1

REPUBLIC OF THE PHILIPPINES

7th Judicial Region

MUNICIPAL TRIAL COURT IN CITIES

CITY OF BOGO

Dakit, Bogo City, Cebu

HEIRS OF PABLITO DAMAYO CIVIL CASE NO. 1339

and ABUNDIA PERINO,

Plaintiffs,

FOR: ACCION PUBLICIANA/

- versus – RECOVERY OF POSSESSION,

DAMAGES, ATTY’S FEES AND

SPS. ANTONIO & DEBBIE ANN COSTS WITH PRAYER FOR

CATAQUEZ, et. al., PRELIMINARY MANDATORY

Defendants. INJUNCTION

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COMPLAINT

COMES NOW the plaintiffs, by the undersigned counsel, unto this Honorable

Court, most respectfully state that:

1. Plaintiffs are Filipino citizens, of legal age, with residence and postal
address at Kalubian, Libertad, Bogo City, Cebu, Philippines, where they
may be served with notice and other processes of this Honorable Court.

2. Defendants are of legal age, Filipinos and may be served with summons
and other processes of this Honorable Court at Siocon, Bogo City, Cebu,
Philippines.

3. Plaintiffs’ are the exclusive and absolute owners of a parcel of land by

reason of hereditary succession from their deceased parents, Spouses
Pablito Damayo and Abundia Perino, known as Lot No.2429, located at
Siocon, Bogo City, Cebu, Philippines, more particularly described as
follows:
“A parcel of land situated in Siocon, Bogo City, Cebu, Philippines,
covered by tax declaration no. 0111 16297, bounded on the North by
creek, bounded on the South by Lot Nos. 2431, 2430-prt, bounded on the
west by Lot Nos. 2428, 2431, bounded on the East by Lot Nos. 1854,
 2430-part, declared in the name of Spouses Pablito Damayo and Abundia
Perino.”

Copy of the tax declaration which has an assessed value of not more than
P20,000.00 is hereto attached and made an integral part as ANNEX “B”.

4. Plaintiffs and their predecessors in interests-parents had been in actual

and constructive possession and exercising acts of ownership of the
above-described as early as the year 1957 until the defendants through
stealth, violence, threat, and intimidation, unlawfully, illegally and
maliciously barged entry and took away the lawful possession of the
above-described lot from the poor and helpless plaintiffs, sometime on
April 7, 2006.

5. One of the herein plaintiffs, Carmelita Ursabia, immediately complained

and sought the help of the barangay authorities of Siocon, Bogo city,
Cebu for unlawful and illegal entry of the defendants who land grabbed
the property owned and in possession of the plaintiffs, without any legal
authority or court order secured by the defendants, to the great prejudice
and damage of the helpless plaintiffs.

6. During the conference before the barangay Siocon, Bogo City, Cebu,
Barangay Captain Emma Jagdon of Siocon, Bogo city, Cebu even
commented to the defendants that they should have no immediately
barged into the subject land and dispossessed the plaintiffs without legal
authority and court orders.

Copy of the said minutes before the barangay is hereto attached as ANNEX
‘C’ which forms integral part of this petition.

7. For the record, plaintiffs and their predecessor in interest-parents had

been in possession of the said lot for almost 50 long years and had been
faithfully and religiously paying the real property taxes on the above-
described property since 1957 and up go the present. Plaintiffs are ready
and willing to present original receipts of the taxes paid by them.

Attached hereto and marked as ANNEX D is the tax declaration issued in the
name of Spouses Pablio Damayo and Abundia Perino as early as the year
1961. Also hereto attached as ANNEX E is the joint affidavit of Epifania
Regala and Soledad Yocte, who by themselves are lot owners adjoining the
lot in issue, attesting the aforementioned facts and truth.

8. Plaintiffs predecessor in interests, Spouses Pablito and Abundia Damayo

bought the lot in issue from Sergio Escolar on April 1, 1957. This Sergio
Escolar was then the registered owner of the subject parcel of land until it
was sold and transferred in favor of Spouses Damayo, the plaintiffs
predecessor-in-interest. This Sergio Escolar in turn bought the said land
from Flora Lepatan. Attached hereto and made as integral part as
ANNEXES F, G and H, respectively, are the deed of sale executed by
Escolar in favor of Spouses Damayo, the tax declaration issued in the
name of Sergio Escolar in the year 1950 and the deed of sale executed by
 Flora Lepatan in favor of Sergio Escolar. In other words, series of
ownership had been made to different persons peacefully and at no point
did the defendants claim ownership on the said lot until the year 2006
that the defendant barged entry by force and violence.

9. Plaintiffs failed to file an ejectment case because of their poor financial

condition, coupled with a fact that Carmelita Ursabia, one of the plaintiffs
in this case was maliciously charged of the crime of attempted murder by
Fausto Cataquez and the herein defendant Antonio Cataquez.

10.For the grave injustice, the plaintiff suffered much from the defendants.
Defendants should be directed to desist from further unlawfully and
illegally possessing the subject lot with any color of authority or lawful
court order and for them to be ordered to vacate the same.

11.Great and irreparable damage and injury has been suffered by the
plaintiffs and will continue to suffer unless a preliminary mandatory
injuction be issued directing the defendants to vacate the land and leave
the premises because their actions had no place in the civilized society
when they by force immediately grabbed the land, possessed it despite of
the fact that plaintiffs were in lawful possession of the same in the
concept of an owner for almost 50 long years, Defendants should not gad
put the law into their own hands.

12.Plaintiffs are willing to post a bond in the amount that may be fixed by the
court to the effect that they will pay all the damages that may sustain by
reason of the writ of the preliminary mandatory injuction be issued.

13.Plaintiff even caused a Legal Notice to vacate to be sent to the defendants

but the same has just fell into deaf ears. Copy of the notice to vacate is
hereto attached as ANNEX I.

14.That by reason of the defendants unjustified refusal to vacate the land

and their unlawful and illegal actions of dispossessing the lot in issue,
plaintiffs suffered serious anxieties, frustrations, sleepless nights
warranting the award of moral damages of not less than P30,000.00 and
exemplary damages of P30,000.00.

15.That plaintiffs were constrained to hire the services of counsel and

promise to pay the sum of P20,000.00, appearance fee of P1,500.00 and
litigation costs of not less than P15,000.00 and ought to be reimbursed by
the defendants solidarily.

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this
Honorable Court that judgment be rendered in favor of the plaintiffs and against the
defendants,

a. By directing them to restitute and vacate the land subject of this case
 b. Defendants be ordered to pay the plaintiffs jointly and severally the
following:

1. P30,000.00 as moral damages

2. P30,000.00 as exemplary damages
3. P20,000.00 as attorney’s fees
4. P1,500.00 as appearance fee per hearing
5. P15,000.00 as litigation costs

Plaintiffs also pray for such other reliefs and remedies just and equitable

under the circumstances.

Bogo City, Cebu, Philippines, October 5, 2010.

ATTY. JOVEN MONDIGO, JR.

