1.

Complaint for sum of money Republic of the Philippines MUNICIPAL TRIAL COURT IN THE CITIES Branch _____, Bacolod City _________________________, Plaintiff, -versus _________________________, #efendant. &--------------------------& Civil Case No. ______________ For !um of "oney $"ediatable%

COMPLAINT

PLAINTIFF, throu'h the undersi'ned counsel, before this (onorable Court most respectfully states that

PARTIES

1. P)*+N,+FF is of le'al a'e, Filipino, married and a resident of _____. (e may be served -ith court orders and processes throu'h his undersi'ned counsel. /. #0F0N#*N, is of le'al a'e, Filipino, married and -ith address at _______, -here she may be served -ith summons and other court orders and processes.

CAUSE OF ACTION

1. )ast ________, defendant obtained a loan -ith the plaintiff in the amount of _____ 2P___3, Philippine currency, payable on or before __________ to'ether -ith interest in the fi&ed amount of _______, as evidenced by the Promissory Note dated ____________, photocopy of -hich is hereto attached as *nne& $*% and made an inte'ral part hereof.

4. #efendant failed to fully pay her account -ith the plaintiff on ___________ as stipulated in the aforementioned promissory note. !he still has a balance of ____ 2P_____3, Philippine currency. 5. !everal verbal demands -ere made by the plaintiff to the defendant for the latter to pay and settle her unpaid obli'ation -ith the former but despite the promises to settle her obli'ation, defendant deliberately failed to ma6e any payments. 7. Conse8uently, the plaintiff -as constrained to refer the matter to his la-yer,______, -ho sent a final demand letter dated _____ to the defendant. !aid demand letter -as received by the defendant on _____ as sho-n in the Re'istry Return Card. Photocopies of the demand letter dated ____ and the Re'istry Return Card are hereto attached as *nne&es $B% and $C%, respectively, and made inte'ral parts hereof. 9. #espite defendant:s receipt of the demand on _____, and the lapse of the fiveday period from receipt -ithin -hich to settle her obli'ation, as stated in the demand letter, defendant obdurately and contumaciously refused and failed to pay the plaintiff a sin'le centavo of her obli'ation in the total amount of _____ 2P_____3, Philippine currency, to plaintiff:s 'reat dama'e and pre;udice. <. ,o effect collection and to protect his contractual ri'hts due to the defendant:s obdurate and contumacious refusal to settle her unpaid obli'ation, the plaintiff -as compelled to hire the services of the undersi'ned counsel to prosecute the instant case and -as char'ed -ith ____ 2P_____3, Philippine currency, as attorney:s fees, plus per court appearance of ____ 2P______3, Philippine currency, to -hich, defendant should be held liable to pay. =. +n addition, P)*+N,+FF incurred liti'ation e&penses, includin' filin' fee, service of summons and other incidental e&penses, amountin' to _____ 2P____3, Philippine currency, to prosecute his claims a'ainst the defendant. !aid amount should be char'ed a'ainst the defendant.

PRAYER

>(0R0F?R0, premises considered, it is most respectfully prayed of this (?N?R*B)0 C?@R, that ;ud'ment B0 +!!@0# a. #+R0C,+NA the #0F0N#*N, to pay P)*+N,+FF the amount of P0!?! _____ 2P______3, Philippine currency, representin' the unpaid principal loan, plus interest and penalty. b. #+R0C,+NA the #0F0N#*N, to pay P)*+N,+FF the amount of P0!?! _____ 2P______3, Philippine currency, as attorney:s fee plus per court appearance of P0!?! _____ 2P______3, Philippine currency. c. #+R0C,+NA the #0F0N#*N, to pay P)*+N,+FF the amount of P0!?! _____ 2P______3, Philippine currency, representin' liti'ation e&penses. and !uch other and further reliefs and remedies ;ust and e8uitable under the premises. Bacolod City, Philippines this ___ day of _______.

Counsel for the Plaintiff

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING I, _______, of le'al a'e, Filipino, married and a resident of _______, under oath, depose and say that 1. + am the plaintiff in the above-entitled case. /. + caused the preparation of the fore'oin' Complaint. 1. + read all the alle'ations thereof and that the same are true and correct on my o-n personal 6no-led'e and authentic records.

