Form 21: Unlawful Detainer

REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT
City of Manila
Branch 1

KRUL ACOSTA,
Plaintiff,
CIVIL CASE No. 98765
-versus- FOR: Unlawful Detainer

MEGAN VITUG,
Defendant.

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

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable Court, most
respectfully avers:

That the plaintiff, KRUL ACOSTA, is of legal age, Filipino citizen, single, with residence and postal address at
123 Benitez Street, Manila;
That the defendant, MEGAN VITUG, is of legal age, Filipino citizen, single, with residence and postal address
at 456 Modesto Street, Manila, where they may be served with summons and other court processes;
The plaintiff is the owner of a land over which an apartment had been constructed located 654 San Pedro
Street, Manila;
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;
The defendant failed to pay the agreed rental for several months starting February 19, 2012 up to the
present;
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”;
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;
By reason of failure of the defendant to vacate the premises and to pay the unpaid rentals, the plaintiff was
compelled to file this complaint engaging the services of counsel in the amount of P10,000.00.
 WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable Court that, after
hearing, judgment be rendered ordering the defendant:

To vacate the subject premises;

To pay the amount of P5,000.00 per month as compensation for the reasonable use of the subject premises
until they finally vacate the said premises;
To pay the plaintiff the cost of the suit.

City of Manila, September 24, 2012.

REYES, TOLENTINO AND CRUZ LAW OFFICE

Counsel for the Plaintiff
Unit 123, Victoria Tower I
Taft Avenue, Manila

By:
Louise Reyes
Roll of Attorney No. 98765
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )

City of Manila ) S.S.

I, KRUL ACOSTA, of legal age, Filipino citizen, single and resident of 123 Benitez Street, Manila, after
having been duly sworn to in accord Nance with law do hereby depose and say:

That I am the plaintiff in the above-entitled case;

That I have caused the preparation of the foregoing complaint and have read the allegations contained
therein;
The allegations in the said complaint are true and correct of my own knowledge and authentic records;
I hereby certify that I have not commenced any other action or proceeding involving the same issues in any
court, tribunal or quasi-judicial agency and, to the best of my knowledge, no such other action or claim is
pending therein;
That if I should learn thereafter that a similar action or proceeding has been filed or is pending, I hereby
undertake to report that fact within five (5) days therefrom to the court or agency where the original pleading
and sworn certification contemplated herein have been filed;
 I executed this verification/certification to attest to the truth of the foregoing facts and to comply with the
provisions of Adm. Circular No. 04-94 of the Honorable Supreme Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 24th of September 2012, in the City of
Manila.

KRUL ACOSTA

SUBSCRIBED AND SWORN to before me this _______ day of September, 2012, in the City of Manila,
affiant exhibiting to me his Driver’s License No. 12345 issued by the Land Transportation Office on April 8, 2012
at the City of Manila.

ATTY. NO CASE
Notary Public
My Commission Expires Dec. 31, 2012
Roll of Attorney No. 34567
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila

Doc. No. ________

Page No. _______
Book No. _______
Series of 2012.
Form 22: Petition for Annulment of Marriage

REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
___ Judicial Region
Regional Trial Court
Branch ________
Pasig City, Metro Manila

JOHN C. FABON
Petitioner,
-versus- CIVIL CASE NO. _____
JUDICIAL DECLARATION OF NULLITY OF MARRIAGE
MARILEN MORAN-FABON
Respondent.
x—————————————————————x

AFFIDAVIT

THE PARTIES
Petitioner, John C. Fabon (John for brevity) is of legal age, Filipino and presently residing at Blk-20, Lot-5, Acacia
Homes Pasig City;

Respondent, Marilen Moran-Fabon (Len for brevity) is likewise of legal age, Filipino and is last known by the
Petitioner to be residing at Block11, Lot 87, ACM Woods Homes, Pasig City, where she may be served by
notices, orders and processes of the Honorable Court.

NATURE OF THE PETITION

In this present Petition, the Petitioner prays of this Honorable Court to declare as null and void her marriage to
Respondent on the ground of the latter’s psychological incapacity.

The following pertinent and relevant Family Code provisions are the bases in the treatise of this Petition:

Art. 36. A marriage contracted by any party who, at the time of the celebration, was psychologically
incapacitated to comply with the essential marital obligations of marriage, shall likewise be void and even if
such incapacity becomes manifest only after its solemnization.

Art. 68. The husband and wife are obliged to live together, observe mutual love, respect and fidelity, and
render mutual help and support.
Art. 72. When one of the spouses neglects his or her duties to the conjugal union or commits acts, which tend
to bring danger, dishonor or injury to the other or the Family, the aggrieved party may apply to the court for
relief.

FACTS OF THE CASE

The classic love affair between Mr. Jay Felizardo and Ms. Marilen Morales started when the latter was
introduced to the petitioner through her cousin Pia. She and Jay were workmates in National Panasonic. What
started as a simple acquaintance was followed by an intense courtship; Jay was immediately attracted to her
that soon enough he was deeply engrossed with her. Jay would often bring Marilen to and fro in her place of
work; he visited her in their house almost on a daily basis. These adorable actuations of Jay eventually led to a
romantic affair between him and the respondent. Not for long, their secret liaison resulted in sexual intimacies
between the two, not just once, but on several occasions. These intimate moments that Jay and Marilen
shared together in the private perfumed parlor, so to speak, resulted in the unexpected pregnancy of the
latter. This turn of events changed their lives forever.

The fruit of their lovely labor was discussed by them with their respective families. Both families agreed that
since Jay and Marilen are gainfully employed, they should now tie the knot for the sake of their soon-to-be
offspring and transformed their amorous relationship into a marital bliss. Needless to say, Marilen’s pregnancy
hastened their marriage that was held on the 28th of May 1998 in a church in Taytay, Rizal. Most members of
their respective families attended the marital ceremony. The first stages of their married life were full of
happiness and excitement, as they awaited Marilen’s first delivery. She and Jay lived with her family after the
wedding and her family was cordial towards him. As time passed, a second child came, and they eventually
moved in to a new house. It was a smooth sailing for the newly-weds at first. But a gradual changed in what
seemed to be a happy union loomed in the horizon.