MADEJA-MONDIGO LAW OFFICE

PTR NO. 6412029 1/28/10

IBP ROLL NO. 813584 1/28/10

ROLL NO. 47853

MCLE NO. 0016617

Counsel for Plaintiffs

VERIFICATION AND CERTIFICATION

That we, CARMELITA DAMAYO URSABIA, MYRNA DAMAYO LEQUIN and

CELIA DAMAYO DIGNOS, of legal age, residents of Siocon, Bogo City, Cebu,
Philippines, Filipino citizens, after having been duly sworn to in accordance
with law, hereby depose and say:

1. That we are the plaintiffs in the above-entitled case;

2. That we have caused the preparation of the foregoing complaint;
3. That we have read the allegations stated therein and the same are
true and correct to the best of my knowledge and belief;

4. That we have not commenced any other action involving

the same issues in the Supreme Court, Court of Appeals or any
other court, tribunal or agency; and that to the best of our
knowledge no such action or proceeding is pending in the said
courts, tribunal or agency and that should we hereinafter learn that
the similar action or proceeding has been filed or its pending
therein, we hereby undertake to notify this Honorable Court within
five (5) days from said notice of such similar and/or pending action
or proceeding.
 IN WITNESS WHEREOF, we hereunto affixed our signatures below on
this 4th day of September, 2010 at Bogo City, Cebu, Philippines.

CARMELITA D. URSABIA MYRNA D. LEQUIN

CTC NO. CTC NO.
Issued on Issued on
At At

CELIA D. DIGNOS
CTC NO.
Issued on
At

REPUBLIC OF THE PHILIPPINES)

PROVINCE OF CEBU )S.S.
CITY OF BOGO )
X--------------------/

ACKNOWLEDGMENT

BEFORE ME, Notary Public for and in the City of Bogo, Cebu,
Philippines, personally appeared CARMELITA D. URSABIA, MYRNA D. LEQUIN
and CELIA D. DIGNOS with their Community Tax Certificates indicated below
their names, known to me and to me known to be the persons who executed
and signed the foregoing instrument and they acknowledged to me that the
same is their free and voluntary act and deed.

WITNESS MY HAND AND SEAL on this 4th day of September, 2010 at

Bogo City, Cebu, Philippines.

ATTY. CESAR M. MADEJA

Notary Public
Until December 2010
Office Address: Cogon, Bogo City, Cebu
Roll No. 59950
PTR 0647234, 12.08.10, Bogo City, Cebu
IBP 0992242, 10.30.10, Cebu
MCLE Compliance No. IV-0011872
MCLE Compliance No. V-0008202

Doc No.
Page No.
Book No.
Series of
 2. Complaint For Ejectment

Republic of the Philippines

National Capital Judicial Region
METROPOLITAN TRIAL COURT
Branch 10, Makati City

Zendrix Echavez,

Plaintiff,
Civil Case No. 16
-versus- For: Ejectment

Marilyn Cosares,
Defendant.

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COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

The Parties

1.) Plaintiff is a Filipino, of legal age, and resident of No. 10 Hidalgo Street, San
Lorenzo Village, Makati City;

2.) Defendant, is also a Filipino, of legal age and resident of No. 20 Ponce Street,
San Lorenzo Village, Makati City, where he may be served with summons
and other court processes.

The Facts

1. By virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid
apartment for a consideration of P5,000.00 a month as rental to be paid within the
first ten (10) days of each month starting November 3, 2011;

2. The defendant failed to pay the agreed rental for several months starting February
19, 2012 up to the present;

3. On May 3, 2012, the plaintiff sent a letter of demand to vacate the apartment which
was received by the defendant as shown in the registry return receipt hereto
attached as Annex “A”;

4. Despite said letter of demand which was repeated by oral demands, the defendant
failed and still refused to pay the agreed amount of rentals and to vacated the
apartment;
 Prayer

WHEREFORE, plaintiff respectfully prays for judgement in his favor by

ordering defendant to vacate the property and peacefully turn over
possession to plaintiff and for defendant to pay plaintiff the amount of One
Million Two Hundred Thousand Pesos (P 1, 200,000.00) representing rentals
on the machineries for eight (8) months and fifty thousand pesos
(50,000.00) for Attorney’s Fees

Other just and equitable reliefs are also prayed for.

Muntinlupa City for Makati City, September 30, 2008

Atty. Marjorie Echavez

Counsel for Plaintiff
5 Floor, Madrigal Business Tower,
th

Madrigal Business Center, Alabang, Muntinlupa City

Attorney’s Roll No. 34975
IBP O.R No. 23655-01/ 03/08-Muntinlupa
PTR O.R No. 45321-01/03/08-Muntinlupa
MCLE Compliance No. II-008776-Nov. 17, 2008
 3.
Republic of the Philippines
City of Cebu S.S.
X--------------------- ------------------- ---------------X

AFFIDAVIT OF ADVERSE CLAIM

I, MARIE B. DELA CRUZ, of legal age, Filipino, single and a resident of 2223
Washington Street, Pio del Pilar, Makati City, after having been duly sworn to in accordance
with law, depose and state:

1. That on July 10, 2013, I have entered into a Deed of Conditional Sale which was
acknowledged on the same date before Notary Public Juan Tamad of Makati City and
entered in his Notarial Register as Doc. No. 2, Page 2, Book II, Series of 2013. A copy of the
said Deed is hereto attached as ANNEX “A” and made an integral part of this Affidavit;

2. That in the said Deed of Conditional Sale, I was the VENDEE of a certain parcel of land
covered by Transfer Certificate of Title No. 111222, more particularly described as follows:

(Technical Description of Property)

3. That because I still have a balance on the purchase price in the amount of P500,000.00
which is payable within one (1) (year) from the date of signing thereof, it was stipulated in
the aforementioned Deed that title and ownership over the subject property will only be
transferred upon full payment of the same;

4. That the VENDOR in the said Deed of Conditional Sale agreed that upon its execution, said
Deed shall be annotated in the Title with the Office of the Register of Deeds of Makati City;

5. However, since the said Deed of Conditional Sale per se could not be annotated on the Title
with the Office of the Register of Deeds, I am therefore executing this Affidavit for the
purpose of attesting to the truthfulness of the foregoing allegations and in support of my
request for the annotation of an adverse claim over the parcel of land covered by the
Transfer Certificate of Title No. 111222.

IN WITNESS WHEREOF, I have hereunto set my hand this 26th day

of September 2013 in Makati City, Metro Manila, Philippines.

MARIE B. DELA CRUZ

Affiant

SUBCRIBED AND SWORN TO before me this 26th day of September

2013 in Makati City, Metro Manila, Philippines, affiant exhibiting to me her Philippine
Passport No. 123456 issued in Manila on January 12, 2012 and valid until January 12, 2017.
Doc. No. _____;
Page No. _____;
Book No. _____;
Series of 2013.
4
Republic of the Philippines
City of Cebu S.S.

X--------------------- ------------------- ---------------X

1. AFFIDAVIT OF COMPLIANCE
I, Marjorie C. Echavez, of legal age, single, a resident of Escario Extension C.F
120., Cebu, Philippines, after being sworn to in accordance with law, depose and
state:
That I am a graduate of Bachelor of Arts Major in Political Science as my pre-
law degree on March 18, 2013.
That I have submitted my transcript of records, 2 pcs. (1x1 picture) for registrar
and school I.D with royal blue background, 2 pcs. (2x2 picture) for student file,
certificate of good moral character, and an NSO authenticated birth Certificate on
May 28, 2014 at University of Southern Philippines Foundation, Salinas Drive Lahug.
Cebu, Philippines.
That I have complied with all other requirements for student admission set forth
by the University of Southern Philippines Foundation, College of Law.
AFFIANT FURTHER SAYETH NAUGHT. IN WITNESS WHEREOF, I have here
unto set my hand this 27th day of November, 2016 at Cebu,City, Philippines.