4. + have not heretofore commenced any other action or proceedin' involvin' the same issue in the !upreme Court, Court of *ppeals, or any other tribunal or a'ency. 5. ,o the best of my 6no-led'e, no such action or proceedin' is pendin' in the !upreme Court, Court of *ppeals, or any other tribunal or a'ency. and that if + should thereafter learn that a similar action or proceedin' has been filed or is pendin' before the !upreme Court, Court of *ppeals, or any other tribunal or a'ency. + underta6e to report that fact -ithin five 253 days therefrom to the (onorable Court. SIGNED this ____ day of ____________ ?ccidental, Philippines. in the City of Bacolod, Ne'ros

_________________

R0P@B)+C ?F ,(0 P(+)+PP+N0!3 C + , B ? F B * C ? ) ? # 3 !.!. &-----------------------& SUBSCRIBED AND SWORN to before me, this _____ day of __________ in the City of Bacolod, Philippines by the said affiant -ho e&hibited to me his C,C No. _____ issued on _____ at ______.

#oc. No. _____. Pa'e No. _____. Boo6 No. _____. !eries of _____.

Notary

Public

/. *ns-er

2;ust follo- the headin' and title of the case3

ANSWER WITH COUNTERCLAIM

DEFENDANT, by the undersi'ned counsel, in compliance -ith the !ummons, -hich she received last _____, before this (?N?R*B)0 C?@R, most respectfully files her *ns-er, averrin' as follo-s C1D ,he alle'ations in para'raphs 1 and / of the Complaint on the personal

circumstances of the parties are admitted. (You have the option to deny the allegation for lack of information and belief as to the truth of the averment) C/D C1D ,he alle'ation in para'raph 1 of the Complaint is li6e-ise admitted. #efendant specifically denies the alle'ations in para'raph 4 and 5 of the

Complaint, the truth of the matter bein' that she had already remitted payments to the plaintiff in the total amount of ___________, representin' payment for her loan, includin' interest. Photocopies of the Receipts dated ____________, are hereto attached as *nne&es $1%, $/%, $1%, $4% and $5%, and made inte'ral parts hereof. C4D ,he alle'ation in para'raph 7 of the Complaint is li6e-ise specifically

denied. #efendant has never received the referred demand letter. ,he si'nature appearin' on the Re'istry Return Card attached as *nne& $C% to the Complaint does not belon' to the defendant. C5D #efendant further specifically denies the alle'ation in para'raph 9, < and =

of the Complaint for the reasons mentioned in para'raphs 1 and 4 of the instant *ns-er. "oreover, the alle'ed attorney:s fees and other liti'ation e&penses are to be borne solely by the plaintiff on the 'round that his case is baseless and unfounded.

and by way ! SPECIAL AND AFFIRMATIVE DEFENSES C7D #efendant repleads and reiterates the material averments from para'raphs

C1D to C5D of the herein *ns-er that are relevant and material in the herein headin'. C9D THE PLAINTIFF HAS NO CAUSE OF ACTION AGAINST THE

DEFENDANT; C<D #efendant had already fully paid her loan, includin' interest, to the

plaintiff as evidenced by the receipts here-ith attached as *nne&es $1%, $/%, $1%, $4%, and $5%. C=D +n addition, the defendant has never received the plaintiff:s demand letter.

(ad she received the same, defendant -ould have produced and sho-n the aforementioned receipts to the plaintiff:s la-yer and the instant case -ould not have been filed. COUNTERCLAIM

C1ED #efendant repleads and reiterates the alle'ations in para'raphs C1D to C=D of the herein *N!>0R that are relevant and material in the herein headin'. C1ED #efendant -as compelled to hire the services of counsel to defend the instant case a'ainst the baseless and unfounded Complaint and -as char'ed the amount of _____, as attorney:s fees plus appearance fee in the amount of ________, per hearin', -hich amount should be char'eable to the plaintiff. C11D #efendant suffered sleepless ni'hts, serious an&iety and besmirched

reputation entitlin' him from the plaintiff to moral dama'es in the amount of __________. C1/D ,o set an e&ample to others so that other persons -ill not follo- plaintiff:s -anton act of filin' a baseless and unfounded suit, an e&emplary dama'e in the amount of __________, is char'eable to the plaintiff.