Their marriage, however short-lived, blessed them with two children. At the time of their marital union Jay
continued working in National Panasonic whiles his now wife Marilen worked in the Land Bank of the
Philippines. As earlier pointed out, the marriage seemed happy in the beginning until one day the respondent
asked him to go abroad supposedly because their incomes were not enough but much to the opposition of the
petitioner. Jay did not like the idea of either him or his wife going abroad to earn more money at the expense
of the family being separated; according to him they could live on their meager incomes for as long as the
family stays together. But because of the insistence of his wife Marilen to go abroad and to escape from her
pestering, he eventually gave in to her wish and flew to Dubai as an overseas worker in 2004. He worked as a
CNC operator in that far away country known for its unforgiving weather.

Jay endured working hard in the harsh climate of Dubai for more than a year while sending money religiously
to Marilen way back in Manila. Everything was normal in the beginning of their new marital arrangement – Jay
working in Dubai and Marilen working in Manila at the Land Bank of the Philippines.

They communicated constantly through texting and phone calls. But this was not for long, what appeared to
be a happy arrangement at first, took an unexpected turn. Jay noticed a sudden change of Marilen’s behavior:
the frequent texts that she regularly sent to him and the phone calls that she often made became far and
infrequent. There were times that when he called her up, Maricen would simply drop the call. On certain
occasions that he would call her late at night, she was not still in the house and nowhere to be found. And
whenever they would finally talk on the phone, she was always in a hurry to stop the conversation arguing that
that the international calls was expensive even if it was Jay who was paying for them anyway. Making the
situation worse, the respondent even prevented their two children from talking to him on the phone. But to
the biggest surprise of Jay, she had the gall to ask him for a marital separation on the phone! She made it clear
to Jay that she was ending their marriage right on the very moment they were conversing on the phone. Jay
was at a loss on Marilen’s strange new actuations towards him and her seeming loss of affection towards him.
The new sad development in his married life drove him to tears and he almost lost his mind figuring out what
could be the reason for his wife’s drastic decision. Did I do something terribly wrong? This was the nagging
question at the back of his tortured mind. He could not think of anything he had done to merit such a cold
treatment from the lady she dearly loved. He however recalled what his childhood friend, Froilan Bagares, told
him about the rumors of Marilen having entertained another man. This man was often seen driving off Marilen
after work. Despite these rumors, Jay still continued to believe that his wife still loved him, ever loyal to him,
cared for their children and valued the sanctity of their young marriage. He was wrong.

Jay went home to the Philippines in 2005 in order to find the real score and hoped to save his marriage to
Marilen. His main task of returning to the Philippines was precisely to fix their marital union he dearly valued
and for the sake of their children. To his consternation, Marilen frankly told him that they part ways and from
then on would lead separate lives. But Jay, hopeful as he had always been, requested the help of his relatives
in the hope that Marilen would take a 360 degree turn on her drastic decision to split up with Jay. Instead of
listening to them however, she dropped the bomb, so to speak, on him in front of their close relatives: Jay’s
parents and sibling and Marilen’s mother. Marilen made her feelings loud and clear to Jay that she had no
intention anymore to patch things up with him. She further added that she no longer loved him, hence, the
eventual separation. That was the last straw for him, and has from then on learned to accept the faith of his
marriage to his once beloved wife. Right there, he decided to go back working abroad. He presently has a
girlfriend and he also religiously continues to give financial support to his two children. And since then, the
petitioner and the respondent had been living separate lives.

WHEREFORE, premises considered, it is respectfully prayed that after trial, judgment be rendered by this
Honorable Court declaring the marriage between the Petitioner and the Respondent VOID AB INITIO by reason
of the psychological incapacity of the petitioner and respondent, citing Art. 36 of the Family Code.

Other reliefs just and equitable are prayed for.

June 28, 2010

Taytay, Rizal for Pasig City

IN WITNESS WHEREOF, I have set hereunto my hand this ______________________, 2010,

____________________.

JOHN C. FABON
Affiant

SUBSCRIBED and sworn to before me, in the city/municipality of Taytay Rizal, this _________ day of
__________ 2009.

Doc.No.; _____
Page No.; _____
Book No.; _____
Series of 2009.
Form 23: Rescission of Contract with Damages

REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
FIRST JUDICIAL REGION
Branch 6
Baguio City

DARLY LON V. IGLESIA, CIVIL CASE No. A002-4345

Plaintiff, FOR: Damages for Breach of

Contract
-versus-
LAST FRONTIER CONSTRUCTION CORP.,
Defendant.
x----------------------------------------------------------------x

COMPLAINT

WITH UTMOST DEFERENCE TO THE HONORABLE COURT:

PLAINTIFF, by and through the undersigned counsel, respectfully alleges as follows:

1. Plaintiff is of legal age, married, and a resident of Rm. 03 3rd Floor Ina Mansions, Kisad Road, Baguio
City;

2. Defendant, Last Frontier Construction Corp., is a corporation duly organized and existing under
Philippine Laws, having its principal office at Rm. 2A Antipolo Building, Session Road, Baguio City;

3. That the plaintiff herein desired to build a house, as a present to his then fiancé and for the purpose of
moving in with his future wife after their wedding on June 12, 2014, thus he availed of the services of the
defendant. He and the company president, Mr. Noel Sison, discussed the needs and specifications for the
project. He was assured by Mr. Sison that the house will be finished before the wedding;

4. On February 14, 2013, Mr. Iglesia and Last Frontier Construction Corp. entered into a written
agreement for the construction of a 2 storey house located in 21 Bokawkan Road, Baguio City. Pursuant
thereto, Mr. Iglesia agreed to pay the sum of P 1,000,000.00 for the project. He made a down payment of
P500,000.00 on the same day, with the balance to be due upon completion of the house. Herein defendant
agreed to build the house in accordance of plaintiff design and instructions for the aforesaid price and to
complete the work on or before June 12, 2013;

5. That on April 04, 2013, while the construction of the house was half finished, Mr. Noel Sison, the
company president requested to the plaintiff a break from the construction of the house for his employees to
have break for the holy week which Mr. Iglesia permitted but with the assurance from Mr. Sison’s that the
construction will resume after the holidays;

6. Defendant failed to resume the construction of the house after the holy week as it had promised. Mr.
Iglesia made numerous calls, sent several letters and even personally visited the defendant’s office to remind
them of the contract but the defendant did not respond and wantonly abandoned the half finished project
thus on June 12, 2013 herein defendant failed to finish the project as agreed upon;

7. A demand letter was sent on July 12, 2013 and another on August 15, 2013 for the defendant to
complete the house construction or to reimburse the down payment but all effort served futile;

8. By reason of the facts and circumstances stated above, defendant has breached the contract;

9. Due to the abandonment of the project by Last Frontier Construction Corp., Mr. Iglesias has suffered
mental anguish, serious anxiety, and strain relationship with his wife;

