Manila NOTICE OF HEARING Perez & Matias Law Offices 49 Dapitan St. , Sampaloc Mla. Counsel of the adverse party Please take notice that the counsel has requested to be heard on Friday 27, April 2012 at 8:30 in the morning ATTY. ASUNTO XYZ Building, Manila

EXPLANATION AS TO SERVICE Copy of this Motion to Dismiss was served the counsel for plaintiff thru registered mail. Personal service cannot be effected due to time, distance and manpower constraints, the same is not practicable. ATTY. ASUNTO XYZ Building, Manila Copy Furnished: Perez & Matias Law Offices 49 Dapitan St. , Sampaloc Mla. Counsel of the adverse party

REPUBLIC OF THE PHILIPPINES METROPOLITAN TRIAL COURT NATIONAL CAPITAL JUDICIAL REGION BRANCH 39, Quezon City

Juan dela Cruz Plaintiff Vs.

Civil Case no. 3456 For : Ejectment

Roel J. Rivera Defendant x--------------------------x MOTION FOR POSTPONEMENT PLAINTIFF, by counsel respectfully states that: 1. This case is set for trial on 5 May 2007 at 8:30 in the morning 2. On said date and time, the undersigned counsel will be unable to appear before this honorable court as he has also been directed to appear on this date and time before RTC of Makati, Branch 139 for PP vs Bil Moko, Criminal case no. 00999888, where he is scheduled to terminate cross-examination of the prosecutions expert witness who will be available only on said date and time. 3. Without impugning the importance of these proceedings, plaintiff respectfully submits that his attendance in the Makati case becomes indispensable, otherwise, the accused in said case would be deprived of the opportunity to confront and cross examine a vital witness against her. 4. This motion is prompted only by the foregoing reason and not for delay. WHEREFORE, plaintiff respectfully prays that the trial scheduled on 5, May 2007 be POSTPONED to another date convenient to this honorable court. Quezon City: 13 April 2007

ATTY. ASUNTO XYZ Building, Manila IBP No. 12345; 1/3/1986;Manila PTR No.61879; 2/2/1986; Manila Roll of Attorneys No. 12344

Request for notice of hearing THE BRANCH CLERK OF COURT METROPOLITAN TRIAL COURT Branch 39, Quezon City Please submit the foregoing Motion to the Court for its consideration and approval; immediately upon receipt hereof and kindly include the same in the courts calendar for hearing on Friday, 27 April 2007 at 8:30 in the morning ATTY. ASUNTO XYZ Building, Manila NOTICE OF HEARING Perez & Matias Law Offices 49 Dapitan St. , Sampaloc Mla. Counsel of the adverse party Please take notice that the counsel has requested to be heard on Friday 27, April 2007 at 8:30 in the morning ATTY. ASUNTO XYZ Building, Manila

EXPLANATION AS TO SERVICE Copy of this Motion for Postponement was served the counsel for plaintiff thru registered mail. Personal service cannot be effected due to time, distance and manpower constraints, the same is not practicable. ATTY. ASUNTO XYZ Building, Manila Copy Furnished: Perez & Matias Law Offices 49 Dapitan St. , Sampaloc Mla. Counsel of the adverse party

REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT NATIONAL CAPITAL JUDICIAL REGION BRANCH 39, Quezon City

Juan dela Cruz Plaintiff Vs. Civil Case no. 3456 For : Collection of Sum of Money

Roel J. Rivera Defendant x--------------------------x

MOTION TO DECLARE DEFENDANT IN DEFAULT PLAINTIFF, by counsel respectfully states that: 1. Plaintiff filed this complaint against defendant on March 1, 2007; summons were served on defendant on March 20, 2007, as indicated by the Sheriffs Return on given date, a copy of which is attached as annex A. 2. Defendants reglementary period to file an answer ended on 5 April 2007; no motion for extension of such time was filed no was any granted motu propio by this honorable court despite lapse of time, defendant has failed to answer the complaint against her; plaintiff is entitled to a declaration of default and the right to present evidence ex parte against defendant. WHEREFORE, plaintiff respectfully prays that defendant be declared in default and that plaintiff be allowed to present evidence ex-parte before the Clerk of Court acting as commissioner. Quezon City: 13 April 2007

ATTY. ASUNTO XYZ Building, Manila IBP No. 12345; 1/3/1986;Manila PTR No.61879; 2/2/1986; Manila Roll of Attorneys No. 12344