PRAYER WHEREFORE, premises considered, it is most respectfully prayed of this (?N?R*B)0 C?@R, that an ?R#0R be issued F C1D #+R0C,+NA for the #+!"+!!*) of the Complaint. and on the C?@N,0RC)*+" F C/D #+R0C,+NA the plaintiff to pay defendant the amount of ___________, as moral dama'es. C1D #+R0C,+NA the plaintiff to pay defendant an e&emplary dama'e in the amount of __________. C4D #+R0C,+NA the plaintiff to pay defendant attorney:s fees in the amount of ___________, and appearance fee of ___________ per hearin'. C5D !uch other and further relief and remedies ;ust and e8uitable under the premises. Bacolod City, Ne'ros ?ccidental, Philippines, this 11th day of #ecember /EE7.

Counsel for the #efendant

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING I, _______, of le'al a'e, Filipino, married and a resident of _______, under oath, depose and say that 1. + am the defendant in the above-entitled case. /. + caused the preparation of the fore'oin' *ns-er -ith Counterclaim. 1. + read all the alle'ations thereof and that the same are true and correct on my o-n personal 6no-led'e and authentic records.

SIGNED this ____ day of ____________ ?ccidental, Philippines.

in the City of Bacolod, Ne'ros

_________________

R0P@B)+C ?F ,(0 P(+)+PP+N0!3 C + , B ? F B * C ? ) ? # 3 !.!. &-----------------------& SUBSCRIBED AND SWORN to before me, this _____ day of __________ in the City of Bacolod, Philippines by the said affiant -ho e&hibited to me his C,C No. _____ issued on _____ at ______.

#oc. No. _____. Pa'e No. _____. Boo6 No. _____. !eries of _____.

Notary

Public

Copy furnished to

Counsel for the plaintiff

1. Complaint-*ffidavit 2criminal action3

COMPLAINT-AFFIDAVIT

I, ______________, of le'al a'e, married and a resident of Bacolod City, Ne'ros ?ccidental, Philippines, under oath depose and say that 1. + am a stoc6holder and treasurer of ___ Pa-nshop and Ge-elry, +nc., a domestic corporation duly e&istin' in accordance -ith Philippine la-s, and -ith principal office at _______ Bacolod City, Ne'ros ?ccidental, Philippines and branches at ____. /. !ometime in ___, _____ obtained several ;e-elry from __ Pa-shop H Ge-elry, +nc. -____________ branch, usin' her open credit line and in payment of said items, ____ issued in my favor Prudential Ban6 "andala'an Branch Chec6 No. _____ post-dated _____ in the amount of __________ at Bacolod City, Ne'ros ?ccidental. Photocopy of the said chec6 is hereto attached as *nne& $*% and made an inte'ral part hereof. 1. + deposited the above chec6 the account of ___ Pa-nshop and Ge-elry, +nc. at RiIal Commercial Ban6 Corporation at RiIal !t., Bacolod City on _____ but said chec6 -as dishonored by the dra-ee-ban6 for the reason $*CC?@N, C)?!0#.% Photocopies of the RCBC #ebit *dvice dated ___ and Prudential Ban6 Chec6 Return !lip dated ___ are hereto attached as *nne&es $B% and $C% and made inte'ral parts hereof. 4. +mmediately after the disputed chec6 -as returned to me, + informed ____and verbally demanded that she ma6e 'ood the said chec6 or to settle her obli'ation -ith ___ Pa-nshop H Ge-elry, +nc. but -ithout any positive action from her. 5. !ometime in ____, + referred the said matter to my la-yer, ____ as it had ta6en a lon' time already for ___ to redeem her chec6 or settle her account. (ence, my la-yer sent a final demand letter dated ____ to ____ for her to ma6e 'ood the sub;ect chec6 or to settle her obli'ation -ith ___ Pa-nshop H Ge-elry, +nc. -ithin five 253 days from receipt thereof. ,he photocopy of the demand letter dated 15 *u'ust /EE1 is hereto attached as *nne& $#% and made an inte'ral part hereof. 7. +n spite of her receipt of the demand letter on ________, SARAH T" BENAVIDES obdurately and contumaciously refuses and totally failed to ma6e 'ood her chec6 or to pay her account -ith the ___ Pa-nshop and Ge-elry, +nc. in the amount of ___________. 9. *s a result of ____ act of not ma6in' 'ood the sub;ect chec6 or pay her account -ith ____ Pa-nshop and Ge-elry +nc., ____ Pa-nshop and Ge-elry +nc. -as compelled to hire the services of counsel in the a'reed sum of ____, -hich amount should be char'ed a'ainst ____. <. ,his *ffidavit is bein' e&ecuted to attest to the truth of the matters herein stated and to support the filin' of a criminal char'e a'ainst ____ -ith address at ________, Bacolod City, Ne'ros ?ccidental for violation of Batas Pambansa Bilan' // andJor such other crime as may be -arranted under the circumstances. IN WITNESS WHEREOF, + have hereunto set my hand this ____ at Bacolod City, Ne'ros ?ccidental, Philippines.