Marjorie C. Echavez
Affiant
5.
Republic of the Philippines
City of Cebu S.S.

X--------------------- ------------------- ---------------X

ACKNOWLEDGEMENT

BEFORE ME, this 27th day of November, 2016 in the City of Cebu, Philippines
personally appeared: Marjorie C. Echavez, with postal Government I.D No: 3505507
issued on April 25, 2013 at Cebu City, Philippines, known to me to be the same
person who executed the foregoing instrument, and he acknowledged to me that the
same is his free act and deed.

IN WITNESS WHEREOF, I have hereunto set my hand and affixed my notarial

seal, the day and place above written.

Doc. No. 2; MARJORIE C. ECHAVEZ

Page No. 3; NOTARY PUBLIC for Cebu Province
Book No. 4; Escario, Extension C.F. 120
Series of 5. Appointment No. 123456 until
December 31, 2020
Roll of Attorney: 3598733
IBP No. 361379454 / Date/Place of Issue
PTR No. 236688/ Date/ Place of Issue
6.

Republic of the Philippines

Cebu City, Cebu Region VII
REGIONAL TRIAL COURT
Branch 12 (66)
Cebu City

Zendrix Echavez,

Plaintiff,
Civil Case No. 16
-versus- For: Notice of Lis Pendens

Marilyn Cosares,
Defendant.

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NOTICE OF LIS PENDENS

THE REGISTER OF DEEDS

Makati City

Please take notice that a parcel of land of land covered by Transfer Certificate of Title
No. 123456 located in Cebu City registered in the name of defendant, is the subject matter of an
action for reconveyance filed by Zendrix Echavez, above-named plaintiff. Accordingly, please
record this notice on the title.

Respectfully submitted.

Makati City, Philippines. December 11, 2016

ATTY. MARJORIE ECHAVEZ

Counsel for the Plaintiff

Copy Furnished:

ATTY. MARJORIE ECHAVEZ

Counsel for the Defendant
4444 Zamora Street, Pasay City
7.

Republic of the Philippines

Cebu City, Cebu Region VII
REGIONAL TRIAL COURT
Branch 12 (66)
Cebu City

Zendrix Echavez,
Plaintiff,
Civil Case No. 16
-versus- For: Motion to Cancel Lis Pendens

Marilyn Cosares,
Defendant.

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2. MOTION TO CANCEL LIS PENDENS

Plaintiff, by counsel and to this honorable Court, respectfully states:

1. Defendant caused the annotationor registration of a notice of lis pendens on the

subject matter of the instant suit,

2. Defendant caused the recording of the lis pendens for the purpose of molesting
plaintiff, and the recordal thereof is not necessary to protect his rights to the property,
his right thereto, if any, is only indirect and contingent.

3. The recordal of the lis pendens is prejudicial to plaintiff’s interest to the property
because, being the owner of said property , it is burden and it restricts its
transferability by sale, as no one will buy it during the pendency of the case and for
as long as the lis pendens is not cancelled.

RELIEF

WHEREFORE, plaintiff respectfully prays that the notice of lis pendens be order
cancelled.

Other just and equitable reliefs are likewise prayed for.

ATTY. MARJORIE C. ECHAVEZ

Counsel for the plaintiff
CF 120, Escario Extension, Cebu City
Roll No. 75648
IBP No. 0456- Cebu
PTR No. 11456788, issued on April 12, 2014
MCLE Compliance Cert No. 66587
 8
DEED OF ABSOLUTE SALE

KNOW ALL MEN BY THESE PRESENTS:

That we, Spouses NICOLAS A. MAPAIT, JR. and MERLINA A. MAPAIT, both of
legal age, Filipino citizens, with residence and postal address at Barangay Cayang,
Bogo City, Cebu, Philippines, for and in consideration of the sum of Eighty-Four
Thousand Seven Hundred Eighty Pesos (P84,780.00), to us in hand paid by
ROSELLER N. GELIG, likewise of legal age, single, Filipino and a resident of Sitio
Panabilan, Barangay Nailon, Bogo City, Cebu, Philippines, receipt whereof is hereby
acknowledged by these PRESENTS, do hereby SELL, CEDE, CONVEY, TRANSFER and
QUITCLAIM, absolutely and irrevocably, unto the said ROSELLER N. GELIG, his
heirs, assigns and/or administrators, our rights, interest and participation over a
portion of a parcel of land which is more specifically described and bounded as
follows:

“ A ONE THOUSAND THREE HUNDRED TWENTY-TWO (1,322) SQUARE

METERS portion of a parcel of land known as Cadastral Lot No. 332-A-1

situated in Barangay Cayang, Bogo City, Cebu, bounded on the North by Lot
No. 336; on the East by Lot No. 332-A-2; on the South by Lot No. 338-A,
and on the West by Lot No. 337-A, 337-B, containing an area of 2,644
square meters, more or less and declared under Tax Declaration No. 0111
07184A in the name of Nicolas Mapait, Jr.”

That we have the perfect and absolute right to dispose a portion of the above
described property being the declared owners, and the said property is free from
any lien or encumbrances in any manner whatsoever and that we shall defend the
herein vendee from the claim or claims of any person whomsoever.

IN WITNESS WHEREOF, we have hereunto affix our signatures this

______day of __________________, ________, in Bogo City, Cebu, Philippines.

NICOLAS A. MAPAIT, JR. MERLINA A. MAPAIT

(vendor) (vendor)

CTC No. CTC No.

Issued at Issued at

On On

Gov’t. ID No. Gov’t ID No.

SIGNED IN THE PRESENCE OF:

______________________________
____________________________
Republic of the Philippines)

Province of Cebu )S.S.

City of Bogo )

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ACKNOWLEDGMENT

BEFORE ME, the undersigned Notary Public, personally appeared Spouses

Nicolas A. Mapait, Jr. and Merlina A. Mapait with their Community Tax Certificates
and/or Identification Cards above-indicated, KNOWN TO ME AND TO ME KNOWN to
be the same persons who executed the foregoing instrument and acknowledged the
same to be their own free will and voluntary act.

WITNESS MY HAND AND SEAL, on the same date and place aforementioned.

