VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING
I, JUAN DELA CRUZ, of legal age, Filipino, married, after having
been duly sworn in accordance with law, depose and state that:
1. I am a plaintiff in the above-stated case;
2. I caused the preparation of the foregoing complaint;
3. I have read the contents thereof and the facts stated therein
are true and correct of my personal knowledge and/or on the
basis of copies of documents and records in my possession;
4. I have not commenced any other action or proceeding involving
the same issues in the Supreme Court, the Court of Appeals, or
any other tribunal or agency;
5. To the best of my knowledge and belief, no such action or
proceeding is pending in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;
6. If I should thereafter learn that a similar action or proceeding
has been filed or is pending before the Supreme Court, the
Court of Appeals, or any other tribunal or agency, I undertake
to report that fact within five (5) days therefrom to this
Honorable Court.

JUAN DELA CRUZ

Affiant
SUBSCRIBED AND SWORN to before me this ___day of ________,
2016, in City of Manila, affiant exhibiting his Philippine Passport No. 12345
issued in Manila on 07 March 2011 valid until 07 March 2016.

NOTARY PUBLIC
Page No. ___;
Doc. No. ___;
Book No. ___;
Series of 2016.

Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 1
Manila
PEOPLE OF THE PHILIPPINES,
Plaintiff,
Crim Case No. 12345
For: MURDER

- versus PEDRO DE MASUPIL,

Accused.
x - - - - - - - - - - - - - - - - - - - - -x

PETITION FOR BAIL

Accused, through the undersigned counsel, unto this Honorable
Court,most respectfully states:
1. That accused is currently detained at the Manila City Jail for the
charge of Murder;
2. That no bail has been recommended for his temporary release on
the assumption that the evidence of guilt is strong;
3. That the prosecution's evidence of guilt against accused, however,
is weak as there is no direct evidence that will point to the accused
to have committed the charges against him. The records will show
that accused was malicious implicated in the case based on the
sworn statement of Mando Duro who subsequently recanted his
testimonies and confessed, among others, that he was made to sign
the "affidavits of witnesses" against his will. Attached hereto is the
copy of the Affidavit of Recantation of Mando Duro as Annex A;
4. That there is no other physical or documentary evidence to show
that accused is guilty of the crime charged;
5. That the burden of showing that evidence of guilt is strong is on the
prosecution, and since this fact is not satisfactorily shown, accused
is entitled to bail as a matter of right during the pendency of the
criminal case.

WHEREFORE, upon prior notice and hearing, it is respectfully prayed

of this Honorable Court that accused Pedro De Masupil be allowed to post
bail for his temporary liberty pending trial of the criminal charge against
him.

Other just and equitable reliefs are likewise prayed for.

16 March 2016 at Manila, Philippines.

JEFFREY L. SANTOS
Counsel for the Accused
PTR No. 54321, 03 January 2016
IBP No. 678910
Roll No. 12345:05/11/2014: Manila
Rm. 123 Westlake Building, Soler St.,
Binondo, Manila
MCLE
Compliance
No.
1234,
05/11/2014
NOTICE OF HEARING
THE BRANCH CLERK OF COURT
Regional Trial Court, Branch 1
Manila
Greetings!
Please submit the foregoing motion to the Honorable Court on 01
April 2016 at 2:00 oclock in the afternoon for its favorable consideration
and approval.

ATTY. JEFFREY L. SANTOS

Copy furnished:
Office of the City Prosecutor
Manila
ATTY. JOSE BAYOLA
Private Prosecutor
No. 69 Pilapil Street,
Sta. Ana, Manila

DEED OF ABSOLUTE SALE

KNOW ALL MEN BY THESE PRESENTS:

This Deed of Absolute Sale, made and entered this 16th day of March
2016, in the City of Manila, by and between:
CHLOE CUSTODIO, of legal age, Filipino, single, and with postal
address at No. 1 Rosal Street, Concepcion, Malabon City, hereinafter
referred to as the SELLER;
and
CHARLES MACTAM, of legal age, Filipino, with residence address
at No. 143 Kamagong Street, San Andres Bukid, Manila, hereinafter
referred to as the BUYER.
WITNESSETH: THAT
WHEREAS, the SELLER is the registered lawful and actual possessor
of a certain parcel of land situated in Sta. Mesa, Manila, and more
particularly described and bounded as follows:
TCT No. T-1234
A PARCEL OF LAND (Lot 4 of the consolidation-subdivision plan (LRC) Pcs12345, being a portion of the consolidation of Lots 1 and 2, Psu-5678
Rec. No. N-98765), situated in Bo. Bacood, Manila, Rizal, Island of Luzon.
Bounded on the NE., points 1 to 8, by Lot 23; on the S., points 8 to 4 by
Lot 78; on the SW., points 2 to 4, by Lot 87; and on the N., points 2 to 3
by Lot 90, all of the consolidation-subdivision plan. Beginning at a pont
marked "1" on plan, being N. 98 deg. 45' E., 1234.56 m. from B.L.L.M.
No.1, Sta. Mesa, Manila xxxxxxxx (a copy of which title is hereto
attached as Annex "A")

WHEREAS, the SELLER is willing to sell and the BUYER is willing to

buy the above-described real estate property;
NOW, THEREFORE, for and in consideration of the amount of One
Million Pesos (P1,000,000.00), Philippine Currency, receipt in full is hereby
acknowledged by the SELLER to her satisfaction, the SELLER SELLS,
CEDES, TRANSFERS and CONVEYS in a manner that is absolute and
irrevocable the above real property unto the BUYER, his heirs, assigns
and successors-in-interest.
The SELLER warrants that she can transfer the title and possession
of the aforesaid real estate property to the BUYER and that there are no
other transactions pending registration with the Registry of Deeds Manila
that will adversely affect the rights of the BUYER.
THAT any and all expenses incidental to the registration and
conveyance of the title from the name of the SELLER to the name of the
BUYER such as Transfer Tax, Documentary Tax, registration expenses and

the like shall be the sole and exclusive account of the BUYER: provided,
that capital gains tax shall be for the account of the SELLER.
IN WITNESS WHEREOF, the parties have hereunto signed this
DEED OF ABSOLUTE SALE this 18th day of March 2016 at the date and
place first above mentioned.

CHLOE CUSTODIO
Seller
TIN No: 123456

CHARLES MACTAM
Buyer
TIN No.: 567890

Signed in the presence of:

___________________________

__________________________

ACKNOWLEDGEMENT
Republic of the Philippines)
City of Manila

) S.S.

BEFORE ME, a Notary Public for and in the City of Manila,

Philippines, personally appeared:
Name

CTC No.

Place Date

CHLOE CUSTODIO
CHARLES MACTAM
known to me to be the same persons who executed the foregoing
document of DEED OF ABSOLUTE SALE and they acknowledged to me that
they executed the same as their free and voluntary act and deed.
I HEREBY CERTIFY that the foregoing document consists of two (2) pages
including this page, and that the parties and their witnesses signed their
names and on one (1) parcel of land covered by TCT No. T-1234 of the
Registry of Deeds of Manila.
IN WITNESS WHEREOF, I have hereunto set may hand and affixed
my notarial seal this ____ day of ____________ 2016.

NOTARY PUBLIC
Doc. No. ____;
Page No. ____;
Book No. ____;
Series of 2016
Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 1
Manila
JOSEPH YEO,
Plaintiff,
Civil Case No. 12345
For: Sum of Money

- versus MIKEY ROMERO,

Defendant.
x - - - - - - - - - - - - - - - - - - - - - - -x

PETITION FOR LETTERS ROGATORY

COMES NOW petitioner, by his counsel, unto this Honorable Court,
respectfully states, that:
1. He is the plaintiff in the abovementioned civil action for
collection of sum of money;
2. The said civil action is presently pending before Branch 1,
Regional Trial Court of Manila;
3. An Order issued by this Court on the 9 th day of March 2016, to
take the testimony of Mr. Chris Ellis of No. 1234 Berchem,
Brussels, Belgium, before Consul Joe Devance, was returned
unexecuted on the ground that the witness refused to give his
testimony regarding the above case, all of which more fully
appears from the certificate of said Consul to said commission
and made part hereof by attaching.
WHEREFORE, petitioner prays that this Honorable Court orders the
issuance by the clerk of court, this Court, of Letters Rogatory directed to
the Court of Brussels and requesting the examination of Mr. Chris Ellis as
witness on the interrogatories filed herewith and made a part hereof.
16 March 2016, City of Manila, Philippines.