Request for notice of hearing THE BRANCH CLERK OF COURT REGIONAL TRIAL COURT Branch 39, Quezon City Please submit the foregoing Motion to the Court for its consideration and approval; immediately upon receipt hereof and kindly include the same in the courts calendar for hearing on Friday, 27 April 2007 at 8:30 in the morning ATTY. ASUNTO XYZ Building, Manila NOTICE OF HEARING Perez & Matias Law Offices 49 Dapitan St. , Sampaloc Mla. Counsel of the adverse party Please take notice that the counsel has requested to be heard on Friday 27, April 2007 at 8:30 in the morning ATTY. ASUNTO XYZ Building, Manila

EXPLANATION AS TO SERVICE Copy of this Motion to declare Defendant in Default was served the counsel for plaintiff thru registered mail. Personal service cannot be effected due to time, distance and manpower constraints, the same is not practicable. ATTY. ASUNTO XYZ Building, Manila Copy Furnished: Perez & Matias Law Offices 49 Dapitan St. , Sampaloc Mla. Counsel of the adverse party

REPUBLIC OF THE PHILIPPINES National Capital Judicial Region METROPOLITAN TRIAL COURT Branch 39, Quezon City Juan dela Cruz, Plaintiff, Criminal case no. 3333 for rape -versusSimon G. Agustin, Accused. x------------------------------------------x MOTION FOR BAIL THE ACCUSED, by counsel, respectfully moves to be allowed on the ground that the prosecutions evidence of his guilt is not strong. In support, he respectfully submits the following: 1. The information alleges that he raped private complainant on 25 December 2005 at his residence in Quezon city. The prosecutions own evidence, however belies this allegation as (a) the medical certificate (attached as ANNEX A to the information) states that private complainant is in a virgin state with no physical and outward signs of trauma; (b) the medical certificate issued by the NBI doctor (attached as ANNEX B to the information) after a physical examination of the accused, two days after the alleged rape, shows he is suffering from erectile dysfunction and has been so afflicted for close to five years now and (c) the sworn statements of the private complainant conflicts with and contradict each other such that her credibility must be placed in doubt. 2. For these reason, there is no basis to conclude that the accused raped the private complainant as there is less than circumstantial evidence of this fact. He is thus, entitled to bail as a matter of right

WHEREFORE, it is respectfully prayed that the accused be granted: (1) a bail hearing, during w/c the prosecution should be directed to present its evidence to show the

strength of its evidence of the accuseds guilt, and thereafter, grant the accused reasonable bail. Other just and equitable reliefs are also prayed for. Quezon City: 13 April 2012 ATTY. ASUNTO XYZ Building, Manila IBP No. 12345; 1/3/1986;Manila PTR No.61879; 2/2/1986; Manila Roll of Attorneys No. 12344 Request for notice of hearing THE BRANCH CLERK OF COURT REGIONAL TRIAL COURT Branch 39, Quezon City Please submit the foregoing Motion to the Court for its consideration and approval; immediately upon receipt hereof and kindly include the same in the courts calendar for hearing on Friday, 27 April 2007 at 8:30 in the morning ATTY. ASUNTO XYZ Building, Manila NOTICE OF HEARING Perez & Matias Law Offices 49 Dapitan St. , Sampaloc Mla. Counsel of the adverse party Please take notice that the counsel has requested to be heard on Friday 27, April 2007 at 8:30 in the morning ATTY. ASUNTO XYZ Building, Manila

EXPLANATION AS TO SERVICE Copy of this Motion for Bail was served the counsel for plaintiff thru registered mail. Personal service cannot be effected due to time, distance and manpower constraints, the same is not practicable. ATTY. ASUNTO XYZ Building, Manila Copy Furnished: Perez & Matias Law Offices 49 Dapitan St. , Sampaloc Mla. Counsel of the adverse party

REPUBLIC OF THE PHILIPPINES National Capital Judicial Region METROPOLITAN TRIAL COURT Branch 39, Quezon City Juan dela Cruz, Plaintiff, Criminal case no. 3333 For : Acts of Lasciviousness -versusSimon G. Agustin, Accused. x------------------------------------------x

INFORMATION The undersigned, Assistant Prosecutor, upon sworn complaint originally filed by the offended party, accuses Simon Agustin of the crime of an ACT OF LASCIVIOUSNESS, committed as follows, to wit: That on or about 10 am on January 23, 2007, in the City of Quezon, Philippines, within the jurisdiction of this Court, the said accused, actuated by lust, did then and there, willfully, unlawfully, and feloniously, commit an act of lasciviousness upon the undersigned by then and there embracing and kissing her and touching her breasts and sexual organs, against her will, and by means of force. Contrary to law Quezon City, February 12, 2007

ATTY. Edmund S. Reyes Assistant City Prosecutor

WITNESSES: Myla S. Reyes

Dennis A. Padilla BAIL RECOMMENDED: PhP 50,000.00 CERTIFICATION A preliminary investigation has previously been conducted in this case under my direction, having examined the witnesses in accordance with the provisions of R.A. No.