10. Unable to move in to the new house, petitioner had to pay rental fees for the total of P45,000 from
June until September of 2014, which would not have been incurred had Last Frontier Construction Corp. fulfill
its obligation;

11. As a result of the breach of contract, Petitioner had to hire another construction company with an
excess cost of P500,000 just to finish the house;

12. That the contract includes stipulations for liquidated damages for failure to complete work, wherein the
Contractor is to pay the Owner liquidated damages equivalent to the One-Tenth of One Percent (1/10 of 1%) of
the Contract Price per calendar day of delay until completion, delivery and acceptance of the said Works by the
OWNER to a maximum amount not to exceed 10%;

13. Considering the urgency of his changing status, the Plaintiff would have not obtained the services of
the Defendant, if the Defendant had not assured him of timely completion of the house;

14. Defendant’s wanton abandonment and inducement of unreliable on-time and fast completion of the
construction project has caused harm its client, which should be curtailed and prevented in the future;
15. Consequently, Plaintiff was constrained to engage the services of counsel to whom it obligated itself to
pay as Attorney's Fees the amount equivalent to TWENTY FIVEPERCENT (25%) of the total amount to be
adjudged in favor of plaintiffs, and the costs of this suit.

PRAYER

WHEREFORE, the above premises considered, it is respectfully prayed of this Honorable Court
after hearing on the merits, that:

a. Defendant be ordered to pay for moral damages for the amount of FIFTY THOUSAND PESO (P50,000);
b. Defendant be ordered to pay actual damages for the amount of FIVE HUNDRED FORTY FIVE THOUSAND
(P545,000)
c. Defendant be ordered to pay liquidated damages for the amount of ONE HUNDRED THOUSAND PESOS
(P100,000)
d. Defendant be ordered to pay exemplary damages for the amount of ONE HUNDRED THOUSAND PESOS
(P100,000)
e. Defendant be ordered to pay attorney’s fees in an amount equivalent to TWENTY FIVE PERCENT (25%)
of the total amount to be adjudged in favor of plaintiffs;
f. Defendant be ordered to pay the costs of this suit.

Other reliefs just and equitable under the premises are likewise prayed for.

Respectfully submitted this 12th day of January 2015, done in the City of Baguio, Philippines.

Frechie Lacmaan
Counsel for Plaintiff
Rm. 105 Patria de Baguio Bldg,
Upper Session Rd., Baguio City
PTR No. 024/Baguio City/12-31-15
Roll of Atty. No. 74570
IBP Lifetime Membership No. 832
MCLE Compliance No. 0826

REPUBLIC OF THE PHILIPPINES }

DONE: IN THE CITY OF BAGUIO } S.S.
X ========================= X
 VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING

I, DARLY LON V. IGLESIA, after having been duly sworn to in accordance with law, hereby depose and
state:

1. That I am a resident Rm. 03 3rd Floor Ina Mansions, Kisad Road, Baguio City;
2. That I have caused the preparation and filing of the foregoing Complaint;
3. That I have read the contents thereof and that the allegations therein are true and correct of my own
personal knowledge and or based on true and authentic records and documents;
4. That I hereby certify that I have not filed the same or similar action or proceeding against the herein
Defendants before any court or tribunal in the Philippines or abroad. If I should learn that a similar action or
proceeding against the herein Defendants has been filed or is pending before any other court or tribunal, I
shall notify the court within five (5) days from such notice.

IN WITNESS WHEREOF, I have hereunto signed this verification this 12th day of January 2015.

DARLY LON V. IGLESIA

Affiant

SUBSCRIBED AND SWORN to before me in the City of Baguio this 12th day of January 2015 by DARLY
LON V. IGLESIA, who has satisfactorily proven her identity to me through her Professional Driver’s License No.
A01-45789valid until November 28, 2017, that she is the same person who personally signed the foregoing
affidavit before me and acknowledged that she executed the same.

Notary Public

Doc. No. 73;

Page No.15;
Book No. 1;
Series of 2015.
Form 24: Damages based on Torts
Form 25: Damages Based on Contract

Republic of the Philippines

REGIONAL TRIAL COURT
11th Judicial Region
Branch ___
Davao City

Fe Tuadles, Plaintiff, CIVIL CASE No. _______________

- versus – FOR: Damages for death, Loss of earning

capacity, Moral damages and Attorney’s
Fees.

Aurelio Laxa, Bonifacio Cruz,

ULTRA Speed Machine Shop
and A’s Metal Products,
Aurelio Lara, Defendants.
x- - - - - - - - - - - - - - - - - - - - - - -
x

COMPLAINT

COMES NOW, plaintiff, Fe Tuadles, by counsel, and unto this Honorable Court, most
respectfully avers THAT:

1. Plaintiff is a Filipino, of legal age, married, and residing at 32E Jacinto St., Davao City,
where he may be served with summons, papers and other process of this Honorable Court ACOP
Law Firm, Suite 704, LANDCO Bldg, Bajada, Davao City.

2. Defendant Aurelio Laxa is a Filipino, of legal age, single, and residing at Purok 14, Mintal,
Davao City, where he may be served with summons, papers and other process of this Honorable
Court.

3. Defendant Bonifacio Cruz is a Filipino, of legal age, married, and residing at Purok Sto.
Nino, Buhangin, Davao City, where he may be served with summons, papers and other process
of this Honorable Court.
 4. Defendant ULTRA Speed Machine Shop and A’s Metal Products is a juridical entity duly
registered with the Securities and Exchange Commission. It is engaged in the selling metal
products and Auto Repair. It is represented herein by Aurelio Lara, owner and manager of ULTRA
Speed Machine Shop and A’s Metal Products. It may be served with papers and other processes
of this Honorable Court at 131 R. Magsaysay Avenue Davao City.

5. Defendant Aurelio Lara is a Filipino, of legal age, married, and residing at 131 R.
Magsaysay Avenue Davao City, where he may be served with summons, papers and other
process of this Honorable Court.

6. Both parties have capacity to sue and to be sued.

7. Plaintiff herein is the wife of victim of the vehicular accident, Romeo Tuadles who is the
sole bread winner of the family.

8. Defendant Bonifacio Cruz, is the registered owner of a Cimarron Jeepney, and particularly
described as follows:

Make and Type: Cimarron Jeepney

Plate No.: LXX-349

9. Defendant ULTRA Speed Machine Shop and A’s Metal Products owned by Aurelio Lara has
legal possession of the vehicle and bound itself by an acknowledgment attached herewith
“Annex A”, to be responsible for any and all incidents that may occur while the said vehicle is in
their custody.