JEFFREY L. SANTOS
Counsel for the Petitioner
PTR No. 54321, 03 January 2016
IBP No. 678910
Roll No. 12345:05/11/2014: Manila
Rm. 123 Westlake Building, Soler St.,
Binondo, Manila
MCLE
Compliance
No.
1234,
05/11/2014
Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 2
Makati City
JOMAR NAYBI,
Petitioner,
SP PROC No. 12345
- versus S/INSP. RAM ROXAS, in his capacity
as the Chief, Intelligence Unit of the
National Capital Region, Philippine
National Police,
Respondent.
x - - - - - - - - - - - - - - - - - - - - - - -x

PETITION FOR HABEAS DATA

Petitioner, through the undersigned counsel, unto this Honorable
Court, most respectfully states, that:
NATURE OF THE PETITION
1. This is a petition for the writ of habeas data filed under A.M. No. 081-16-SC, also known as the Rule on the Writ of Habeas Data to
require the respondent/s to produce and, if necessary update and
rectify, or, in the alternative, suppress or destroy information within
its control and/or contained in its database, which relates to
petitioner, his/her family, his/her home and his/her correspondence.
2. Petitioner respectfully submits that respondent obtained the
information through an unlawful act, has unjustifiably failed to
disclose the information to petitioner, and/or has unjustifiably
refused to update, rectify, suppress or destroy the information.
3. This act or omission of respondent to comply with petitioner's
demand is a violation of, or poses a threat of violation to,
petitioner's right to privacy in life, liberty and security.
4. In view of the foregoing, petitioner brings this petition before this
Honorable Court praying that the respondent be required to cause
the immediate production of the information requested so that the
same may be revealed to petitioner for proper updating,
rectification or, in the alternative, for its suppression or destruction,
whatever may be necessary to protect petitioner's privacy.

PARTIES

5. Petitioner is a Filipino, of legal age, and residing at No.1 Bullion

Street, Forbes Park, Makati City. He may be served with notices
from this Honorable Court through his undersigned counsel.
6. Respondent is being impleaded in his capacity as a public officer or
employee, in charge of the information or database of the
Intelligence Unit, PNP, which office is engaged in the gathering,
collecting, and storing of data. He may be served summons and
other processes of this Honorable Court at the Intelligence Unit of
Philippine National Police, Camp Crame, Quezon City. Respondent is
of legal age, with postal address at the abovestated address and is
engaged in the gathering, collecting, and storing of data. He/She
may be served summons and other processes of this Honorable
Court at the abovementioned address.
MATERIAL ALLEGATIONS
7. Petitioner is a citizen of the Republic of the Philippines whose right
to privacy is protected by the Bill of Rights found in Article III of the
1987 Philippine Constitution, which provides:
Section 3. (1) The privacy of communication and
correspondence shall be inviolable except upon lawful order
of the court, or when public safety or order requires
otherwise as prescribed by law.
Any evidence obtained in violation of this or the
preceding section shall be inadmissible for any purpose in
any proceeding.
xxx
Section 7. The right of the people to information of
matters of public concern shall be recognized.
Access to official records and documents, and papers
pertaining to official acts, transactions, or decisions as well
as to government research data used as basis for policy
development, shall be afforded the citizen, subject to such
limitations as may be provided by law.
8. Also, in Lourdes T. Marquez vs. Hon. Aniano A. Desierto, et al., this
Honorable Court had occasion to rule:
Zones of privacy are recognized and protected in our
laws. The Civil Code provides that "[e]very person shall
respect the dignity, personality, privacy, and peace of mind
of his neighbors and other persons" and punishes as
actionable torts several acts for meddling and prying into
the privacy of another. It also holds a public officer or
employee or any private individual liable for damages for
any violation of the rights and liberties of another
person, and recognizes the privacy of letters and other

