Professional Documents
Culture Documents
JUAN ILOK
Defendant.
Plaintiff,
BRAD ARMPIT
of
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COMPLAINT
1.
2.
3.
in the amount of ONE HUNDRED FIFTY THOUSAND PESOS (PHP 150 000.00)
to be paid on July 31, 2007 in the presence of Pedro Siponon and Jose Kogmohon.
4.
That upon due date the defendant paid only the amount of ONE
5.
6.
That the complainant try to settle the dispute within the barangay
level. After further demand the defendant failed to comply his obligation.
7.
and intentional refusal to pay his overdue obligation, Plaintiff is entitled to the
award of moral damages in the amount of P10,000.00;
16.
PRAYER
WHEREFORE, PREMISES CONSIDERED, it is most respectfully prayed
of this Honorable Court that, after due hearing, judgment be rendered against
the defendant ordering the latter to pay the plaintiff as follows:
1.
3.
4.
Cost of suit.
Other reliefs just and equitable under the premises are likewise prayed for.
I FURTHER CERTIFY that I have personally examined the affiantcomplainant and that I am satisfied that he voluntarily executed and understood his
Complaint-Affidavit.
VERIFICATION/CERTIFICATION
OF NON-FORUM SHOPPING
I, JUAN ILOK, Filipino, of legal age with address at Pardo Cebu City after
having been duly sworn on accordance with law depose and say:
1. That I am the plaintiff in the above-entitled case;
2. That I caused the preparation of the foregoing Complaint and I have
read the allegations therein and certify that the same are true and correct of my
own personal knowledge;
3. That I further certify that I have not commenced any other action
involving the same issues before the Supreme Court, Court of Appeals or any
division thereof or any tribunal or agency; and to the best of my knowledge no
such action is pending before the Supreme Court, Court of Appeals or any
division thereof or any tribunal or agency;
4. That in the event that any action involving the same should be made
known, I hereby bind myself to report the same within five (5) days from
knowledge thereof to this Honorable Court.
WITNESS WHEREOF, I hereunto set my hand this _______ day of
________, ________ at Quezon City, Metro Manila, Philippines.
JUAN ILOK
Plaintif
NOTARY PUBLIC
Doc. No._____
Page No. ____
Book No. _____
Series of _____
Defendant.
NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS
Sum
of
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MOTION FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADING
COMES NOW the Defendant, by the undersigned counsel, and unto this
Honorable Court, respectfully moves:
NOTICE OF HEARING
To: Atty. Angelico Zenon M. Delos Reyes
Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City
Greetings:
Please take notice that on Friday, _______________, at 8:00 oclock A.M., or as
soon thereafter as counsel may be heard, the undersigned will ask Branch _____
of the Regional Trial Court of Quezon City to approve the foregoing Motion for
Extension of Time to File Responsive Pleading.
COPY FURNISHED:
Atty. Angelico Zenon M. Delos Reyes
Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City
EXPLANATION
The foregoing Motion for Extension of Time to File Responsive Pleading
has been served on Plaintiffs counsel by registered mail due to lack of time and
personnel to effect personal delivery.
Defendant.
NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS
Sum
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MOTION FOR BILL OF PARTICULARS
COMES NOW the Defendant, by the undersigned counsel, and unto this
Honorable Court, respectfully alleges:
of
3.
That in the course of their business, the plaintiffs spouse made financial
contributions through the request and assurances of the defendant that such amount will
be repaid. That however, after several months and upon inquiry, plaintiffs spouse found
out that defendant misappropiated the financial investments made for his own personal
use. That despite demands, defendant failed to remit to and/or settle with the plaintiffs
spouse the aggregate amount of Ninety Eight Thousand Seven Hundred Pesos
(P98,700.00);
5.
the former executed an Acknowledgement of Debt in favor of the plaintiff on January 26,
2008, a photocopy of which is attached hereto as Annex A;
6.
defendants obligation through the Acknowledgement was reduced to the sum of Sixty
Thousand Pesos (P60,000.00), and transferred in favor of the plaintiff as formalized n a
duly-notarized Loan Agreement entered by and between the plaintiff and the defendant on
January 29 2008, a photocopy of which is hereto attached as Annex B;
2. That said allegations are insufficient and defective in that it fails to specify
the genuineness and authenticity of documents and the exact circumstances
which actually prevailed;
NOTICE OF HEARING
Greetings:
Please take notice that on Friday, _______________, at 8:00 oclock A.M., or as
soon thereafter as counsel may be heard, the undersigned will ask Branch _____
of the Regional Trial Court of Quezon City to approve the foregoing Motion for
Bill of Particulars.
COPY FURNISHED:
Atty. Angelico Zenon M. Delos Reyes
Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City
EXPLANATION
The foregoing Motion for Bill of Particulars has been served on the
Plaintiffs counsel by registered mail due to lack of time and personnel to effect
personal delivery.
Defendant.
NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS
Sum
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SECOND MOTION FOR EXTENSION OF TIME
TO FILE RESPONSIVE PLEADING
COMES NOW the Defendant, by the undersigned counsel, and unto this
Honorable Court, respectfully moves:
of
1. That the extended deadline for the filing of the Defendants Answer is
already tomorrow ________________ which was granted by this Honorable Court
as per Order dated ______________;
2. That the undersigned counsel was suddenly stricken by the dreadful and
painful sore-eyes infection last two days ago, Defendant need and respectfully
request another short extension in which to file his Answer to the Complaint;
NOTICE OF HEARING
COPY FURNISHED:
Atty. Angelico Zenon M. Delos Reyes
Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City
EXPLANATION
The foregoing Second Motion for Extension of Time to File Responsive
Pleading has been served on Plaintiffs counsel by registered mail due to lack of
time and personnel to effect personal delivery.
Defendant.
NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS
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FINAL MOTION FOR EXTENSION OF TIME
TO FILE RESPONSIVE PLEADING
Sum
of
COMES NOW the Defendant, by the undersigned counsel, and unto this
Honorable Court, respectfully moves:
1. That the second extended deadline for the filing of the Defendants
Answer is already tomorrow ________________ which was granted by this
Honorable Court as per Order dated ______________;
2. That the undersigned counsel, not yet fully recovered from the dreadful
sore-eyes, conducted an initial interview with the Defendant for the preparation
of his Answer but yesterday, when the draft pleading will be shown for
comments, Defendant failed to arrive at undersigneds office because the latter
contracted also the same disease;
4. That this final request for extension of the hearing is not for the purpose
of delaying the disposition of the case.
NOTICE OF HEARING
COPY FURNISHED:
Atty. Angelico Zenon M. Delos Reyes
Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City
EXPLANATION
The foregoing Final Motion for Extension of Time to File Responsive
Pleading has been served on Plaintiffs counsel by registered mail due to lack of
time and personnel to effect personal delivery.
Defendant.
NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS
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Sum
of
NOTICE OF HEARING
COPY FURNISHED:
Atty. Atty. Louise Marie S. Perez
Counsel for the Defendant
Citibank Tower Eastwood City
Bagumbayan, Quezon City
EXPLANATION
Defendant.
NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS
Sum
of
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1. That defendant and undersigned counsel was not able to timely file an
answer for the reason that both suffered a very infectious disease of sore-eyes
from _____________ upto _______________;
NOTICE OF HEARING
COPY FURNISHED:
Atty. Angelico Zenon M. Delos Reyes
Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City
EXPLANATION
The foregoing Motion to Lift Order of Default has been served on
Plaintiffs counsel by registered mail due to lack of time and personnel to effect
personal delivery.
NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS
Defendant.
Sum
of
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ANSWER
2. That the said two documents were fraudulently executed by the plaintiff
NAPOLEON C. GATMAITAN, the defendant EDGARDO S. SANTOS not
having executed any such promissory note in favor of the former, thus, the said
promissory note is null and void.
Quezon City,_____________
COPY FURNISHED:
Atty. Angelico Zenon M. Delos Reyes
Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City
VERIFICATION
EDGARDO S. SANTOS
Affiant
NOTARY PUBLIC
Doc. No.________;
Page No.________;
Book No.________;
Series of ________;
Defendant.
NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS
Sum
of
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MANIFESTATION AND MOTION TO WITHDRAW AS COUNSEL WITH
SUBSTITUTION OF COUNSEL
COMES NOW Atty. Louise Marie S. Perez, counsel of record for the
Defendant and unto this Honorable Court respectfully moves to withdraw as
counsel for Defendant with the express consent of the defendant as shown in this
motion.
That upon the approval of this Honorable Court, all pleadings, notices and
papers in connection with the above entitled case be addressed to the new
counsel, Atty. Corazon Alma T. Soliman, with address at 13th floor, Will Tower
Mother Ignacia St., Barangay South Triangle, Quezon City.
EDGARDO S. SANTOS
NOTICE OF HEARING
COPY FURNISHED:
EXPLANATION
The foregoing Manifestation and Motion to Withdraw as Counsel with
Substitution of Counsel has been served on Plaintiffs counsel by registered mail
due to lack of time and personnel to effect personal delivery.
Defendant.
NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS
Sum
of
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MOTION FOR EXECUTION OF JUDGMENT
COMES NOW the Plaintiff, by the undersigned counsel, and unto this
Honorable Court, respectfully moves for the execution of judgment under the
following premise:
1. That a decision has been rendered in this case on August 1, 2011, in favor of
the Plaintiff and against the Defendant;
2. That the period for appeal has already expired without the Defendant
having perfected an appeal from said decision;
3. That said decision is now final and executory.
NOTICE OF HEARING
TO: ATTY. CORAZON ALMA T. SOLIMAN
Counsel for the Defendant
13th floor, Will Tower
Mother Ignacia St.,
Barangay South Triangle, Quezon City
Greetings:
Please take notice that on Friday, _______________, at 8:00 oclock A.M., or as
soon thereafter as counsel may be heard, the undersigned will ask Branch _____
of the Regional Trial Court of Quezon City to approve the foregoing Motion for
Execution of Judgment.
COPY FURNISHED:
ATTY. CORAZON ALMA T. SOLIMAN
Consel for the Defendant
13th floor, Will Tower
Mother Ignacia St.,
Barangay South Triangle, Quezon City
EXPLANATION
The foregoing Motion for Execution of Judgment has been served on
Defendants counsel by registered mail due to lack of time and personnel to effect
personal delivery.