Doc. No._______

Page No._______

Book No._______

Series of ______
9.) LAST WILL AND TESTAMENT

LAST WILL AND TESTAMENT

KNOW ALL MEN BY THESE PRESENTS:

I, MARJORIE C. ECHAVEZ Filipino citizen, of legal age, single, born on

the 16th day of September, 1992, a resident of Purok Orchids, Barangay
Gairan, Bogo City, Cebu, Philippines, being of sound and disposing mind and
memory, and not acting under undue influence or intimidation from anyone,
do hereby declare and proclaim this instrument to be my Last Will and
Testament, in English, the language which I am well conversant. And I
hereby declare that all my paraphernal properties which consist of the
following:

1) 1.05 hectare of corn and coconut land located

in Simbuawan
2) 1.5 hectare of land in Nailon planted with Gemelina
and Mahogany trees
3) 5,000 square meters land in Gairan planted with
Citrus trees
4) one (1) unit Suzuki van
5) one (1) unit Honda motorcycle green in color
6) one (1) unit Honda motorcycle red in color
7) assorted jewelries

shall be distributed to my love ones in this manner:

To my beloved father, Ivan, I hereby give and bequeath the 1.05 corn
and coconut land located in Simbuawan;

To my precious cousins, Sean, Ezek and Maki, I hereby give and

bequeath in equal shares the 1.5 hectare property in Nailon planted with
Gemelina and Mahogany trees; to Kuya Sean, the Suzuki van; to Kuya Ezek,
the Honda green motorcycle; and to Maki, the Honda red motorcycle;

To my dear brother, Roy, the 5,000 square meters property in Gairan

planted with Citrus trees; and

To my dear sister, Babie, all my jewelries;

That should I finally rest in eternal peace, it is my wish and desire to

be buried according to the rites of the Roman Catholic Church and
interred at our family mausoleum in New Corazon Cemetery, Bogo City,
Cebu;

That I hereby direct that the executor and administrator of this Last
Will and Testament or his substitute shall be excused from posting any
bond;

That I hereby revoke, set aside and annul any other will or
testamentary dispositions I have made, executed, signed or published.
 IN WITNESS WHEREOF, I have hereunto affixed my signature this 28th
day of July, 2016, in Bogo City, Cebu, Philippines.

MARJORIE C ECHAVEZ
(Testator)

ATTESTATION CLAUSE

We, the undersigned attesting witnesses, do hereby affirm that the

foregoing is the Last Will and Testament of MARJORIE C ECHAVEZ and we
certify that the testator executed this document while of sound mind and
memory. That the testator signed this document in our presence, at the
bottom of the last page and on the left hand margin of each and every page,
and we, in turn, at the testator’s behest have witnessed and signed the
same in every page thereof, on the left margin in the presence of the
testator and of the notary public, this 28th day of July, 2016 at Bogo City,
Cebu, Philippines.

ARLENE DIAZ LIM JOCELYN FERNAN BOLAMBAO

(Witness) (Witness)
P. Rodriguez St., Bogo City, Cebu Nailon, Bogo City, Cebu

DELIA YTANG SUICO

(Witness)
Gairan, Bogo City, Cebu

JOINT ACKNOWLEDGMENT

BEFORE ME, Notary Public for and in the province of Cebu, personally
appeared:

The testator Monalisa MARJORIE C ECHAVEZ, with CTC No. 1234567B

issued at Bogo City, Cebu on February 2, 2016;

Witness Arlene Diaz Lim, with CTC No. 1234568B issued at Bogo City,
Cebu on January 14, 2016;

Witness Jocelyn F. Bolambao, with CTC No. 1234569 issued at Bogo

City, Cebu on January 10, 2016;

Witness Delia Y. Suico, with CTC No. 1234570 issued at Bogo City,
Cebu February 15, 2016;

all known to me to be the same persons who executed the foregoing Will,
the first as testator and the last three as instrumental witnesses, and they
respectively acknowledged to me that the same as their own free act and
deed.
 This Last Will and Testament consists of three (3) pages, including the
page on which this acknowledgment is written, and has been signed on the
left margin of each and every page thereof by the testator and his
witnesses, and sealed with my notarial seal.

IN WITNESS WHEREOF, I have hereunto set my hand the day, year,

and place above written.

ATTY. CESAR M. MADEJA

Notary Public
Until December 2017
Office Address: Cogon, Bogo City, Cebu
Roll No. 59950
PTR 0647234, 12.08.15, Bogo City, Cebu
IBP 0992242, 10.30.15, Cebu
MCLE Compliance No. IV-0011872
MCLE Compliance No. V-0008202

Doc. No._____;
Page No._____;
Book No. ____ ;
Series of 2016.
10.) Petition for Receivership

REPUBLIC OF THE PHILIPPINES)

CITY OF MANILA S.S.

x----------------------------------------------------------------------------------------------------------------x

AFFIDAVIT

A, of legal age, married and a resident of the City of Manila, Philippines, after
having duly sworn in accordance with law, hereby deposes and says:

That he is the Plaintiff in the above titled case and that he has read the
foregoing complaint and that the facts therein stated are true and correct;

That he is the owner of the estate as pro-indiviso owner of the same with the
defendant;

That the defendant is in actual physical possession of the property in litigation

and as such, he is in control of the produce of the said property pending litigation;

That the produce or income from said property are in danger of being lost,
removed or materially injured unless a receiver be appointed to guard and preserve the
same, and the defendant is not only hostile to the plaintiff but also shows his demands
to exclude said plaintiff from all the products or proceeds coming from the said property;

That the defendant is hopelessly insolvent for he is heavily indebted to various

persons;

That he is willing and ready to file a bond in the amount which this Honorable
Court may fix in favor of the defendant against whom this receivership is presented to
the effect that he, the plaintiff will pay to the said defendant all damages which he will
sustain by reason of theappointment of receiver in case the plaintiff shall have procured
such appointment without sufficient cause, and such other bonds which this Honorable
Court may require him to file hereafter, as security for such damages.

FURTHER AFFIANT SAYETH NAUGHT.

______________________

(Affiant)
 11.) Republic of the Philippines

National Capital Judicial Region

Regional Trial Court

Branch 23, Manila

Profood Manufacturing Corporation,

Plaintiff,

S. P. No. 56772

For: Voluntary Dissolution of Stock Corporation

x-----------------------------------------------------------------------------------------------------x

PETITION FOR VOLUNTARY DISSOLUTION OF STOCK CORPORATION

Profood Manufacturing Corporation through the undersigned borad of directors.

And unto this Honorable Court, respectfully states:

1. That the said corporation has been duly organized and existing under the laws of the
Philippines, having its principal place of business at Maguikay , Mandaue City, Cebu;

2. That the authorized capital stock of said corporation is ONE MILLION PESOS (P
1,000,000) Philippine currency, divided into 10,000 shares of per value of ONE
HUNDRED PESOS (P 100) per share;

3. That in a meeting of the stockholders of the corporation held in Maguikay, Mandaue

City, Cebu on March 7, 2017, the dissolution of the said corporation was resolved upon
by the affirmative vote of the stockholders holding or representing at least two-thirds
(2/3) of all shares of stock issued or subscribed;

4. That the following are the present claims and demands against the corporation:

National Steel Corporation – P500,00 Promissory Note

Boysen Paint Corporation- P900,000 Promissory Notes

Profood Employees Union – P 100,000 13th Month Pay

5. That the Corporation has present assets to the value of One Hundred Thousand
Pesos (P100,000) over and above its debts and liabilities.

WHEREFORE, it is respectfully prayed that upon prior publication of notice as required

by law and due hearing on this petition, this Honorable Court adjudje and declare the
above-mentioned corporation dissolved, and that the board of directors of said
corporation be designated liquidator to take charge of winding up the affairs of the
corporation.

Mandaue City, April7, 2017.