private communications. The Revised Penal Code makes a

crime of the violation of secrets by an officer, the revelation
of trade and industrial secrets, and trespass to dwelling.
Invasion of privacy is an offense in special lawslike the AntiWiretapping Law, the Secrecy of Bank Deposits Act, and the
Intellectual Property Code. (G.R. No. 135882, June 27,
2001.)
9. Finally, Republic Act 6713, known as the Code of Conduct and
Ethical Standards for Public Officials and Employees, makes it a duty
of every public officer and employee to allow the inspection of all
public documents, and to respond to requests within fifteen days,
viz:
Section 5. Duties of Public Officials and Employees.
In the performance of their duties, all public officials and
employees are under obligation to:
(a) Act promptly on letters and requests. All public
officials and employees shall, within fifteen (15)
working days from receipt thereof, respond to letters,
telegrams or other means of communications sent by
the public. The reply must contain the action taken on
the request.
xxx

xxx

xxx

(e) Make documents accessible to the public. All

public documents must be made accessible to, and
readily available for inspection by, the public within
reasonable working hours.
10.
On 02 March 2016, petitioner requested access to all
information held about him by the respondent, within fifteen days
from respondent's receipt. A copy of the written request is attached
as Annex "A".
11.
The period given to respondent to allow petitioner access to
its database has already lapsed.
12.
As a result of respondent's failure or unjustifiable refusal to
allow access to its database, petitioners right to privacy is being
violated.
13.
The use and possible dissemination of the information held by
respondent is an unlawful intrusion into petitioner's privacy, which
intrusion threatens to ultimately violate petitioner's right to life,
liberty and security.
14.
The information which remains hidden from petitioner is in the
database of respondent located in the following offices: Intelligence
Unit, PNP, Camp Crame, Quezon City and The Mansion, Araneta
Center, Cubao, Quezon City.

PRAYER
WHEREFORE, petitioner prays that this Honorable Court give due
course to this Petition and issue the writ of habeas data and rule, as
follows:

1. Upon the filing of the petition, ENJOIN respondent

disseminating the information;

from

2. Upon notice and hearing, ORDER respondent to:

a. Produce the information in its possession regarding
petitioner's
person,
his/her
family,
home
and
correspondence;
b. Correct, suppress or destroy the information in its database,
whatever may be applicable as determined by this Honorable
Court; and
c. Rectify the damage caused to petitioner's reputation by
making a public apology to petitioner, which shall be
circulated in the manner and to such persons as the petitioner
may deem appropriate.
Other reliefs just and equitable under the premises are likewise
prayed for.
16 March 2016, Manila for Makati City, Philippines.
JEFFREY L. SANTOS
Counsel for the Petitioner
PTR No. 54321, 03 January 2016
IBP No. 678910
Roll No. 12345:05/11/2014: Manila
Rm. 123 Westlake Building, Soler St.,
Binondo, Manila
MCLE
Compliance
No.
1234,
05/11/2014

VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING
I, JOMAR NAYBI, of legal age, Filipino, married, after having been
duly sworn in accordance with law, depose and state that:
1. I am the petition in the above-stated Petition;

2. I caused the preparation of the foregoing Petition;

3. I have read the contents thereof and the facts stated therein
are true and correct of my personal knowledge and/or on the
basis of copies of documents and records in my possession;
4. I have not commenced any other action or proceeding
involving the same issues in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;
5. To the best of my knowledge and belief, no such action or
proceeding is pending in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;
6. If I should thereafter learn that a similar action or proceeding
has been filed or is pending before the Supreme Court, the
Court of Appeals, or any other tribunal or agency, I
undertake to report that fact within five (5) days therefrom
to this Honorable Court.

JOMAR NAYBI
Affiant
SUBSCRIBED AND SWORN to before me this ___day of ________,
2016, in City of Manila, affiant exhibiting his Drivers Licence No. 12345
issued in Manila on 07 March 2011.

