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Republic of the Philippines

FIRST JUDICIAL REGION


REGIONAL TRIAL COURT
Branch 7, Baguio City

JANET D. DE LIMA,
Plaintiff,
Civil Case No.: 000081
- versus -
FOR: DAMAGES
GLORIA M. MACAPAL,
Defendant.
x-------------------------------------x

APPEARANCE AS COUNSEL

CLERK OF COURT
Regional Trial Court
Branch 7, Baguio City

ATTY. REGINE V. VIERNES


202 3F Prudential Bldg.,
Session Rd., Baguio City

MAAM:
Please enter the appearance of the undersigned as counsel for the defendant in the above
titled case for all legal purposes.

RESPECTFULLY SUBMITTED.

24 February 2018.

ATTY. SUSHEN JIMBEL MARIZ M.SISON


Counsel for Defendant

3F La Azotea Bldg., Session Road, Baguio City


PTR No. 99910; 01/04/2013; Baguio City
IBP OR No: 6928764; 01/04/2013; Baguio City
Roll No.: 81319; 04/08/2005
Baguio City, Philippines
TIN No. 143-444-434-000

COPY FURNISHED PERSONALLY


on 24 February 2018

ATTY. JONE P. PURUEL


Counsel for Plaintiff
202 3F Prudential Bldg., Session Rd., Baguio City
PTR No. 66570; 01/04/2013; Baguio City
IBP OR No: 1234564; 01/04/2013; Baguio City
Roll No.: 93422; 04/08/2010
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 61, Baguio City

RODY D. DUDIRTY,
Plaintiff,
Civil Case No.: 000081
- versus -
FOR: COLLECTION OF SUM OF MONEY
JACKS RESTAURANT, INC.,
Defendant.
x-------------------------------------x

WITHDRAWAL AS COUNSEL WITH SUBSTITUTION

BRANCH CLERK OF COURT


Regional Trial Court
Branch 61, Baguio City

ATTY. AILYN K. KINDIPAN


3F La Azotea Bldg.,
Session Road, Baguio City

Please make of record the WITHDRAWAL of the undersigned ATTY. MYRE M. MEJIA
and the SUBSTITUTION of the undersigned ATTY. SUSHEN M. SISON as counsel for
plaintiff RODY D. DUDIRTY with her express conformity as indicated below. Henceforth
kindly address all pertinent notices to the undersigned new counsel ATTY. SUSHEN JIMBEL
MARIZ M. SISON at the address given below.

RESPECTFULLY SUBMITTED.

24 February 20187

ATTY. MYRE M. MEJIA ATTY. SUSHEN M. SISON


3F La Azotea Bldg., Session Road, Baguio City Counsel for Plaintiff
PTR No. 99910; 01/04/2013; Baguio City 3F La Azotea Bldg., Session Road, Baguio City
IBP OR No: 6928764; 01/04/2013; Baguio City PTR No. 88890; 01/04/2013; Baguio City
Roll No.: 81319; 04/08/2005 IBP OR No: 9999764; 01/04/2013; Baguio City
Baguio City, Philippines Roll No.: 87697; 04/08/2005
TIN No. 143-444-434-000 Baguio City, Philippines
TIN No. 999-007-434-000

COPY FURNISHED:

With Conformity: ATTY. AILYN K. KINDIPAN


Counsel for Defendant
ROD Y D. DUDIRTY 202 3F Prudential Bldg., Session Rd., Baguio City
Plaintiff PTR No. 66570; 01/04/2013; Baguio City
IBP OR No: 1234564; 01/04/2013; Baguio City
Roll No.: 93422; 04/08/2010
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 21, Baguio City

MARIAN R. RIVERA,
Petitioner,
Civil Case No.: 000053
- versus -
FOR: RESCISSION OF CONTRACT
DINGDONG D. DANTES, WITH DAMAGES
Respondent.
x-------------------------------------x

PETITION FOR CONTRACT RECISSION WITH DAMAGES

COMES NOW, petitioner, by the undersigned counsel, most respectfully states:

(1) That petitioner is Filipino, of legal age, and a resident of 098 Gibraltar, Baguio City
where he may be served with summons and other court processes, while respondent is
Filipino, of legal age, a friend of petitioner, and a resident of Apartment No. 99 Quirino
Hill, Baguio City where she may be served with summons and other court processes;