Profood Manufacturing Corporation

By

Juan dela Cruz

President

Manny Pacman

Corporate Secretary

Nora Peet

Director

Mercedes Benz

Director

Maria Akala

Director
 12.) Republic of the Philippines
National Capital Judicial Region
REGIONAL TRIAL COURT
Branch _____
Makati City
IN THE MATTER OF RECONSTITUTION
OF ORIGINAL COPY OF TRANSFER
CERTIFICATE OF TITLE NO. T-123456

Spec. Proc. No. ____

ALA TITULO,
Petitioner.
x----------------------------------------------x
PETITION FOR RECONSTITUTION
OF TRANSFER CERTIFICATE OF TITLE

COMES NOW, petitioner ALA TITULO through counsel, unto this Honorable
Court, respectfully alleges:

1. That petitioner is of legal age, married, Filipino citizen and residing at 222 Teresa
Street, Valenzuela, Makati City; that respondent REGIE STER is the Register of
Deeds of Makati City where he may be served with summons and other court
processes;

2. That petitioner is the registered owner of a parcel of land located at

4522 Acacia Street, Pembo, Makati City and covered by Transfer Certificate of
Title No. T-123456, Register of Deeds of Makati City, free of any encumbrances;

3. That on April 5, 2013 the office of the register of Deeds of Makati City was burned
and all the Torrens Titles in said office including T.C.T. No. T-123456 were burned;

4. That said transfer certificate of title was never mortgaged or sold to anyone.

WHEREFORE, it is respectfully prayed that the Register of Deeds of Makati City

issue a reconstituted original certificate of title based on the owner’s
duplicate certificate of title hereto attached in the name of herein petitioner.
Other just and equitable reliefs are likewise prayed for.

Respectfully submitted.
15 August 2013
City of Makati.

ATTY. VX YZ
Counsel for the Petitioner
 13.) Republic of the Philippines
REGIONAL TRIAL COURT
5th Judicial Region
Branch _23
Legazpi City

MR. X,
Petitioner,
CIVIL CASE NO. 123
-versus- For: Sum of Money with prayer
for the issuance of writ of preliminary
attachment
MR. Y,
Respondent

x----------------------------------- - - ------------------------- -----------------------------------------------x

COMPLAINT COMES NOW , the plaintiff, through the undersigned counsel, and unto this
honorable court, most respectfully avers:

1. That plaintiff is of legal age, Filipino Citizen, with postal address at#1136-A A. Maceda
Street, Legazpi City;

2. That Defendant Y, is of legal age, Filipino Citizen, with postal address at No. 24
Evangelista Street, Santolan, Pasig City, where he may be served with summons and
other processes by this Honorable Court;

3. That sometime in January 2005, defendant obtained several construction materials

from the plaintiff in the total amount of P5,000,000.00 as evidenced by the Purchase
Order, Delivery receipt which are hereto attached as Annexes “A” – “D” hereof;

4. That as payment of the said construction materials, defendant issued several postdated
checks and represented that the same will be covered by sufficient funds on its maturity
dates. Copies of the checks are hereto attached as Annexes “E” – “G” hereof;

5. That on its maturity date, the said checks was dishonored by the drawee banks upon
presentment for payment for reason ACCOUNT CLOSED, as evidenced by the notice of
dishonor issued by the bank which is hereto attached as Annex “H” hereof;

6. That despite repeated demands orally and in writing, defendants refused and
continously refusing to make good the said bounced checks or pay the construction
materials to the damage and prejudice of herein plaintiff. Copy of the demand letter is hereto
attached as Annex “I” hereof;

7. That as a result of the unwarranted and unjustifiable refusal of the defendants to pay the
said construction materials or make good said checks, plaintiff suffered sleepless nights,
serious anxiety in which he should be awarded the amount of P100,000.00 as moral
damages, and to set an example to the public, plaintiff should be awarded exemplary
damages on the amount of P100,000.00;
ALLEGATIONS IN SUPPORT FOR THE ISSUANCE OF WRIT OFPRELIMINARY
ATTACHMENT

Plaintiff re-pleads all the foregoing averments by way of reference and in so far as they are
relevant and material to its application for the issuance of a writ of Preliminary Attachment;

8. A sufficient cause of action exists against the defendant;

9. The defendant are guilty of fraud in contracting and in the performance of their obligation as
manifested by defendant, Mr. Y, who represented himself as a credible businessman and
financially capable of paying his obligation, when in truth and in fact, he is not, and the
fraudulent scheme becoming more evident when despite demands, he failed and refused to
settle without justifiable ground his just and demandable obligation;

10. There is no sufficient security for the claim sought to be enforced by the present action;

11. The amount due to the plaintiff in the above-entitled case is P5,000,000.00, excluding legal
fees and other charges as of to date for which amount, an order of attachment is being sought
above all legal counterclaims against the Defendants;

12. Plaintiff is ready and willing to give a bond to be fixed by this Honorable Court, executed to
the defendant, to answer for all costs which may be adjudged to the latter, and all damages
which defendant may sustain by reason of the attachment prayed for, if the court shall finally
adjudge that Plaintiff is not entitled thereto; In support of the foregoing allegations, the Plaintiff
has attached hereto his affidavit.

WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable Court
that, after hearing, judgment be rendered as follows:

1. An order of attachment be immediately issued by this Honorable Court, requiring the

sheriff to attach properties of the Defendants which are not exempt from execution or so
much thereof as may be sufficient to satisfy Plaintiff’s demand which is in the total amount of
P5,000,000.00; and after hearing;

2. Judgment be rendered ordering the defendant to pay plaintiff the amount of

P5,000,000.00, representing unpaid account excluding legal fees and other charges as
of to date;

3. Ordering the defendants to pay the plaintiff the amount of P100,000.00 as moral
damages, and P100,000.00 as exemplarydamages
4. P50,000.00 by way of Attorney’s fees and P2,500.00 as per appearance fee and costs of suit;

5. Ordering the defendants to pay the costs of suit.

6. Other reliefs which are just and equitable are likewise prayed for.

Legazpi City, Philippines, March 31, 2005.

ABOGADO LAW OFFICE

Counsel for the Petitioner
Rasi Bldg., Legazpi City

By :ABOGADO A. ABOGADO
IBP No. 1231231/2-5-05
PTRNo.123/10-2203/
Leg.Roll No. 123123
 14.) REPUBLIC OF THE PHILIPPINES

FIRST JUDICAL REGION

REGIONAL TRIAL COURT OF ILOCOS NORTE

LAOAG CITY BRANCH 2

IN THE MATTER OF PETITION FOR NATURALIZATION OF

SERGEI D. IVANOVICH

Petitioner,

SP. PROC NO. 123

X-------------------------------------------------------------------------------------------------------------------------X

PETITION FOR NATURALIZATION

PETITIONER,and unto this Honorable Court, |respectfully avers:

1. That the petitioner’s full name is SERGIE DRAGUNOV IVANOVICH, of legal

Age, the son of Jean Jacques Ivanovich, his father and Elizabeth Dragunov Ivanovich,
His mother; born in Laoag City, Ilocos Norte, Philippines in July 7, 1970.
2. That his present place of residence Bryg.55-A, Laoag City, Ilocos Norte;
3. That is former place of residence were Zenelograd, Moscow, Russia;
4. That he was born in Laoag City, Ilocos Norte;
5. That he is married to Maria Mahinhin Ivanovich; and is a father of 2(two) children;
6. That his wife Maria Mahinhin is 41 years old; having been born on July 28, 1973;
7. That the names, sex, date and place of birth of his children are as follows;