_________ *ffiant SUBSCRIBED AND SWORN to before me this ___ at Bacolod City, Ne'ros ?ccidental, Philippines. + certify that + have personally e&amined the affiant and + am satisfied that she freely and voluntary e&ecuted the fore'oin' *ffidavit-Complaint -ith full 6no-led'e of its contents.

Prosecutor

4. Counter-*ffidavit 2criminal action3

C?@N,0R-*FF+#*K+,

I, ______________, of le'al a'e, married and a resident of Bacolod City, Ne'ros ?ccidental, Philippines, under oath depose and say that 1. + am the Respondent in +.!. No. ________, entitled $____ Pa-nshop and Ge-elry +nc. vs. ___________, for violation of B.P. //, -hich is pendin' before the ?ffice of the City Prosecutor, Bacolod City. /. + am denyin' the alle'ations in the Complaint-*ffidavit dated ____ e&ecuted by ________, the truth of the matter bein' as follo-s 2provide your o-n version of the facts. Provide your defenses such as payment, etc. or attac6 the elements of the offense li6e not all the elements of B.P // are present etc.3 1. ,his Counter-*ffidavit is bein' e&ecuted to attest to the truth of the fore'oin' and constitutes my defense to the above-stated Complaint. IN WITNESS WHEREOF, + have hereunto set my hand this ____ at Bacolod City, Ne'ros ?ccidental, Philippines.

________ *ffiant SUBSCRIBED AND SWORN to before me this ___ at Bacolod City, Ne'ros ?ccidental, Philippines. + certify that + have personally e&amined the affiant and + am satisfied that she freely and voluntary e&ecuted the fore'oin' Counter-*ffidavit -ith full 6no-led'e of its contents.

Prosecutor

5. +nformation 2BP//3

Republic of the Philippines ?ffice of the City Prosecutor Bacolod City People of the Philippines, Complainant, - versusGuan de la CruI, *ccused. &-------------------& INFORMATION ,he undersi'ned *ssistant City Prosecutor accuses Guan de la CruI of K+?)*,+?N ?F B*,*! P*"B*N!* B)A. //, committed as follo-s ,hat on or about the //nd day of November /EE9, in the City of Bacolod, Philippines, and -ithin the ;urisdiction of this (onorable Court, the herein *ccused, 6no-in' fully -ell that her account -ith Prudential Ban6-"andala'an Branch, Bacolod City, Ne'ros ?ccidental, had been closed, did, then and there, -illfully, unla-fully, and feloniously ma6e out, issue and deliver to therein offended party, ____ Pa-nshop and Ge-elry +nc., Prudential Ban6-"andala'an Branch Chec6 No. _____ postdated __________ in the amount of ___________, in payment of a pree&istin' obli'ation from the herein offended party. that -hen said chec6 -as presented to the dra-ee-ban6 for payment, the same -as dishonored and returned for reason of $*ccount Closed%, and herein accused, despite notice of dishonor and demands made upon him failed and refused, and still fails and refuses to redeem or ma6e 'ood the said chec6 up to the present. *ct contrary to la-. Bacolod City, Philippines, February /E, /EE<.