(2) That on 20 March 2014, petitioner bought from respondent the formers TOYOTA VIOS,
described in attached document ANNEX 1 and to be delivered on 20 July 2014, for SIX
HUNDRED THOUSAND PESOS (P600,000.00) payable on equal monthly installments.
Said sale was evidenced by a Contract of Sale herein attached as ANNEX 2;

(3) That petitioner had already paid two monthly installments totaling to THREE
HUNDRED THOUSAND PESOS (P300,000.00) as of 20 May 2015;

(4) That three (3) days after latest payment, petitioner learned that respondent already
transferred said property to ANTONNETE T. TAUS, their common acquaintance,
through a Deed of Donation on 25 July 2015 without reserving any sufficient property to
answer for her obligation and in fraud of petitioner pursuant to ARTICLE 1387 of the
CIVIL CODE OF THE PHILIPPINES;

(5) That due to said fraud, petitioner was deprived of Three Hundred Thousand Pesos
(P300,000.00) and suffered damages;

(6) That there are no other legal means to obtain reparation for such damages sustained, so
petitioner was constrained to file the instant petition engaging him to pay FIFTY
THOUSAND PESOS (P50,000.00) for legal services or attorneys fees; and

(7) That this action for rescission with damages was commenced within the Four (4) year
period allowed under ARTICLE 1389 of the CIVIL CODE OF THE PHILIPPINES.

WHEREFORE, petitioner respectfully prays that judgment be rendered in his favor:

(1) RESCINDING the Deed of Donation dated 27 February July 2017;


(2) ORDERING respondent to pay ONE HUNDRED THOUSAND PESOS (P100,000.00)
as NOMINAL DAMAGES; and

(3) ORDERING respondent to pay FIFTY THOUSAND PESOS (P50,000.00) as Attorneys


Fees.

Other just and equitable reliefs are likewise prayed for.

This 9th day of January 2013 in the City of Baguio, Philippines.

ATTY. REY M. MENDEZ


Counsel for Petitioner
202 3F Prudential Bldg., Session Rd., Baguio City
PTR No. 66570; 01/04/2013; Baguio City
IBP OR No: 1234564; 01/04/2013; Baguio City
Roll No.: 93422; 04/08/2010

REPUBLIC OF THE PHILIPPINES }


DONE: IN THE CITY OF BAGUIO } S.S.
VERIFICATION AND CERTIFICATION

I, MARIAN R. RIVERA, a Filipino, of legal age, and a resident of 098 Gibraltar, Baguio
City, subscribing under oath, hereby deposes and states that:

(1) I am the complainant in the instant case;

(2) 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; and

(3) I attest to the authenticity of the annexes thereof.

I certify further that:

(1) I have 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;

(2) 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; and

(3) If I 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, I hereby undertake to notify this Honorable Court within five (5) days from
such notice.

IN WITNESS WHEREOF, I have hereunto affix my signature this 27th day of February
2017 in the City of Baguio, Philippines.

MARIAN R. RIVERA
Affiant
Passport ID No. AW9334210
Issued: 01/12/2012; Baguio City

SUBSCRIBED AND SWORN to before me, in the City of Baguio, this 27 th day of
February 2017, by the affiant who has satisfactorily proven his identity to me through his
Passport Identification Detail indicated below his name, that he is the same person who
personally signed the foregoing document before me and who acknowledged that he executed
the same.

Atty. Sushen Jimbel Mariz M. Sison


Notary Public
2nd floor, Puso ng Baguio,
Session Road, Baguio City
(074) 415-3567/ 09058517855
PTR No. 105555; 1-9-17/Baguio City
Roll No.93355
IBP O.R. No. 423765 Baguio-Benguet
MCLE No. III- 1234567, 07-03-16
Commission Serial No. 89-NC-16 (R)
TIN: 865-888-333
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 21, Baguio City
NOLI DE CASTRO,
Petitioner,
Civil Case No.: 00038-R
- versus -
FOR: JUDICIAL PARTITION
BEATRICE MARAVILLA-ESTANIO
and REGINA V. MARAVILLA,
Respondent.
x-------------------------------------x

PETITION FOR JUDICIAL PARTITION


COMES NOW, petitioner, by the undersigned counsel and unto this Honorable Court,
respectfully states that:

(1) Petitioner is a Filipino citizen, of legal age, single, and resident of #23 Breeze Homes,
Pias Road, Camp 7 Barangay, Baguio City where he may be served with summons and
other court processes;

