COMMENT

THE DEFENDANTS, by counsel, respectfully state:

1. As to the portion of the pending motion of the plaintiff dropping the defendant Mr. xxx from the first and
the second amended complaints, the defendants Mrs. Xxx and her spouse Mr. xxx, respectfully manifest that
they do not object to that particular portion of the pending motion and of the second amended
complaint, considering that, indeed and truly, there is no legal and factual justification at all from the very
beginning to implead Mr. xxx as a co-defendant.

2. As to the portion of the pending motion seeking the admission of the second amended complaint itself,
the defendants respectfully manifest that they do not object thereto, subject to the condition that as soon as
the plaintiff is informed of the official order of the Court admitting her second amended complaint, she
must immediately pay to the Office of the Clerk of Court (OCC) the mandatory docket/foiling fees based
on the plaintiff’s new/alternative financial prayer stated in her second amended complaint which claims
a monetary award of P3,821,089.00, pursuant to:

(a) Rule 141 of the Rules of Court and based on existing jurisprudence on the doctrine of jurisdiction in relation
to docket/filing fees which implements the said Rule 141,

(b) the previous order of the Honorable Court on the same old issue, and

(c) the previous motions and other related pleadings on the said issue, (which the defendants hereby adopt
into this comment, by incorporation and reference, for brevity).

3. Subject to the final and official computation to be done by the Office of the Clerk of Court (OCC), the initial
estimate of the undersigned counsel is that the plaintiff must pay the additional amount of more than
P76,000.00 based on the ballpark formula of P20.00 per P1,000.00 of financial prayer, under Rule 141

4. Pursuant to the previous order of the Court on the same issue, there is a need to SUSPEND the
proceedings in this case until such time that the plaintiff shall have submitted to the Court the authentic copies
of the official receipts proving the fact of payment by the plaintiff of the above-mentioned mandatory
docket/filing fees.

5. In the spirit of procedural orderliness, the defendants should be required to file their joint amended answer
only upon receipt by them, thru counsel, of a copy of an order of the Court noting and approving the proofs of
payment by the plaintiff of the additional/jurisdictionaldocket/filing fees covering her new/additional/alternative
financial prayer, preferably within 15 days from receipt of such order.

WHEREFORE, premises considered, it is respectfully prayed:

1. That this comment be noted;

2. That the plaintiff be given a specific period within which to submit to the Court authentic copies of the official
receipts proving the payment of the mandatory/jurisdictional additional docket/filing fees covering her
new/additional/alternative financial prayer stated in the second amended complaint, counted from receipt by the
plaintiff of a copy of the order formal admitting her second amended complaint;