NOTARY PUBLIC
Page No. ___;
Doc. No. ___;
Book No. ___;
Series of 2016.

SPECIAL POWER OF ATTORNEY

KNOW ALL MEN BY THESE PRESENTS:

I, JAYJAY HELTERBRAND, single, of legal age, Filipino and with residence
and postal address at No. 1 Fast Street, S.H. Loyola Street, Manila, do hereby
appoints MARK CAGUIOA, single, likewise of legal age, Filipino and with
postal address at Furious Street, Greenwoods, Pasig City, as my true and
legal representative to act for and in my name and stead and to perform the
following acts:
1. To sell, offer for
to the purchase
and in my name
of my property
Title No. 12345.

sale, and come to an agreement as

price and thereafter to sign for me
and receive payment from the sale
covered by Transfer Certifi cate of

HEREBY GRANTING unto my representative full power and

authority to execute and perform every act necessary to render
effective the power to sell the foregoing property, as though I myself,
have so performed it, and HEREBY APPROVING ALL that he may do by
virtue hereof with full right of substitution of his person and revocation
of this instrument.
IN WITNESS WHEREOF, I hereunto set my hand this 16 th day of
March 2016, in the City of Manila.

JAYJAY HELTERBRAND
Principal

MARK CAGUIOA
Attorney-in-Fact

Signed in the presence of:

_____________________________

___________________________________

Republic of the Philippines )

City of Manila
) S.S

BEFORE ME, personally appeared:

Name
JAYJAY HELTERBRAND
MARK CAGUIOA

SSS ID No. 12345

Drivers License No. 56789

known to me and to me known to be the same persons who executed the

foregoing instrument and acknowledged to me that the same is their free
and voluntary act and deed.
WITNESS MY HAND AND SEAL, on the date and place first above
written.

NOTARY PUBLIC
Doc. No.______;
Page No. ______;
Book No.______;
Series of 2016.

Republic of the Philippines

REGIONAL TRIAL COURT
10
th
Judicial RegionBranch 69Cagayan de Oro CityPEOPLE OF THE
PHILIPPINES,Plaintiff,CRIM. CASE NO. 08282NPS NO.X-06-INV-010A-0037Versus-For: ESTAFA THRUFALSIFICATIONOF PUBLIC DOCUMENTAPIPA G.
GURO,Accused,/*********************************************************
********************************/
INFORMATION
The undersigned Associate Prosecution Attorney II accuses ApipaG. Guro
of the crime of Estafa thru Falsification of Public Document,defined and
penalized under Article 315, paragraph 2, in relation toArticle 172 and
Article 48 of the Revised Penal Code, committed asfollows:
That on October 31, 2007 in the City of Cagayan de Oro,Philippines, and
within the jurisdiction of the Honorable Court,accused Apipa G. Guro
[hereinafter Accused] misrepresentingherself to be Doa Aiqa
Macarambon-Bacsarpa, applied for a loanwith South Bank in the amount
of PhP 5,000,000.00. A parcel of landlocated at Balulang, Cagayan de Oro
City, covered by Certificate of Title No. T-178439, in the name of Don
Mario Bacsarpa married toDoa Aiqa Macarambon-Bacsarpa was then
offered by the accusedas collateral. The accused did then and there
wilfully, unlawfully, andfeloniously falsify the deed of real estate
mortgage and thepromissory note corresponding to the said loan by
forging their signatures when in truth and in fact they did not so
participate, to thedamage and prejudice of the complaining bank and the
SpousesBacsarpas in the aforesaid sum of PhP 5,000,000.00.Contrary to
law.
Cagayan de Oro City, July 19, 2010
AZRIFA A. MAMUTUK
Associate ProsecutionAttoryney IIApproved:
JOANNE N. VELEZ
City Prosecutor
BAILBOND REOCMMENDED: PHP 100,000.00WITNESSES:
1.
Vincy Jane A. Polinar c/o South Bank, Kausawagan, Cagayande Oro
City2.And others.
CERTIFICATION
This is to certify that as shown by the records the undersigned,an
authorized officer, that there is a reasonable ground to believe thata

crime has been committed and that the accused is probably

guiltythereof; that the accused was informed of the complaint and of
theevidence submitted against her and was given an opportunity
tosubmit controverting evidence.
AZRIFA A. MAMUTUK
Associate ProsecutionAttorney II
SUBSCRIBED AND SWORN
to before me this July 19, 2010 inthe City of Cagayan de Oro, Philippines.