Name of Children Name of School

Vladimir Mahinhin Ivanovich Ilocos Norte College of
Male, July 24, 1993 Arts and Trades Laoag
Laoag City, Ilocos Norte City, Ilocos Norte

Natalia Poklonskaya Mahinhin Ivanovich Shamrock Elementary School

Female, January 1, 1996 Laoag City, Ilocos Norte
Laoag City, Ilocos Norte

8. That he arrived in the Philippines from Moscow, Russia on August 26,1980

9. That he has resided continuously in the Philippines for not less than ten(10)
Years as permanent resident immediately preceding the date if this petition;
10. That he speaks and writes English and Tagalog;
11. That his trade of profession is a Restaurant Chef in which he has been engaged since
January 4, 1989; and from which he derives an annual average income of one million
pesos (P1,000,000,00);
12. That he is the owner of a real estate, Situated in Brgy. 55-B Barit Laoag City, Ilocos
Norte, worth not less than five thousand pesos (P5,000,00)
13. That he has enrolled his minor children of school age in the following schools recognized
by the government and civics are thought as part of the school curriculum.

Said enrolment having lasted during the entire period of his required residence in the
Philippines;
 Name of Children Name of School
Vladimir Mahinhin Ivanovich ShamrockElementary School
Male, July 24, 1993 Laoag City Ilocos Norte; and
Ilocos Norte College of Arts
and Trades Laoag City, Ilocos
Norte

Natalia Poklonskaya Mahinhin Ivanovich Shamrock Elementary School

Female, January 1, 1996 Laoag City, Ilocos Norte
Laoag City, Ilocos Norte

14. That he believes in the principle underlying in the Philippine Constitution; is of good
moral character and had conducted himself in a proper and irreproachable manner
during the entire period of his residence in the Philippines in his relations with the
constituted government as well as with the community in which he lives; has mingled
socially with the Filipinos, and has evinced a genuine desire to learn and embrace the
customs, traditions, and ideas of the Filipinos;

15. That he is not opposed to organized government or affiliated with any association or
group of persons who uphold and teach doctrines opposing all organized government;
that he does not defend or teach the necessity or propriety of violence, personal assault,
or assassination for the success and predominance of their ideas; that he is not a
polygamist or a believer in polygamy or in the practice of polygamy, that he has never
been convicted of any crime involving moral turpitude, that he is not suffering from
mental alienation or incurable contagious disease’ and that he is not a citizen or subject
of a nation at war in the Philippines;

16. That he has complied with the requirements of the Naturalization Law(CA No. 473)
regarding the filing with the Office of the Solicitor-General of his bona fide intention to
become citizen of the Philippines;
17. That it is his intention in good faith to become a citizen of the Philippines and to
renounce absolutely and forever all allegiance and fidelity to any foreign state or
sovereignty; if this petition is granted, and particularly to Sergei Dragunov Ivanovich of
which at this time he is a citizen or subject that he will reside continuously in the
Philippines from date of the filing of this petition up to the time of his admission to
Philippine citizenship;
18. That he has a bit heretofore made petition for any citizenship to any court;
19. That Maki Barrera of legal age residing at Brgy.7 Sucsuquen Piddig , Ilocos Norte and
John Altarejos Mitra of legal age, residing at Brgy.2 San Nicolas, Ilocos Norte, who are
Filipino citizens, will appear and testify as witnesses at the hearing of this petition;
20. That attached hereto and made integral parts of this petition are; ( a ) Affidavit of
witnesses ( Annex”A”); and ( b ) a signed copy of petitioners declaration of intention to
become a citizen of the Philippines (Annex”B”).

WHEREFORE,your petitioner prays that he be admitted a citizen of the Philippines.

Dated at this 23rd day of July, 2014 in Laoag City, Philippines.

SERGEI D. IVANOVICH
Petirioner
Brgy.55-B Barit, Laoag City, Ilocos Norte
 VERIFICATION AND CERTIFICATION

I. SERGEI D. IVANOVICH, of legal age, a citizen of Russia and a resident of Brgy: 55-
A Barit City, do hereby depose and say:

That I am the petitioner in the above captioned petition for Naturalization; and

That I have read the allegations therein and the same are true and correct to the best
of my knowledge and belief.

And I further certify that:

I have neither commenced any other action involving the same issues in the
Supreme Court, Court of Appeals or any other court, tribunal or agency: and

Should I hereinafter learn that the similar action or proceeding has been filed or its
pending therein. I hereby undertake to notify this Honorable Court within five (5) days
from said notice of such similar and/or pending action or proceeding.

IN WITNESS WHEROF, I hereunto affixed my signature below on this 25th July 2014
at Laoag City, Philippines.

SERGEI D. IVANOVICH
CTC #0123456
Issued at: Laoag City
Issued on: July 25, 2014

REPUBLIC OF THE PHILIPPINES

PROVINCE OF ILOCOS NORTE

CITY OF LAOAG

ACKNOWLEDGEMENT

BEFORE ME, a Notary Public in the City of Laoag, Province of Ilocos Norte, Philippines,
personally appeared SERGEI DRAGUNOV IVANOVICH for his execution of a PETITION FOR
NATURALIZATION with a CTC numbered 79134679.

IN WITNESS WHEREOF, I have hereunto set my hand and affixed my notarial seal on this 25th
day of July, 2014 in Laoag City, Philippines.
 15.) Republic of the Philippines
Regional Trial Court
City of Cebu
Branch 23

In the matter of escheat proceedings

of the estate of the deceased
JUAN DELA CRUZ
Spec Proc No. 9765
For: Escheat
x-----------------------------------------------------------------------------------x
PETITION FOR ESCHEAT
The City Prosecutor of Cebu City and in behalf of the City of Cebu,
unto this Honorable Court, respectfully avers that:
1. Juan dela Cruz, a Filipino citizen, and resident of the City of Cebu,
Province of Cebu, died intestate in the said City on March 2, 2016.
2. At the time of his death, he left real property in the City of Cebu, Province
of Cebu to wit:
A parcel of land with an area of 893, 00 square meters, located at
Barangay Lahug, Cebu City covered by Transfer Certificate of Title No.
312445.
3. He left no heir/s or persons who by law are entitles to inherit his real
property.
WHEREFORE, it is respectfully prayed that, upon due notice and
hearing, and after the payment of his just debts and charges, the estate of
the deceased Juan dela Cruz be declared escheated in favor of the
Government in accordance with law.

Cebu City, this 23rd day of December 2016.

Marjorie C Echavez
City Prosecutor
 16.) Republic of the Philippines

Regional Trial Court

Cebu City

Mario Makiling , complainant

vs.

Maria Makiling, accused Case No. IV- 1909-09

For: Adultery

COMPLAINT

The undersigned, Mario Makiling, accuses Maria Makiling of the crime of adultery,
committed as follows, to wit:

That on or about March 2016 , at about 3 p.m. in the City of Cebu, Province of Cebu
and within the jurisdiction of this Honorable Court, the said accusedMariaMakiling did
then and there voluntarily, unlawfully, and feloniously had sexual intercourse with her
co-accused Manuel Maldito Jr., who is not her husband, and the latter knowing her to
be married to Mario Makiling, voluntarily, unlawfully, and feloniously had carnal
knowledge with her.

