Oral Argument- Plaintiff

My client, a simple, hard-working guy with an ultimate dream to buy a house of his own. He worked
almost 23 hours a day for him to finally pursue his ultimate dream .

One day, it came to his knowledge that a house and lot located in the Wack Wack Subdivision is being
offered for sale by the Real Estate Company named Chill Lang Realty Corp. for the amount of 2 Million
Pesos.

Our client, upon knowing such sale, diligently searched the profile of the Company and even asked his
friends working on Real Estate business about the company and found out that it is indeed a reliable
and trusted company.

He paid the reservation fee of 10, 000. Upon payment of such reservation fee, he did not gave only his
hard-earned money, but also, his full trust and confidence with the Chill Lang Realty Corp.

He trusted the company and gave his entire savings thinking that before this year ends, he can finally
move to his newly bought house and spend new year there.

Your honor, our client religiously coordinated with the company thru its representatives from the
moment he paid the reservation fee until the last amount was paid. He relied and believe taht
everything is in order, he regularly visits the company office and even settle his account personally, he
signed all documents needed inside the company premises and when he received the acknowledgement
receipt of his last payment of the amount of 1 million, he was so happy.

Until one day, when he went to the principal office of the company, he learned a terrorizing fact, which
broke his heart and soul, the representative of the company told him that no contract of Sale was
entered into between our client and the company and that the person in charge with his account is no
longer connected with the company.

And it broke his heart even more when the Company told him that they cannot execute a contract of
Sale in his favor and that no house and lot will be transfered under his name since despite of the
receipts and ackowledgment receipts given to him as evidence of his payment, according to the records
of the company, he paid nothing for the purchase of the property.

Your Honor, we are pleading this hornorable court to compel to execute the necessary contract of sale
and to effect the transfer the property over the house and lot subject of this case in favor of client for
having paid the property in full. We are pleading to give credence to all the submitted evidence by our
client to support that there was indeed payment of 2 Milllion Pesos and that client is a legitimate buyer
of the company

We further plead to invalidate the defense of the Company that it was their former employee who
contracted with the plaintiff who should be solely liable for the claim of our client, and that they have
no liablity against her acts for defrauding the client because the employer should be jointly and severally liable for
the negligent act of the employee while in the performance of his duties and functions. The employer shall only be relieved if it show
that it exercised the diligence of a good father of a family, both in the selection of the employee and in the supervision of the
performance of his duties.

From the evidence we submitted to the honorable court, we can therefore concluded that Chill Lang Realty
Corp has been negligent for failure to supervise and monitor the transaction of client with their
employee, Ms. Ryzza Mae Sotto as well as their failure to impose measures to prevent this acts of their employees
that will cause damages to their client , this is evident from the fact that Ms. Ryzza Mae Sotto was able to
contact our client, she was also able to receive the payment of 2 million pesos and she was able to issue
receipt and other documents while inside the Companys principal address, as contrary to the statement
of the company that Ms Sotto was already terminated at that time, which is the reason why our client
never doubted all transcations done with Ms. Sotto.

Now, we are pleading this honorable court to judicially compel Chilll Lang Realty Corp., or if not, be
liable for the acts done by its employee who transacted with my client.