(2) Respondent BEATRICE MARAVILLA-ESTANIO is a Filipino citizen, of legal age,


married to Ysmael I. Estanio, and resident of #55 Tarbora, Trancoville, Baguio City
where she may be served with summons and other court processes, while respondent
REGINA V. MARAVILLA is a Filipino citizen, of legal age, and resident of #24 Pias
Road, Camp 7 Barangay, Baguio City where she may be served with summons and other
court processes;

(3) Petitioner and respondents are the legitimate children and sole heirs of their deceased
father PATRICIO O. MARAVILLA who died intestate on 12 December 2014, as
evidenced by his death certificate herein attached as ANNEX 1;

(4) Deceased left intestate estate consisting of:

(a) One (1) parcel of land located at Crystal Cave, Baguio City, covering 750 square
meters, more particularly described by Transfer Certificate of Title No. 9238
herein attached as ANNEX 2, and
(b) Six (6) parcel of lands located at Woodsgate, Camp 7, Baguio City, covering a
total of 1,500 sq. m. and more particularly described in Transfer Certificate of
Title No. 3333-B herein attached as ANNEX 3;

(5) Deceased left no indebtedness or obligations chargeable against his intestate estate;

(6) Petitioner and respondents, however, failed to agree on project partition of said parcel of
land, leading petitioner to institute this ordinary action for partition pursuant to
SECTION 1, RULE 74 of the RULES OF COURT and thereby committing him to pay
FIFTEEN THOUSAND PESOS (P15,000.00) for legal services.

WHEREFORE, petitioner respectfully prays that judgment be rendered in his favor: (1)
ORDERING the partition and segregation of ONE-THIRD (1/3) portion belonging to petitioner
of the parcel of land described in paragraph 4[a] hereof; (2) ORDERING the partition and
segregation of the ONE-THIRD (1/3) portion belonging to petitioner of the six (6) parcels of
land described in paragraph 4[b] hereof; (3) ORDERING respondents to pay petitioner FIFTEEN
THOUSAND PESOS (P15,000.00) as Attorneys Fees; and (4) ORDERING such other reliefs as
this court may deem just and equitable under the circumstances.

This 27th day of February 2017 in the City of Baguio, Philippines.

ATTY. LARRY R. RONDEZ


Counsel for Petitioner
122 3F Prudential Bldg., Session Rd., Baguio City
PTR No. 22220; 01/02/2013; Baguio City
IBP OR No: 1222264; 01/02/2013; Baguio City
Roll No.: 64422; 04/08/2009

REPUBLIC OF THE PHILIPPINES }


DONE: IN THE CITY OF BAGUIO } S.S.

VERIFICATION AND CERTIFICATION


I, NOLI DE CASTRO, a Filipino, of legal age, and a resident of #23 Breeze Homes,
Pias Road, Camp 7 Barangay, Baguio City, subscribing under oath, hereby deposes and states
that:

(1) I am the complainant in the instant case;

(2) 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; and

(3) I attest to the authenticity of the annexes thereof.

I certify further that:

(1) I have 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;

(2) 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; and

(3) If I 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, I hereby undertake to notify this Honorable Court within five (5) days from
such notice.

IN WITNESS WHEREOF, I have hereunto affix my signature this 27th day of February
2017 in the City of Baguio, Philippines.
NOLI DE CASTRO
Affiant
SSS No. 7732
Issued: 11/12/2011; Baguio City

SUBSCRIBED AND SWORN to before me, in the City of Baguio, this 27 th day of
February 2017, by the affiant who has satisfactorily proven his identity to me through his SSS
Identification Detail indicated below his name, that he is the same person who personally signed
the foregoing document before me and who acknowledged that he executed the same.

Atty. Sushen Jimbel Mariz M. Sison


Notary Public
2nd floor, Puso ng Baguio,
Session Road, Baguio City
(074) 415-3567/ 09058517855
PTR No. 105555; 1-9-17/Baguio City
Roll No.93355
IBP O.R. No. 423765 Baguio-Benguet
MCLE No. III- 1234567, 07-03-16
Commission Serial No. 89-NC-16 (R)
TIN: 865-888-333

Republic of the Philippines


FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 4, Baguio City

MOCHA U. USON,
Plaintiff,
Civil Case No.: 000023
- versus -
FOR: COLLECTION OF SUM OF MONEY
LENI R. ROBREDO,
Defendant.
x-------------------------------------x