Contrary to law.

Cebu City, Philippines, 16th day of July 2016.

Mario Makiling

COMPLAINANT

REPUBLIC OF THE PHILIPPINES)

CITY OF CEBU) SS.

ACKNOWLEDGMENT

BEFORE ME, a Notary Public for and in the City of Cebu, personally appeared with
Community Tax Certificate No. 120-091 issued on May 25, 2016 at Cebu City and Tax
Identification No. (T.I.N.) 0291-898 , known to me and to me known to be the same
person who executed the foregoing instrument which he acknowledged to me as his
free and voluntary act and deed, consisting of only 2 pages, including this page in which
this Acknowledgement is written, duly signed by him and his instrumental witnesses on
each and every page hereof.

WITNESS MY HAND AND SEAL this 16TH day of July 2016 at Cebu City, Philippines.

Marjorie C. Echavez

NOTARY PUBLIC

IBP No. 1290-109-1

MCLE No. 62710

 PTR No. 125

Roll of Attorney No.

09288

Doc. No.I-09

Page No.4

Book No. _52

Series of 2016

IN WITNESS WHEREOF, I have hereunto affirmed my signature the 16th day of

July, 2016, in the City of Cebu, Philippines.

Mario Makiling

Affiant

JURAT

SUBSCRIBED AND SWORN before me this 16th day of July, 2016, affian exhibiting to
me his Philippine Passport No.34927 issued on July 29,2015 at Cebu City.

Marjorie C. Echavez

NOTARY PUBLIC

Doc. No. I-09 IBP No. 12970-109-1

Page No.4 MCLE No. 62710
Book No. _52 PTR No. 125
Series of 2016 Roll of Attorney No. 09288
 17.Republic of the Philippines
Municipal Trial Court
Branch 5
Baguio City

Mr. Uzumaki Naruto, plaintiff Civil Case No. 2

Accompanied by his Attorney –in – fact, For:Unlawful Detainer
Atty. Poging Attorney

-versus-

Mr. Uchiha Sasuke, Defendant

x---------------------------------------------------------------------------------------------------------------x

COMPLAINT

COMES NOW, the plaintiff together with the undersigned counsel to this most
honorable court, MOST RESPECTFULLY STATES THAT;

1. The Plaintiff is of legal age, married and a resident of Puguis, La Trinidad Benguet. The
Defendant is likewise of legal age, married and temporary residing at Petersville Subdivision,
Baguio City.
2. The Plaintiff is the owner of the two-storey house unit located at the Petersville Subdivision,
Baguio City, and having the residential address of PV 123 as evidenced by pertinent documents
like tax declaration and deed of sale. ( EXHIBIT “A” )
3. The Defendant is the lessee of the house unit that is owned by the Plaintiff as evidenced by the
written contract of lease that both parties signed. (Exhibit “B”)
4. The Plaintiff and the Defendant came up with a written agreement of Lease on June 26, 2007,
which they both agreed upon and was duly signed by the two parties as shown in their contract of
lease. (Exhibit “B”)
5. Item No. 16 of the contract which the defendant signed expressly provides that he will only be
occupying the property for one (1) year, after which, he will vacate the house when that term
expires. (Exhibit “B”)
6. The contract also provides that the defendant should also take care of the property and its
premises” with the utmost diligence”.
7. On June 28, 2008, the plaintiff, after returning from Japan, was surprised to discover that the
defendant did not vacate the property as he expected. Worse, he installed a “sari-sari store” in the
original building structure of the house unit.
8. The plaintiff confronted the defendant about it but the defendant claimed that it was a “DEED
OF SALE” which they signed and not a “CONTRACT OF LEASE” and therefore, the defendant
is the new owner of the house unit.
9. On August 20, 2008, after continuous demands, the defendant constantly refuses to vacate the
house unit and even invited relatives to stay with him.
10. The defendant willfully and maliciously violated the agreement which they mutually agreed
upon, and which the defendant signed.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court that
judgement be rendered in favor of the plaintiff and that after judgement;
a. The defendant shall vacate the house unit owned by the plaintiff.
b. The defendant shall be ordered to pay P 120, 000 for the Attorney’s Fees.

Such other reliefs and remedies under the premises are likewise prayed for.

Baguio City, Philippines, this 28th day of September 2008.

Poging Attorney
Counsel for the Plaintiff
PTR No. 18909595:1-04-07:B.C.
IBP No, 693095:1-04-07:B.C.
Roll No. 42481:5-10-97: Manila
Rm. 4 2/F Baguio Boating Center
180 Burnham Lake, Baguio City

VERIFICATION AND CERTIFICATION

I, Mr. Uzumaki Naruto, of Legal age, married, Filipino Citizen and a resident of Puguis, La
Trinidad Benguet, after being sworn according to law, hereby depose and state that;

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein are true and correct of my
personal knowledge and/or on the basis of copies of documents and records in my
possession;

4. I have not commenced any other action or proceeding involving the same issues in the
Supreme Court, the Court of Appeals, or any other tribunal or agency;

5. To the best of my knowledge and belief, no such action or proceeding is pending in the
Supreme Court, the Court of Appeals, or any other tribunal or agency;

6. If I should thereafter learn that a similar action or proceeding has been filed or is pending
before the Supreme Court, the Court of Appeals, or any other tribunal or agency, I undertake
to report that fact within five (5) days therefrom to this Honorable Court.

Uzumaki Naruto
Complainant

In witness thereof, I, Mr. Poging Attorney, counsel of the plaintiff, have herunto set my hand this
29th of September at Baguio City.

Poging Attorney
Counsel for the Plaintiff
PTR No. 18909595:1-04-07:B.C.
IBP No, 693095:1-04-07:B.C.
Roll No. 42481:5-10-97: Manila
Rm. 4 2/F Baguio Boating Center
180 Burnham Lake, Baguio City
 18. REPUBLIC OF THE PHILIPPINES

7TH JUDICIAL REGION

MUNICIPAL TRIAL COURT IN CITIES

CITY OF BOGO

DAKIT, BOGO CITY, CEBU

PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 234

Plaintiff,

FOR: CONCUBINAGE

- Versus –

PETRON GASUL and JENNIFER

RUBY,

Accused.

X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - X

INFORMATION

The undersigned accuses PETRON GASUL and JENNIFER RUBY, of the crime
of CONCUBINAGE, committed as follows:

That on the 29oth day of June 2011 to March 2015, at Cantecson, Gairan, City
of Bogo, Province of Cebu, Philippines and within the jurisdiction of this Honorable
Court, the above-named accused, being lawfully married to the complainant Vilma
Gasul, without the said marriage being legally dissolved or the complainant having
been declared presumptively dead by means of a final judgment in a proper
proceedings, did then and there willfully, unlawfully and feloniously cohabit with
accused Jennifer Ruby, knowing fully well that Petron Gasul is legally married to
Vilma Gasul.

CONTRARY TO LAW.

Bogo City, Cebu, Philippines, September 20, 2016.

CESAR M. SALAD

Deputy City Prosecutor

MCLE Compliance No. IV-0022819

7/04/16
Witnesses:

1. Vilma Gasul, Lawaan, New Washington, Antique

2. Antonio Gasul, Sitio Cantecson, Gairan, Bogo City, Cebu
3. Winda Bartolome, Sitio Cantecson, Gairan, Bogo City, Cebu
4. Many others.