10.Defendant Aurelio Lara is the employer of Aurelio Laxa, being the owner of ULTRA Speed
Machine Shop and A’s Metal Products.

11.On December 29, 2010, Bonifacio Cruz brought his vehicle to ULTRA Speed Machine Shop
and A’s Metal Products by Aurelio Lara for repair and left the said vehicle at the shop.

12.At about January 2, 2011, Aurelio Laxa, a driver of A’s Metal Products with his co-workers
on board drove the vehicle in going to the beach.

13.In driving back from the beach, Aurelio Laxa lost control of the vehicle while negotiating a
curve causing it to turn turtle resulting in the death of one of its passengers Romeo Tuadles.

14.A demand letter for indemnification for damages was by plaintiff to defendants.

15. Defendant Bonifacio Cruz promptly denied liability for reason that his vehicle was used
and driven without his knowledge and consent by Aurelio Tuadles at the time of the accident.

16.As a result of the death of Romeo Tuadles, his family is in financial difficulties because they
depend on him as a sole wage earner in the family. Hence, they must be made to pay for
damages for the death of Romeo Tuadles, in the amount equivalent to FIVE HUNDRED
THROUSAND PESOS (P 500,000.00).

17.Due to the sudden death of Romeo Tuadles, his wife and children suffered mental anguish
and serious anxiety.

18. Consequently, Plaintiff was constrained to engage the services of counsel to whom it
obligated itself to pay as Attorney's Fees the amount equivalent to TWENTY FIVE PERCENT (25%)
of the total amount to be adjudged in favor of plaintiffs, and the costs of this suit.
 PRAYER

WHEREFORE, the above premises considered, it is respectfully prayed of this Honorable

Court after hearing on the merits, that:

a. Defendants be ordered to pay for damages for death in the amount of FIVE
HUNDRED THROUSAND PESOS.

b. Defendants be ordered to pay moral damages in the amount of FIVE HUNDRED

THOUSAND PESOS (Php 500,000.00);

c. Defendants be ordered to pay attorney’s fees in an amount equivalent to TWENTY

FIVE PERCENT (25%) of the total amount to be adjudged in favor of plaintiffs;

d. Defendants be ordered to pay the costs of this suit.

Other reliefs just and equitable under the premises are likewise prayed for.

For the Plaintiff

By

ATTY. LOREVILL PINOON

ACOP Law Firm, Suite 704, Landco Bldg.,

Bajada Street, Davao City

PTR No. 1247838 1-20-2012 Davao City

IBP No. 911117 1-21-2012 Davao City

Roll No. 89994

MCLE Ex. No. 111-000748 1-13-2012

For 3rd compliance

Form 26: Answer with Negative and Affirmative Defenses
 
ANSWER WITH SPECIAL AND AFFIRMATIVE DEFENSES
AND COUNTERCLAIM

JUAN DELA CRUZ

Plaintiff, CIVIL CASE NO. 12368

-versus-

PEDRO SANTOS

Defendant,

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

ANSWER WITH SPECIAL AND AFFIRMATIVE DEFENSES

AND COUNTERCLAIM

NOW COMES the defendant in the above entitled case, and to this Honorable Court most respectfully alleges:

1. Defendant admits the averment in paragraph 1,2 and 3 of the complaint;

2. Defendant specifically denies the allegation in paragraph 4 of the complaint, the truth being that…. ( State here the
fact being claimed by the defendant as the true state of facts or the truth being those stated in the special and
affirmative defenses herein set forth)

3. Defendant has no knowledge or information to form a belief as to the truth of the averment in paragraphs 5,6,7 and 8
of the complaint;

By way of special and affirmative defenses, defendant avers:

1. That the obligation has been paid;

2. That the defendant had purchases said land from plaintiff and paid said promissory notes;

3. That the cause of action has prescribed.

By way of counterclaim, defendant alleges:

1. That by virtue of this unwarranted and malicious act initiated by the plaintiff, defendant was forced to engage counsel
in the sum of P10,000.00.

WHEREFORE, it is respectfully prayed that the complaint be dismissed and

defendant be awarded the amount of P5,000.00

Other equitable reliefs are likewise prayed for.

Manila, Philippines, May 27, 2000.

 ERNESTO FLORES

Attorney for the Defendant

_______________________

Address

P.T.R. No.______ Date & Place of Issue______

IBP O.R. No._____ Date & Place of Issue_____
Form 27: Answer with Counterclaim

Republic of the Philippines

Regional Trial Court

7th Judicial Region

Branch 32

Dumaguete City

Juan Tamad,

Plaintiff,

Civil Case No.________

versus

For: ACCION PUBLICIANA

Maria Bulay-og,

Defendant.

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

ANSWER WITH COUNTERCLAIM

Defendant, Maria Bulay-og, through the undersigned counsel, to this Honorable Court, respectfully states that:

I. ADMISSIONS

1.1 The defendant admits the allegation in paragraph 1 of the Complaint in so far as it relates to her personal
circumstances except the allegation as to her civil status;

1.2 Defendant also admits the allegation in paragraph 4 of the Complaint but only as to the fact that plaintiff did
not reside on the subject property;

II. SPECIFIC DENIALS

2.1 The allegation in paragraph 1 of the Complaint relating to defendant's civil status is denied. Defendant, Maria Bulay-
og is single.

2.2 Defendant also denies the allegations in paragraph 1 of the Complainant relating to the personal circumstances of
the plaintiff are denied for lack of knowledge or information sufficient to form a belief as to the veracity thereof;

2.3 The allegations in paragraphs 2 and 3 of the Complaint that the plaintiff is the absolute and registered owner of the
subject lot situated in Bagacay, Dumaguete City, Negros Oriental, are strongly denied. The truth of the matter is found in
the affirmative defenses found hereunder;
2.4 All the other allegations in paragraph 4 of the Complaint are denied for lack of knowledge or information sufficient to
form a belief as to the veracity thereof;

2.5 The defendant strongly denies the allegations in paragraphs 5,6,7,8,9, and 10 of the Complaint. The truth of
the manner is found in the affirmative defenses found hereunder;
2.6
2.6 The defendant strongly denies the allegations in paragraphs 11, 12, and 13 of the Complaint not only for lack of
knowledge or information sufficient to form a belief as to the veracity thereof but also for being distorted conclusions of
facts and law;

III. AFFIRMATIVE DEFENSES

In support of their DENIALS, the defendant asserts the following affirmative defenses:

3.1 The present case is a clandestine attempt on the part of the plaintiff to gain possession of property through judicial
fiat the actual possessor and owner thereof being defendant Maria Bulay-og. The subject property, Lot No. 20, situated
in Bagacay, Dumaguete City, Negros Oriental, covered by OCT. No. 1122 has been the subject of a Kasulatan sa
Pagbligya sa Yuta between Pedro and Juana Tamada, plaintiff's parents, and Mario and Juanita Bulay-og, defendant's
parents, dated August 8, 1952, hereto attached as Annex “1”.