COMPLAINT FOR COLLECTION OF SUM OF MONEY


COMES NOW, plaintiff, by counsel and unto this Honorable Court, respectfully states
that:
(1) Plaintiff is a Filipino, of legal age, and a resident of 67 Green Valley Subdivision, Baguio
City where she may be served with summons and other processes;

(2) Defendant is also a Filipino, of legal age, and a resident of 12 Brgy. Camp Allen, Baguio
City where she may be served with summons and other processes;

(3) On 10 January 2011 and over a period of six (6) months, defendant borrowed certain
amounts from plaintiff totaling to NINE HUNDRED THOUSAND PESOS
(P900,000.00), and promised to pay these amounts on or before 20 November 2012 as
evidenced by three (3) promissory notes herein attached as ANNEX A, ANNEX B and
ANNEX C.

(4) When the due date arrived and despite repeated demands thereafter, both oral and written,
defendant failed or refused to pay said amount;

(5) Resort to Barangay Conciliation process proved futile as defendant failed to appear
despite being duly notified. Thus, a Certification to File Action, a copy of which is
attached as ANNEX D, was issued by the Barangay Chairperson;

(6) Defendants obligation is due and demandable, and plaintiff is entitled to the payment of
the entire amount of Nine Hundred Thousand Pesos (P900,000.00);

(7) By reason of defendants unreasonable failure or refusal to pay his due and demandable
obligation, plaintiff was forced to engage the services of a counsel to vindicate his rights
committing himself to pay legal services amounting to Fifty Thousand Pesos
(P50,000.00).

WHEREFORE, plaintiff respectfully prays for judgment be rendered in his favor


through a Decision directing defendant to pay him NINE HUNDRED THOUSAND PESOS
(P900,000.00) plus legal interest as actual damages, and FIFTY THOUSAND PESOS
(P50,000.00) as Attorneys Fees.

Other just and equitable reliefs are likewise prayed for.


This 28th day of February 2017, in the City of Baguio, Philippines.

ATTY. STEPH C. CASTRO


Counsel for Plaintiff
2F Puso ng Baguio Bldg., Session Road, Baguio City
PTR No. 11111; 01/14/2013; Baguio City
IBP OR No: 1122764; 01/14/2013; Baguio City
Roll No.: 76555; 04/08/2004
Baguio City, Philippines
TIN No. 111-423-114-000
REPUBLIC OF THE PHILIPPINES }
DONE: IN THE CITY OF BAGUIO } S.S.

VERIFICATION AND CERTIFICATION


I, MOCHA U. USON, a Filipino, of legal age, and a resident of 67 Green Valley
Subdivision, Baguio City, subscribing under oath, hereby deposes and states that:

(1) I am the complainant in the instant case;

(2) 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; and

(3) I attest to the authenticity of the annexes thereof.

I certify further that:

(1) I have 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;

(2) 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; and

(3) If I 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, I hereby undertake to notify this Honorable Court within five (5) days from
such notice.

IN WITNESS WHEREOF, I have hereunto affix my signature this 28th day of February
2017 in the City of Baguio, Philippines.

MOCHA U. USON
Affiant
Drivers License No. A01-12-032984
Issued: 10/12/2012; Baguio City
SUBSCRIBED AND SWORN to before me, in the City of Baguio, this 28 th day of
February 2017, by the affiant who has satisfactorily proven her identity to me through her
Drivers License indicated below her name, that she is the same person who personally signed
the foregoing document before me and who acknowledged that she executed the same.
Atty. Sushen Jimbel Mariz M. Sison
Notary Public
2nd floor, Puso ng Baguio,
Session Road, Baguio City
(074) 415-3567/ 09058517855
PTR No. 105555; 1-9-17/Baguio City
Roll No.93355
IBP O.R. No. 423765 Baguio-Benguet
MCLE No. III- 1234567, 07-03-16
Commission Serial No. 89-NC-16 (R)
TIN: 865-888-333
Republic of the Philippines
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 8, Baguio City

PROCOPRIO B. ANDRES,
Plaintiff,
Civil Case No.: 000044-R
- versus -
FOR: ANNULMENT OF DOCUMENT
ROMEO N. BONIFACIO,
Defendant.
x-------------------------------------x