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 147
Makati City
PEOPLE

OF

THE

PHILIPPINES,

Plaintiff,
Crim Case
No. 123456
- versus -

for

Homicide
AKU SADO,
Accused.
x - - - - - - - - - - - - - - - - - - - - -x

INFORMATION
The undersigned Assistant City Prosecutor hereby accuses Aku Sado of the crime of
Homicide

committed

as

follows:

That on or about August 12, 2013, Makati City within the jurisdiction of this court,
the said accused, armed with a bladed weapon, with intent to kill, did then and there
willfully,unlawfully and feloniously attack, assault and stab one VIC TIMA, thereby
inflicting

upon

him

fatal

wound

which
Contrary

directly

caused
to

his

death.
law.

Makati, Philippines, August 22, 2013.

ATTY. BEN TONG

Private Prosecutor

WITNESSES:

MARIA MAKILING

JUAN TAMAD

CERTIFICATION
I hereby certify that a preliminary investigation was conducted in the above-entitled
case,and there is prima facie evidence that the crime of Homicide has been committed
and that the accused is probably guilty thereof.
ATTY. BEN TONG
Private Prosecutor

Bail Recommended: None

(CAPTION)
MOTION
(TO DECLARE DEFENDANT IN DEFAULT)
Plaintiff, by counsel and unto this Honorable Court, respectfully states
1.The records of the Honorable Court show that Defendant was served
with copy of the summons and of the complaint, together with annexes
thereto on _____________;
2.Upon verification however, the records show that Defendant
_____________ has failed to file his Answer within the reglementary
period specified by the Rules of Court despite the service of the summons
and the complaint;
3.As such, it is respectfully prayed that Defendant _____________ be
declared in default pursuant to the Rules ofCourt and that the Honorable
Court proceed to render judgment as the complaint may warrant.

PRAYER
WHEREFORE, it is respectfully prayed that Defendant _____________ be
declared in default pursuant to the Rulesof Court and that the Honorable
Court proceed to render judgment as the complaint may warrant.
Other relief just and equitable are likewise prayed for.
_____________, Philippines, __Date__.

(COUNSEL)
(NOTICE OF HEARING)
(EXPLANATION)
COPY FURNISHED:
OPPOSING COUNSEL
REPUBLIC OF THE PHILIPPINES7th JUDICIAL REGIONREGIONAL TRIAL
COURTBRANCH _____CEBU CITYJUAN DE LA CRUZPlaintiff,-versus- CIVIL
CASE
NO.
______________FOR:JUAN
TAMADDefendant.x---------------------------------------/MOTION TO DECLARE
DEFENDANT IN DEFAULT
Plaintiff, by counsel and unto this
Honorable Court, respectfully states1.
The records of the Honorable
Court show that Defendant was served with copy of thesummons and of
the complaint, together with annexes thereto on 15 January 2015.2.
Upon verification however, the records show that Defendant Juan Tamad
has failed tofile his Answer within the reglementary period specified by
the Rules of Court despite theservice of the summons and the
complaint;3.
As such, it is respectfully prayed that Defendant Juan
Tamad be declared in default pursuant to the Rules of Court and that the
Honorable Court proceed to render judgment as the complaint may
warrant.P R A Y E RWHEREFORE,
it
is
respectfully prayed that
Defendant JUAN TAMAD bedeclared in default pursuant to the Rules of
Court and that the Honorable Court proceedto render judgment as the
complaint may warrant.Other reliefs, just and equitable under the given
circumstances, are likewise prayed for.RESPECTFULLY SUBMITTED.16
FEBRUARY 2015CEBU CITY, PHILIPPINES.(COUNSEL) NOTICE OF
HEARINGHON. CLERK OF COURTBR. ______