3.2 Proof of the genuiness and due execution of such Kasulatan sa Pagbaligya sa Yuta of Lot No. 20 are the following:

a. Sworn statement of Ms. Maria Junriza S. Cimeni, hereto attached as Annex “2”, stating that she was present when the
sale took place and that she also signed as witness to the Kasulatan sa Pagaligya sa Yuta notarized by Atty. Primitivo
Ruiz, with document no. 25, page no. 5, book no. X, series of 1952;

3.3 Sometime in 1953, a small house was built where defendant and her family, together with a cousin, Marvilia Serna,
Lived until Mario and Juanita Bulay-og died in March and November 1980, respectively.

3.4 In 1984, Maria went to Manila to work and left the property under the care of her cousin, Marvilia who later on
married a neighbor, Kristiano Cruz. They lived in the adjoining lot of Lot No. 20. Marvilia's Sworn Statement is hereto
attached as Annex “3”;

3.5 In 1981, Maria Bulay-og came home to Bagacay, Dumaguete to settle permanently. Planning to rebuild their house
for her and her family, she applied for the issuance of a building permit from the City of Dumaguete. Such Building
permit is hereto attached as Annex “4”;

3.6 Since 1986, Maria Bulay-og and her family have been in peaceful and undisturbed possession and occupation of the
land. It was only in April 2014, that plaintiff, Juan Tamad, suddenly claimed ownership over the said lot.

3.7 Other relevant documents supporting defendant's claim of ownership and lawful occupation over the subject
property include the following;
a. A certification issued by the City Treasurer, Mr. Marquel Peonila, stating that the realty taxes over the subject property
under the name of Mario Bulay-og have been paid by the couples for the years 1952 to 1980 and by herein defendant,
Maria Bulay-og for the years 1981 to 2016. Such certificate is hereto attached as Annex “5”

b. Real property tax receipts for the years 2014 to 2016 are also hereto attached as Annexes “6”, “7”, and “8”;

3.8 In view of the overwhelming and unequivocal evidence presented above, showing that the plaintiff has lost
ownership of Lot No. 20 Psu-01-23-456789 by virtue of a Deed of Absolute Sale executed by him in favor of the
defendant, and that plaintiff deliberately, and without just cause, refused to deliver the OCT over the said, his complaint
for accion publiciana is preposterous, hence can never prosper.

IV. COMPULSORY COUNTERCLAIM

The defendant replead the foregoing recitals by way of reference;

4.1 The filing of this case clearly baseless and malicious. For such reason, the defendant and her family has suffered
mental anguish, sleepless nights, serious anxiety and other similar injuries. The plaintiff must then be held liable to
indemnify them the amount of Fifty Thousand Pesos (Php 50,000.00) by way of moral damages;

4.2 By reason of the filing of this malicious and baseless complaint, the defendants were compelled to engage the
services of the undersigned counsel for a stipulated amount of Forty Thousand Pesos (P40,000.00) as attorney's fee and
an appearance fee of Two Thousand Five Hundred Pesos (P2,500.00) per hearing for which they should be reimbursed by
the plaintiff;
Form 28: Complaint in Intervention

Republic of the Philippines

REGIONAL TRIAL COURT
11TH Judicial Region
Branch 17
Davao City
LEON TROTSKY
Intervenor, CIVIL CASE No. 128-9456
For: INTERVENTION
VS.
DEREK RAMSY
Plaintiff
-x------------------------------------------- x
COMLAINT-IN-INTERVENTION
INTERVENOR, by counsel, unto this Honorable Court respectfully states and prays
that:
1. Intervenor, a Russian but naturalized Filipino citizen, of legal age, married to Jessica
Sanchez, a Filipino citizen and a resident of Trotsky resort, Boracay Island, Philippines.

2. Herein Intervenor is the true owner of the property which is the subject of controversy
in Civil Case No. 128-9456, embraced in the alleged new Transfer Certificate of Title
No. 11919, originally under TCT No. 12345, (hereto attached as Annex “A-1”) with an
area of five thousand square meters (5,000 sq m) located at Brgy. San Isidro, Babak
Pulong Harding Lungsod ng Samal, Philippines.
3. Said property in question, was acquired by the Intervenor from Kobe Bryant on
June 7, 2005 in consideration of P1,500,000.00 as stated in the Deed of Sale
registered under the name of Kobe Bryant and Jessica Sanchez, recorded in the Registry
of Deeds in the Province of Davao del Norte. (copy attached as Annex” A-2”)
4. The litigants in this case, (plaintiff) as claimant and (defendant) who is in actual used
and possession of the property in question, have no legal standing of their claims on the
basis that all transactions and performances subsequent to the transaction executed
between herein Intervenor and Mr. Kobe Bryant in relation to the property in question
described in the original title TCT 12345 and in TCT 11919 is presumed to be void
considering that said property was already sold to Intervenor and now is the subject of
this complaint.

5. The Intervenor deeply affected of the fraudulent transactions initiated by the

irresponsible vendor (Kobe Bryant) of the questioned property, which is the subject
matter in this case, that caused him to initiate legal remedy for the relief and recovery of
damages inflicted to his person, and bring the matter to this honorable court in a way of
intervention.

WHERFORE, it is prayed:
3. That all transactions and performances executed by the litigants in relation to the
property-in-question, including related documents in their possession shall be declared void.

4. That the litigants be ordered by this Honorable Court to voluntarily turn-over the
questioned property to the rightful owner who is the Intervenor in this case.

5. That if voluntary turn-over of the property or waiver of the claim by both plaintiff and
defendants is not possible, order be made against the litigants to pay for the damages and
other litigation expenses plus attorney’s fees in favor of the Intervenor.
6. Further it is prayed that Intervenor be granted such relief found to be consistent with law
and equity.