COMPLAINT
COMES NOW, plaintiff, by counsel and unto this Honorable Court, respectfully states
that:
(1) Plaintiff is a Filipino, of legal age, single, and a resident of 67 Green Valley Subdivision,
Baguio City where he may be served with summons and other processes, while defendant
is also a Filipino, of legal age, single, a friend of plaintiff, and a resident of 13 Brgy.
Camp Allen, Baguio City where he may be served with summons and other processes;

(2) Plaintiff owns a MOTOR VEHICLE, hereinafter referred to as personalty, which is


described as follows:

ONE (1) UNIT MOTOR VEHICLE


Make: Isuzu 2012 Model
Plate Number: UV AFB 143
MV File Number: 4305-10999
Motor Number: 886668
Serial/ Chassis Number: VCM 6565 432
Official Receipt Number: 12334789
Certificate of Registration Number: 93334060

(3) Petitioner and defendant agreed to enter into a contract of sale wherein the former shall
sell the second personalty to the latter in exchange for money. However, as no amount
was ever agreed upon by them, the contract was never made;

(4) On 17 November 2012, defendant borrowed the personalty for business purposes and
petitioner, a good friend as he was, lent said personalty to the former on condition that the
personalty be returned ten (10) days thereafter;

(5) However, on the date of the supposed delivery, defendant refused to deliver said
personalty and claimed that he bought the same from petitioner. Defendant, through
fraud, showed petitioner their purported DEED OF ABSOLUTE SALE dated 17
November 2012, herein attached as ANNEX 1, in which said personalty was allegedly
sold for and in consideration of SEVEN HUNDRED FIFTY THOUSAND PESOS
(P750,000) and which contained the forged signature of the latter;

(6) The events led petitioner to obtain legal services of a counsel and to institute the instant
complaint for annulment of the abovementioned document, thereby committing him
FIFTY THOUSAND PESOS (P50,000.00) as Attorneys Fees; and
(7) This action is commenced within Four (4) years from the time of discovery of
defendants fraud pursuant to ARTICLE 1391 of the CIVIL CODE OF THE
PHILIPPINES.

PRAYER
WHEREFORE, plaintiff most respectfully prays this Honorable Court to render
judgment in his favor:
(1) ANNULLING the Deed of Absolute Sale dated 17 November 2012;
(2) ORDERING restitution of the possession of the personalty described in paragraph 2
hereof to plaintiff;
(3) ORDERING defendant to pay plaintiff FIFTY THOUSAND PESOS (P50,000.00) as
Attorneys Fees;
(4) ORDERING other just and equitable reliefs as it may deem proper.

This 11th day of January 2013 in the City of Baguio, Philippines.

ATTY. LORENZ YEE


Counsel for Plaintiff
202 3F Prudential Bldg., Session Rd., Baguio City
PTR No. 66570; 01/04/2013; Baguio City
IBP OR No: 1234564; 01/04/2013; Baguio City
Roll No.: 93422; 04/08/2010

REPUBLIC OF THE PHILIPPINES }


DONE: IN THE CITY OF BAGUIO } S.S.

VERIFICATION AND CERTIFICATION


I, PROCOPRIO B. ANDRES, a Filipino, of legal age, and a resident of 67 Green Valley
Subdivision, Baguio City, subscribing under oath, hereby deposes and states that:

(4) I am the complainant in the instant case;

(1) 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; and

(2) I attest to the authenticity of the annexes thereof.

I certify further that:

(1) I have 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;

(2) 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; and

(3) If I 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, I hereby undertake to notify this Honorable Court within five (5) days from
such notice.

IN WITNESS WHEREOF, I have hereunto affix my signature this 11th day of January
2013 in the City of Baguio, Philippines.

PROCOPRIO B. ANDRES
Affiant
Drivers License No. A01-12-035555
Issued: 10/13/2012; Baguio City

SUBSCRIBED AND SWORN to before me, in the City of Baguio, this 11 th day of
January 2013, by the affiant who has satisfactorily proven his identity to me through his Drivers
License indicated below his name, that he is the same person who personally signed the
foregoing document before me and who acknowledged that he executed the same.
Atty. Sushen Jimbel Mariz M. Sison
Notary Public
2nd floor, Puso ng Baguio,
Session Road, Baguio City
(074) 415-3567/ 09058517855
PTR No. 105555; 1-9-17/Baguio City
Roll No.93355
IBP O.R. No. 423765 Baguio-Benguet
MCLE No. III- 1234567, 07-03-16
Commission Serial No. 89-NC-16 (R)
TIN: 865-888-333