Professional Documents
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CONSTANCIA REYES,
Plaintiff,
CIVIL CASE NO._________
versus- FOR:“DAMAGES” based on
Articles 19, 21 and 2219 of
the Civil Code
NESTOR B. RODRIGUEZ,
SHARON MAY MERCADO
FARRO and MICHAEL
ANGELO DA-ANG
FARRO, IVY JOYCE B.
FERRERIA and REONEL D.
FERRERIA, JOYCE ANN S.
PALOGAN,
MAYFLOR F. GUIYAB,
DAISY R. DARACAN,
OLIVER G. FERRER, and
JOMAR U. MORADA,
GERSON R. GONZALES,
NEHEMIA S. ESPANOL,
Defendant/s,
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COMPLAINT
PARTIES
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CAUSE OF ACTION
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Annex “A”
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Annex “B”
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Annex “C”
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Annex “D”
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the amount of Php7,777.00. Consequently, a Criminal Complaint
docketed under NPS DOC. NO. II-05-INV-17G-00242 was lodged
against Constancia, et. al. before the Office of the City Prosecutor in
Santiago City accusing the former of committing the crime of
ESTAFA(Large Scale), defined and penalized under Article 315 of
the Revised Penal Code;
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Annex ”E”
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Annex ”F”
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Annex “G”
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of Sixty Nine Thousand Nine Hundred Ninety Three(Php69,993.00)
Pesos with the false promise that, in exchange, she will receive
product packages, monetary incentives in the amount of One
Thousand Five Hundred(Php1,500.00) Pesos from every new member
that she will recruit, and a free amortization of motorcycle for each
account. Consequently, a Criminal Complaint docketed under NPS
DOC. NO. II-13-INV-17I-00116 was lodged against Constancia, et. al.
before the Office of the City Prosecutor in Dagupan, Tabuk City,
Kalinga accusing the former of committing the crime of
SYNDICATED ESTAFA, defined and penalized under Article 315 of
the Revised Penal Code;
10. Fearing for her liberty and suffused with shame and
embarrassment for herself and her family, Constancia had to secure
the assistance of a legal counsel to represent her in defense of herself
and her family honor, and to assist her to prepare her Joint Counter-
Affidavit[8] sometime on 11 September 2017 which she submitted to
the Office of the City Prosecutor Santiago City on 12 September 2017,
thus Constancia incurred attorney’s fees of Fifty thousand
(Php50,000.00) pesos;
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Annex “H”
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Annex “I”
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level marketing and it was founded on July 13, 2015. The headquarters of
Blessings 777 is in San Juan City, Metro Manila. It is a company that is
dedicated in producing world class healthcare products because it has its
own manufacturing plant and have its own product and research
development group.
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12. And on 20 October 2017, the Office of the City Prosecutor
handed down its Resolution[10] under NPS DOC. NO. II-05-INV-
17G-00242 , the dispositive portion of which reads –
xxxxx
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Annex “J”
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CORAZON JIMENEZ GALLANDEZ, and RENIER
LANUZA SARAOS be DISMISSED.”
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Annex “K”
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Annex “L”
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According to Constancia Reyes, Blessings 777
issues an Official Collection Receipt as opposed to the
Purchase Order, Sales Order, and Motortrade
Receipts issued by the group of Benigno Pascual Blas,
Jr. She stressed that Mio Riders Club is different from
Blessings 777. She claimed that the business activities
of the Mio Riders Club are unknown to Blessings 777.
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Annex”M”
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Costales and Angelica Tolentino considering that they
are likewise victims of MIO and Blessings 777. As to
respondents Constancia Reyes, Analine Reyes,
Ronald Lim, Rexson Herrreria, John Reyes and
Jericho Reyes, we can not find any specific
participation whatsoever, not even a single allegation
about their part, in the scheme. “
COMMON ALLEGATIONS
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service, for which reason she should be awarded moral damages of
TWO HUNDRED FIFTY THOUSAND PESOS [Php250,000.00];
PRAYER
Other relief and remedy just and equitable under the premises
are also prayed for.
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THE LAW OFFICES OF DAMASEN & SUBIA
Unit 5, Mango Suites, Calao East, Santiago City
E-mail: lmdlawoffice@gmail.com
Mobile No.: 09178730405
Tel. No.: (078) 305-2392
By:
&
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IN WITNESS WHEREOF, I have hereunto set my hand this ____ of
February, 2018, at Santiago City.
CONSTANCIA REYES
Affiant
Driv. Lic. No. B12-06-000650
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