Signed this 4th day of March 2013 in Davao City, Philippines.

LEON TROTSKY
Intervenor

Assisting Counsels:
LEONARDO P. CATARAJA
Davao City
Form 29: Interpleader

NALI LITO,
Plaintiff, SCA No.
____________
- versus -
UMA AGAW and INA AGAWAN,
Defendants.
x --------------------------------------- x

COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff and defendants are all of legal age; plaintiff resides at

________________ while defendants reside at _______________ and_______________, respectively, where they may be
served with pertinent
notices.

2. On 1 June 2007, plaintiff found a Gold Rolex Oyster watch, without knowing who its true owner is. The watch
is now in plaintiff’s possession. On or about 5 June 1999, defendants made similar representations to plaintiff as to
ownership of the watch.
3. Plaintiff, who claims no interest in the watch, cannot determine the conflicting claims of defendants and thus
seeks to compel defendants to interplead and litigate their several claims between themselves.

WHEREFORE, it is respectfully prayed that this Honorable Court issue an order directing defendants to
interplead with one another to determine their respective rights and claims and to allow plaintiff to recover his expenses
for safekeeping and the costs of this suit, as first lien upon the subject matter of
this action.

Quezon City; 7 July 2007.

(Sgd.) ATTICUS FINCH

Counsel for Plaintiff
[Address]

VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING

Form 30: Mandamus

REPUBLIC OF THE PHILIPPINES

Supreme Court
P. Faura, Manila
Hon. LORETTA ANN ROSALES,Atty. AL. S. VITANGCOL III,Engr.
RODOLFO LOZADA, JR.and THOMAS AFRICA,
Petitioner,

-versus- G. R. No.________________

COMMISSION ON ELECTIONS,represented by its Chairman,Hon. JOSE A.R. MELO,

Respondent.
x------------------------------------------------------x

PETITION

PETITIONERS, by counsel, respectfully state that:

1. That the petitioner is of legal age, (state the capacity and residence of the petitioner, and of the
public and private respondents);

2. That (state the facts and circumstances under which the respondent-tribunal, board or officer)
unlawfully neglected the performance of an act which the law specifically enjoins as a duty resulting
from an office, trust or station, or unlawfully excluded the petitioner from the enjoyment of a right or
office to which the petitioner is entitled;

3. That the petitioner has no other plain, speedy and adequate remedies in the ordinary course of law
other than this action;

4. That (state the material dates showing when notice of judgment or final order or resolution subject
thereof was received, when a motion for new consideration, if any, was filed and when notice of the
denial thereof was received).

5. That the petitioner by reason of the wrongful act of the respondent has sustained damages in the
sum of __________ pesos (Php___________);

WHEREFORE, it is respectfully prayed, that after due notice and hearing, a Writ of mandamus be
issued, commanding the respondent forthwith to: (here state the act required to be done, with
damages and costs.)

________ City, Philippines, this _____ day of _______2011

Name _______________________________
Appointment No. _____________________
Roll of Attorney No. ___________________
PTR No.____, ____ (date and place of issue)
IBP No. ____, ____ (date of issue) (chapter)
Office Address________________________
Email Address ________________________
Contact No. __________________________
MCLE Compliance (or Exemption) No._____

VERIFICATION AND CERTIFICATION AGAINST FORUM-SHOPPING

Form 31: Prohibition
Republic of the Philippines
National Capital Judicial Region
REGIONAL TRIAL COURT
Branch ___
Quezon City

ANDRES BONIFACIO
Petitioner, SCA No._________

-vs- For: Prohibition

SANGUIGUNIANG BARANGAY NG SOCORRO

QUEZON CITY
Respondent
x-------------------------------------------------------------------x

PETITION FOR PROHIBITION

PETITIONERS, by counsel, respectfully state that:

1. That the petitioner is of legal age, (state the capacity and residence of the petitioner, and of the
public and private respondents);

2. That (state the facts and circumstances under which the respondent-tribunal, board or officer,
exercising judicial functions, has acted without, or in excess of its jurisdiction, or with grave abuse of
discretion in the proceedings complained of);

3. That (state that there is no appeal from such act or any plain, speedy and adequate remedy in the
ordinary course of law);

4. That a certified true copy of the decision (or order) herein sought to be annulled is hereto attached
as “Annex A”, together with copies of all pleadings and documents relevant and pertinent thereto.

5. That (state the material dates showing when notice of judgment or final order or resolution subject
thereof was received, when a motion for new consideration, if any, was filed and when notice of the
denial thereof was received).

WHEREFORE, it is respectfully prayed, that pending the proceedings in the action, a preliminary
injunction be granted ordering the respondent _________ to desist and refrain from further
proceedings in the premises, and that after due notice and hearing, a Writ of Prohibition be issued
commanding the said respondent to desist absolutely and perpetually from further proceedings (in the
action or matter in question), with costs.

________ City, Philippines, this _____ day of _______2010.

Name _______________________________
Appointment No. _____________________
Roll of Attorney No. ___________________
PTR No.____, ____ (date and place of issue)
IBP No. ____, ____ (date of issue) (chapter)
Office Address________________________
Email Address ________________________
Contact No. __________________________
MCLE Compliance (or Exemption) No._____

VERIFICATION AND CERTIFICATION AGAINST FORUM-SHOPPING

Form 31: Foreclosure of Mortgage

Republic of the Philippines

REGIONAL TRIAL COURT
10th Judicial Region
Branch ___
Malaybalay City

LEGINE RAMAYLA
Petitioner – Mortgagee
SCA No. ___________
-vs- For: Foreclosure of Real Estate
Mortgage
NIKKI EBILLO
Mortgagor
x---------------------------------------x

COMPLAINT FOR FORECLOSURE OF REAL ESTATE MORTGAGE

COMES NOW, the plaintiff by the undersigned attorney, and unto this Honorable Court,
respectfully states:
1. That both the plaintiff and the defendant are of age, and residents of
______________________________________________

2. That on _____________, the defendant, in order to secure the payment of the sum of
______________, acknowledged to have been received by him on said date, executed in
favor of the plaintiff a first mortgage on certain real property located in
________________________, a true copy of said mortgage contract is hereto attached as
Exh. “A”, and made an integral part of this complaint.