5180, as amended by P.D. No. 77, Dec.6, 1972 and P.D. 911, March 23, 1976 and as implemented by Dept. of Justice Circular No. 74, series of 1967 and Circular No. 23, series of 1975.

ATTY. Edmund S. Reyes Assistant City Prosecutor SUBSCRIBED AND SWORN to before me this 12th day of February 2007 in the City of Quezon, Philippines, by ATTY. EDMUND S. REYES, assistant fiscal of Quezon City. OSCAR O. ORBOS Judge, MTC of Quezon City

REPUBLIC OF THE PHILIPPINES National Capital Judicial Region METROPOLITAN TRIAL COURT Branch 39, Quezon City Juana dela Cruz, Plaintiff, Criminal case no. 3333 For : Abduction with consent -versusSimon G. Agustin, Accused. x------------------------------------------x

INFORMATION The undersigned, provincial fiscal, upon sworn complaint originally filed by the offended party, accuses Simon G. Agustin of the crime of Abduction with Consent, committed as follows: That on or about 23 January 2011 in the City of Quezon, Philippines, within the jurisdiction of this court, the said accused willfully, unlawfully, and feloniously removed, took and carried away Juana dela Cruz, a virgin over twelve and under eighteen years

of age, from her dwelling with her consent and with lewd designs. Contrary to law: Quezon City, February 12, 2012

ATTY. Edmund S. Reyes Assistant City Prosecutor

WITNESSES: Myla S. Reyes

Dennis A. Padilla BAIL RECOMMENDED: PhP 50,000.00 CERTIFICATION A preliminary investigation has previously been conducted in this case under my direction, having examined the witnesses in accordance with the provisions of R.A. No. 5180, as amended by P.D. No. 77, Dec.6, 1972 and P.D. 911, March 23, 1976 and as

implemented by Dept. of Justice Circular No. 74, series of 1967 and Circular No. 23, series of 1975.

ATTY. Edmund S. Reyes Assistant City Prosecutor SUBSCRIBED AND SWORN to before me this 12th day of February 2007 in the City of Quezon, Philippines, by ATTY. EDMUND S. REYES, assistant fiscal of Quezon City. OSCAR O. ORBOS Judge, MTC of Quezon City

REPUBLIC OF THE PHILIPPINES National Capital Judicial Region REGIONAL TRIAL COURT Branch 39, Quezon City Juan dela Cruz, Plaintiff, Criminal case no. 3333 For : Serious Illegal Detention/kidnapping -versusSimon G. Agustin, Accused. x------------------------------------------x

INFORMATION The undersigned assistant prosecutor accuses Simon Agustin of the crime of SERIOUS ILLEGAL DETENTION ( or KIDNAPPING), committed as follows: That about and during the period beginning from the 4th day of January 2009, in the city of Quezon, Philippines, and within the jurisdiction of this Honorable Court, said accused, suspecting that one Juan dela Cruz had knowledge of the elopement of her sister, did then and there willfully, unlawfully, feloniously and by force, take said plaintiff, a man 50 years of age, while the latter was walking in Quezon Boulevard, whom said accused detained and kept locked in his room from 5th January to February 5, 2009, or a period of 30 days, under restraint and against the will of the said plaintiff, and said accused did, during said period of detention, maltreat and refuse to release said plaintiff until the sister of the accused was found. Contrary to law. ATTY. Edmund S. Reyes Assistant City Prosecutor

WITNESSES: Myla S. Reyes

Dennis A. Padilla BAIL RECOMMENDED: PhP 50,000.00

CERTIFICATION A preliminary investigation has previously been conducted in this case under my direction, having examined the witnesses in accordance with the provisions of R.A. No. 5180, as amended by P.D. No. 77, Dec.6, 1972 and P.D. 911, March 23, 1976 and as implemented by Dept. of Justice Circular No. 74, series of 1967 and Circular No. 23, series of 1975. ATTY. Edmund S. Reyes Assistant City Prosecutor SUBSCRIBED AND SWORN to before me this 12th day of February 2007 in the City of Quezon, Philippines, by ATTY. EDMUND S. REYES, assistant fiscal of Quezon City. OSCAR O. ORBOS Judge, RTC of Quezon City

LEGAL FORMS

Submitted by: VIRGILIO A. TIONGSON, JR.

Submitted to: ATTY. ALICIA L. EMPEO

DEEDS and CONTRACTS

MOTIONS

INFORMATIONS

COMPLAINTS