BAIL RECOMMENDED: P10,000.00

ADDRESS OF THE ACCUSED: Petron Gasul, Cantecson, Gairan, Bogo City, Cebu

Jennifer Ruby, A. Padre Pedro St., Bogo City, Cebu

CERTIFICATION

I hereby certify that I have conducted preliminary investigation by furnishing

a copy of the complaint together with the supporting documents and requiring them
to submit their counter-affidavits. On the basis of the evidence on records, the
undersigned finds prima facie case to hold respondents for trial in court.

SUBSCRIBED AND SWORN to before me this 20th day of September, 2016, at

Bogo City, Cebu, Philippines.

APPROVED:

ABBY A. MANUEL IRIS R. SHOVEL

City Prosecutor Prosecutor II

MCLE Compliance No. V-6504 OCP, Bogo City

dated 3/03/15
 19. REPUBLIC OF THE PHILIPPINES
SEVENTH JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 61
CITY OF BOGO
DAKIT, BOGO CITY, CEBU

REPUBLIC OF THE PHILIPPINES, CIVIL CASE NO. B-0101

Represented by City Mayor Jun
Polistico II, FOR: EXPROPRIATION
Plaintiff, OF REAL PROPERTY

- Versus –

CATALINO PUSGAY,
Defendant.
X---------------------------------- -----------X

COMPLAINT

COMES NOW the plaintiff through the undersigned counsel, and unto

this Honorable Court, respectfully avers:

1. That the plaintiff is the City Mayor of Bogo City, Cebu;

2. That the defendant is of legal age and a resident of Barangay San

Vicente, Bogo City, Cebu;

3. That the plaintiff, by virtue of City Ordinance No. 2016-45 has the
power to exercise the right of eminent domain and to take private
property for public use;

4. That the following described property, together with all the

improvements thereon, is a private property, owned by the
defendant, to wit:

“A parcel of land known as Cadastral Lot No. 2018 located in

Barangay San Vicente, Bogo City, Cebu declared under
Transfer Certificate of Title No. 12345 in the name of Catalino
Pusgay containing an area of 500 square meters, more or
less.”

5. That the above-described property is herein sought to be

condemned in order to convert the same to be the location of the
city health center II of the City of Bogo which is avowedly a public
purpose;
6. That the plaintiff hereby tenders and offers to deposit such sum as
may provisionally be ascertained and fixed by this Honorable Court
so that, pending these proceedings, the plaintiff may immediately
be placed in possession of the property involved.

WHEREFORE, it is respectfully prayed:

That , after due notice and hearing, an order of condemnation be

entered, declaring that the plaintiff has a lawful right to take the
property herein sought to be condemned for the public use
hereinabove specified, upon payment of just compensation to be
determined as of the date of the filing of this complaint;

That upon the entry of the order of condemnation, three

competent and disinterested persons be appointed as commissioners
to ascertain and report to the court the just compensation for the
property condemned;

That, pending these proceedings, the plaintiff be placed in

possession of the property involved upon deposit with the City
Treasurer of such sum as may provisionally be ascertained and fixed
by this Court, subject to the orders and final disposition of the same.

Bogo City, Cebu, Philippines, February 28, 2017.

ATTY. MIKEIL CHRISTIAN

Counsel for Plaintiff
 20. REPUBLIC OF THE PHILIPPINES
SEVENTH JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 61
CITY OF BOGO
DAKIT, BOGO CITY, CEBU

IN RE: IN THE MATTER OF THE

GUARDIANSHIP OF THE MINOR
LOVE VALENTINE GO,
SP. PROC. NO. 0143
RUDOLF VALENTINE,
Petitioner.
X--------------------- ----------- ------------ X

PETITION

COMES NOW the undersigned counsel in behalf of the petitioner, and

unto this Honorable Court, respectfully avers:

1. That the petitioner who is of age, single, and a resident of Pandan

Heights, Bogo City, Cebu, Philippines, is the uncle of the minor LOVE
VALENTINE;

2. That the said minor LOVE VALENTINE, who at the time of the filing of
this petition, is only eight (8) years of age, is a resident of Pandan
Heights, Bogo City, Cebu, Philippines;

3. That the said minor is seized of real and personal property located in
Cogon, Bogo City, Cebu, Philippines, of the probable value of Two
Million and Five Hundred Pesos (P2,500,000.00);

4. That due to the minority of said LOVE VALENTINE it is necessary and

convenient that a guardian of his person and property be appointed;

5. That the names, ages, and residences of the relatives of the said
minor, and the person having her in his care, are as follows, to wit:

MARIA VALENTINE, 70 years of age, grandmother, Pandan Heights,

Bogo City, Cebu
RUDOLF VALENTINE, 45 years old, uncle, Pandan Heights, Bogo
City, Cebu and the person having her care
ROMEO GO, 50 years old, uncle, Guadalupe, Cebu City
MARINA GO ARRIOLA, 48, aunt, Labangon, Cebu City

6. That as above stated, RUDOLF VALENTINE is the person having the

said minor in his care, and that he possess all qualifications to whom
letters of guardianship should issue.

WHEREFORE, it is respectfully prayed that, upon due notice and

hearing, and upon the giving of such bond as this Honorable Court may
direct, the said RUDOLF VALENTINE be appointed guardian of the person and
estate of the minor LOVE VALENTINE GO.

Bogo City, Cebu, Philippines, March 1, 2017.

ATTY. MIKEIL CHRISTIAN

Counsel for Petitioner

VERIFICATION

REPUBLIC OF THE PHILIPPINES)

CITY OF BOGO )SS
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RUDOLF VALENTINE, after being duly sworn in accordance with law,

deposes and says:

That he is the petitioner in the above-entitled case

That he has caused the above petition to be prepared and has read
and knows the contents thereof

That the allegations therein are true of his own knowledge

RUDOLF VALENTINE
Affiant
 21.REPUBLIC OF THE PHILIPPINES
SEVENTH JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 61
CITY OF BOGO
DAKIT, BOGO CITY, CEBU

IN RE: PETITION FOR QUO WARRANTO

JUAN DELA CRUZ,

Petitioner,
ELECTION CASE NO. 001
- Versus –

PEDRO MARCELO,
Respondent.
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PETITION

COMES NOW the petitioner, through the undersigned counsel, and

unto this Honorable Court, respectfully alleges:

1. The petitioner is a registered candidate for the office of City Mayor,

City of Bogo, Cebu, Philippines, within the jurisdiction of this
Honorable Court;

2. That the respondent, PEDRO MARCELO, on or about May 8, 2016

was proclaimed City Mayor-elect of said city;

3. That the respondent, on or about May 18, 2016 assumed the office
of such City Mayor;

4. That said respondent, PEDRO MARCELO, is ineligible to hold office

of City Mayor on the ground of having spent in his election
campaign an amount in excess of that allowed by Election Code.

WHEREFORE, it is respectfully prayed that after due hearing, a writ of

QUO WARRANTO be issued ousting the respondent, PEDRO MARCELO from
the office of City Mayor of Bogo City and that the said office be declared
vacant.

Bogo City, Cebu, Philippines, May 20, 2016.

ATTY. MIKEIL CHRISTIAN

Counsel for Petitioner