3. That the condition of said mortgage, as stated therein, is such, that if within the period of
_______________ from and after the execution of same, the defendant shall pay or cause to
be paid to the plaintiff, his heirs or assigns, the said sum of ________________ together with
the stipulated interest of ________% per annum, then the said mortgage shall be discharged;
otherwise, it shall remain in full force and effect, to be enforceable in the manner prescribed
by law;

4. That the defendant has not paid or caused to be paid the mortgage debt of _________ or
any part thereof, in spite of the lapse of the stipulated period;

5. That the plaintiff has demanded of the defendant to pay the above sum of _____________,
plus the stipulated interest, but said defendant has failed to pay the same;

6. That the defendant has also agreed in the mortgage contract that should the plaintiff
foreclose the mortgage, the latter is entitled to receive the further sum of __________% of
the total amount due as attorney’s fees, expenses and costs.

7. That there are no other persons having or claiming an interest in the mortgaged property.

WHEREFORE, it is respectfully prayed:

(a) That, upon due hearing, judgment be rendered: (1) ordering the defendant to pay unto the
court within the reglementary period of ninety days the sum of _____________ together
with the stipulated interest at _______% per annum from and after _______________, plus
 the additional sum of ______% of the total amount due as attorney’s fees, expenses and
costs; (2) and that in default of such payment, the above-mentioned property be ordered
sold to pay off the mortgage debt and its accumulated interest, plus _____% of the total
amount due as attorney’s fees, expenses and costs,

(b) That plaintiff be granted such other relief in law and equity. ___________,
______________________, 20 _____.

___________________
Counsel for Plaintiff
(address)
FORM 33: COMPLAINT FOR REPLEVIN

Republic of the Philippines

Regional Trial Court
National Capital Judicial Region
Branch 1, Manila

Juan Tamad
Plaintiff, Civil case no. 11111
For: Replevin
-versus-

Maria Makiling
Defendant
x----------------------------x

COMPLAINT

Plaintiff by the undersigned counsel and unto this Honorable court respectfully avers that:

1.Both Plaintiff and defendat are of age and is currently residing at 3 Rose st. Tondo Manila and
4 Rose St. Tondo Manila respectively;

2.Plaintiff is the owner of a certain personal property, namely a Hyundai Starex valued at
P450,000 and more particularly described as follows to wit; A motor Vehicle namely a 4
cylinder 1999 hyundai starex van rented by the defendant on January 4 2012 to be used in
defendants company outing. Which van defendant failed to return on the same day agreed upon
by both parties.

3.Said property has not been distrained or taken for a tax assessment or seized under a writ of
execution or preliminary attachment or custodia legis.

4. Plaintiff has demanded from defendant the return of said property but the later refuse and
continues to refuse to do so.

5.Plaintiff has executed a performance bond in double the value of the property, in favor of the
defendant, for the return of the property to former if such return be adjudged, and for the
payment of such sum as the defendant may recover in the action.

WHEREFORE it is respectfully prayed that:

a. The subject property be delivered to the plaintiff;

b. Defendant be made for the cost of this suit;

c. The plaintiff be granted such other reliefs consistent with law and equity;

City of Manila March 29, 2012.

SIGNATURE OF COUNSEL
VERIFICATION AND CERTIFICATION OF NON FORUM SHOPPING
FORM: 34: PETITION TO CHANGE NAME

RA 9048 Form No. 4.1. (LCRO)

(Devised 10 October 2001)
Republic of the Philippines
OFFICE OF THE CITY/MUNICIPAL CIVIL REGISTRAR
Province:____________________
City/Municipality: __________________

Republic of the Philippines )

__________________________ ) SS Petition No. __________________

PETITION FOR CHANGE OF FIRST NAME

I, _____________________________, of legal age, ______________________,
and a resident of ___________________________, after having been duly sworn to in accordance with law,
hereby declare that:

1)I am the petitioner seeking the change of first name in:

a) my Certificate of Live Birth
b) the Certificate of Live Birth of (complete name of owner) who is my (relation of owner to the
petitioner).

2)I/He/She was born on ____________________ at _________________, ____________,

_____________________.
3) The birth was recorded under registry number ___________________________________________ .
4)The first name to be changed is from _______________________ to _________________________ .
5)The grounds for filing this petition are the following:
(Ground selected should be explained/justified in a separate sheet of paper to be attached to this form.)
a) The first name is extremely difficult to write or pronounce;
b)I have/He/She has habitually and continuously used _________________ and I/he/she is publicly
known in the community with that first name;
c) The first name is tainted with dishonor;
d)he first name is ridiculous;
e) The first name causes confusion;

6) I submit the following documents to support this petition:(Use additional sheets, if necessary.)
a) ______________________________________________________________________________
b) ______________________________________________________________________________
c) ______________________________________________________________________________
d) ______________________________________________________________________________
e) _____________________________________________________________________________
7)I have/He/She has not filed any similar petition and that, to the best of my knowledge, no other similar
petition is pending with any LCRO, Court or Philippine Consulate.
8)I have/He/She has no pending criminal, civil or administrative case in any court or any quasi-judicial body.
9)I am filing this petition at the LCRO of ______________________ , ________________________

VERIFICATION

I, ___________________________________ , the petitioner, hereby certify that the allegations herein

are true and correct to the best of my knowledge and belief.
___________________________________
Signature over printed name of petitioner

SUBSCRIBED AND SWORN to before me this __________ day of ______________________ in the

city/municipality of ____________________, petitioner exhibiting his Community Tax Certificate No.
________________ issued at ______________________________ on ________________________ .

___________________________
Administering Officer
Doc. No. ________________
Page No. ________________
Book No. ________________
FORM 35: PETITION FOR ADOPTION
Republic of the Philippines
REGIONAL TRIAL COURT
9th Judicial Region
Branch 15
Zamboanga City

IN RE: PETITION FOR ADOPTION

OF ANAKIN SKYWALKER SP No. 111334

DARTH VADER and PADME AMIDALA,

Petitioners.
x
-----------------------------------------------------x

PETITION
PETITIONERS, by counsel, respectfully state that:

1. Petitioners are husband and wife, both of legal age, and residents of __________.
2. They have no legitimate children of their own and desire to jointly adopt a minor named ANAKIN
SKYWALKER, 10 years old, the legitimate child of _________________.
3. The parents of the minor are not insane, intemperate and are in full possession of civil capacity; they have
not abandoned the minor child. With full knowledge of petitioners’ intention, they have expressly given their
written consent to the adoption, as shown by their statement, a copy of which is attached as ANNEX A.
4. Petitioners are qualified to adopt the minor and are financially capable of supporting the minor; they are
also morally qualified to bring up and educate the said minor.

WHEREFORE, it is respectfully prayed that judgment be rendered in petitioners’ favor adjudging

the minor child ANAKIN SKYWALKER freed from all legal obligations of obedience and maintenance with
respect to his/her natural parents and that he/she be declared to all legal intents and purposes, the child of
herein petitioners and that his/her surname be changed to that of petitioners.

Quezon City; 7 July 2007.

(Sgd.)
MASTER YODA
[Address]

PLUS:
Verification and Certification against Forum Shopping
FORM 36: PETITION FOR ISSUANCE OF WRIT OF HABEAS CORPUS

Republic of the Philippines

National Capital Judicial Region
REGIONAL TRIAL COURT
Branch 191
Makati City

IN RE: PETITION FOR HABEAS

CORPUS OF THE MINORS LUKE
AND LEIA SKYWALKER SP No. 111334

PADME AMIDALA,
Petitioner.

-vs-

ANAKIN SKYWALKER,
Respondent.
x ----------------------------------x

PETITION

PETITIONER, by counsel, respectfully states that:

1. Petitioner is the mother of the minors Luke and Leia Skywalker, who were born out of the valid
marriage between petitioner and respondent Anakin Skywalker.
2. The marriage failed and petitioner has been living separately from respondent since 2004. Sometime
in February 2007, respondent, unknown to petitioner, abducted the minor children and has kept them
incommunicado and out of petitioner’s reach.
3. Being below seven (7) years of age, custody of the minors is naturally presumed to belong to
petitioner, as their mother. Consequently, respondent’s refusal to allow petitioner to regain custody over the
minors is unlawful and unjustified.

WHEREFORE, petitioner respectfully prays that a writ of habeas corpus issue directing respondent to make a
return showing his legal authority to detain the minor children, subject of this petition, and thereafter, present
the minor children personally before the Court on a date and time it chooses.

Quezon City; 7 July 2007

.
OBI WAN KENOBI
Counsel for Petitioner
[Address]

PLUS: Verification and Certification against Forum Shopping

FORM 37: PETITION FOR GUARDIANSHIP

PETITION FOR GUARDIANSHIP

NOW COMES X, by his undersigned attorney, to this Honorable Court and respectfully represents:
1. That he is the father of the minor Y;

2. That Y is presently a resident of the City of Manila;

3. That Y is the owner of a parcel of land located in the City of Manila valued at P50,000 and as such
minor can make no transactions regarding the same;

That the nearest of kin of Y are the following:

(here mention the nearest kin and their address)

That due to the minority of the said ___________________, it is necessary and convenient that
a guardian of his person and property be appointed;
That, as above stated, ____________________ is the person having the said minor in his care, and that
he possesses all qualifications to whom letters of guardianship should issue.
(Furnish a bond of not less than 10% of the value of the property or annual income, if it exceeds P50,000)

WHEREFORE, it is respectfully prayed that after due notice and hearing your petitioner be appointed
guardian over the estate of Y.
Manila City, January 7, 2019;
________________________
Counsel
(Address)

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

FORM 38: PETITION FOR VOLUNTARY INSOLVENCY
FORM 39: ELECTION PROTEST

PETITION
Petitioner through counsel respectfully alleges:
1. That he is a qualified voter and was one of the registered candidates voted for in the general election
held on _____________ in the province of _______________Philippines. within the jurisdiction of the
court;

2. That according to the certificate of canvass of the provincial board of canvassers for the province of
________ the total votes for the office of the provincial governor for the said province was___________
the respondent appearing to have received ______ votes, the petitioner ____________votes and the
other registered candidate voted for as follows:_______________ .

3. That on _______, the said provincial board of canvassers proclaimed the respondent ________ elected
to the office of the provincial governor of the province of _______;

4. That the petitioner contests the election of the said respondent on the following grounds:
__________________).
5. That the petitioner is willing to give a bond, as this Honorable Court may determine to cover all
reasonable expenses and costs and damages, incidental to these proceedings.

WHEREFORE, it is respectfully prayed:

1. That upon service of summons in accordance with law, a day be set for the hearing of the protest;

2. That an order be issued to the municipal treasurers of the Municipalities of ______ to bring and
present before the Honorable Court on or before the day of the hearing of this protest the ballot
boxes, copies of the registry list, the election statements, the voter’s affidavits and other documents
used in the said election in said Municipalities, in order that this Honorable Court may re-examine
and revise the same;

3. That after due proceedings, the election of the respondent, and ________________ for the office of
Provincial Governor ____________ be annulled and that the petitioner be declared duly elected
instead;

4. That the expenses and costs incurred in these proceedings be assessed against the respondent.

________, City, Philippines, this _____ day of _______ 20____

________________
Counsel
(Address)
FORM 40: MOTION FOR JUDGMENT ON THE PLEADINGS

Republic of the Philippines

National Capital Judicial Region
REGIONAL TRIAL COURT
Branch 191
Makati City

CATHERINE VELASCO
Plaintiff, CIVIL CASE No.________
For:
-vs-

KRISHIANNE LOUISE LABIANO

Defendant.
x---------------------------------------x

MOTION FOR JUDGMENT ON THE PLEADINGS

Plaintiff, by counsel, respectfully alleges that:

1. On May 5, 2013, plaintiff sued defendant for a sum of money in the amount of Two Hundred Thousand Pesos
(P200,000.00);

2. In his Answer, defendant admitted the obligation and merely stated that he was asking to be given an
extension of time to pay his obligation but that plaintiff instead filed the Complaint;

3. Said Answer has not tendered any issue and in fact it can be read therefrom that defendant admitted the
obligation; consequently, a judgment on the pleadings may be rendered.

WHEREFORE, it is respectfully prayed that this Honorable Court render a judgment on the pleadings.

Makati City, Philippines. August 5, 2013.

ATTY. VX YZ
Counsel for Plaintiff

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

MeTC - Branch 62
Makati City

ATTY. AB CD
Counsel for the Defendant
1234 Zamora Street, Pasay City

Greetings!

Please take notice that the undersigned counsel will submit the foregoing Motion to the Honorable Court on
August 27, 2013 at 8:30 in the morning for its favorable consideration and approval.

ATTY. VX YZ
Counsel for Plaintiff
Copy furnished by registered mail:

ATTY. AB CD
Counsel for the Defendant
2233 Zamora Street, Pasay City

EXPLANATION

Due to lack of messengerial services to effect personal service, a copy of the foregoing motion was sent to
defendant's counsel through registered mail.

ATTY. VX YZ
Counsel for Plaintiff