Criminal Case No. ________ For Kiolation of Batas Pambansa Bl'. //

"aria !antos Prosecutor ++ *pproved Pedro CruI City Prosecutor

>itnesses 1. "ary Gane *bad and others Bail Recommended P/,EEE.EE *ddress of the *ccused ______

7. +nformation 2Robbery3 Republic of the Philippines R0A+?N*) ,R+*) C?@R, ?F N0AR?! ?CC+#0N,*) !i&th Gudicial Re'ion Branch ___, Bacolod City People of the Philippines, Complainant, - versusGuan de la CruI and Pablo Gose, *ccused. &-------------------& INFORMATION ,he undersi'ned *ssistant City Prosecutor accuses Guan de la CruI of Robbery under *rt. /=4, par. 5 of the Revised Penal Code in relation to R.*. <17=, committed as follo-s ,hat on or about the //nd day of November /EE9, in the City of Bacolod, Philippines, and -ithin the ;urisdiction of this (onorable Court, the herein *ccused, armed -ith icepic6s, conspirin', confederatin' and actin' in concert, -ith intent to 'ain and -ith violence a'ainst and intimidation of person, did then and there, -illfully, unla-fully, and feloniously ta6e, rob and carry a-ay one 213 ____ No6ia Cellphone valued in the amount of ___________ , belon'in' to "ary Gane *bad, a'ainst the latter:s -ill, to the dama'e and pre;udice of said offended party in the aforementioned amount. *ct contrary to la-. Bacolod City, Philippines, February /E, /EE<.

Criminal Case No. ________ For Robbery 2under *rt. /=4, par. 5 of the Revised Penal Code3

"aria !antos Prosecutor ++

*pproved Pedro CruI City Prosecutor >itnesses 1. "ary Gane *bad - address /. Gon Basa - address 1. and others + hereby certify that + am filin' this case in accordance -ith !ec. 7 of Rule 11/ of the Revised Rules on Criminal Procedure because the *ccused herein havin' been la-fully arrested -ithout a -arrant of arrest did not as6 for preliminary investi'ation nor si'ned a -aiver of the provisions of *rt. 1/5 of the Revised Penal Code. "aria !antos !@B!CR+B0# *N# !>?RN to before me this ____________ in the City of Bacolod, Philippines.

PR?!0C@,?R Received and filed this ______________.

________________ Bail Recommended P1EE,EEE.EE *ddress of the *ccused ______ Presently detained at the loc6-up cell of the Bacolod City Police ?ffice, Bacolod City

7. Petitioner for declaration of nullity of marria'e Republic of the Philippines Re'ional ,rial Court of Ne'ros ?ccidental 7th Gudicial Re'ion Branch ____, Bacolod City __________________, Petitioner, versus CIVIL CASE NO" _______ F #$ D%&'a#a() n ! N*'')(y ! Ma##)a+%

__________________, Respondent. L -----------------------------------------------------L PETITION PLAINTIFF, throu'h the undersi'ned counsel, before this (onorable Court, most respectfully states that C1D Plaintiff is of le'al a'e, Filipino, married and a resident of ___, !ilay City,

Ne'ros ?ccidental, Philippines, -here she may be served -ith court orders and processes. C/D #efendant is of le'al a'e, Filipino, married and a resident of ____, -here

he may be served -ith summons, court orders and processes. C1D ,he Plaintiff and the #efendant entered into a Contract of "arria'e on 7

"ay /EE4 at the !an *ntonio *bad Parish Church, Aeneral )acson 0&t., Bacolod City and officiated by Rev. Fr. ____ ,he fact of their marria'e is recorded in the Re'ister of "arria'es of the ?ffice of the City Civil Re'istrar of Bacolod City, under Re'istry No. __. ,he certified machine copy of the parties: Certificate of "arria'e is hereto attached as *nne& $*% and made an inte'ral part hereof. C4D +mmediately after their marria'e sometime last ____ the defendant -ho is

a seaman by trade left for his employment and -as supposed to come home to the plaintiff at the end of the term of his employment contract on ______________.

C5D

(o-ever, the defendant never returned to the plaintiff. (e finally called

the plaintiff last _____ confessin' that he has another family in ______ and is compelled to stay -ith them considerin' the threats a'ainst his life by the family of his first -ife. C7D #espite her o-n an'uish, the plaintiff mana'ed to in8uire -ith the

National !tatistics ?ffice and discovered that indeed, the defendant had contracted an earlier marria'e -ith a certain _____ in _______ last _______. ,he certified machine copy of the said Certificate of "arria'e is hereto attached as *nne& $B%, and made an inte'ral part hereof. C9D +n vie- of the fore'oin', the plaintiff is compelled to file for the

declaration of nullity of her marria'e -ith the defendant. C<D No child -as born to the parties. Neither have the parties ac8uired any

con;u'al property durin' their marria'e. C=D ,o the best 6no-led'e of the plaintiff, there are no creditors -ith claims

a'ainst the parties. PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this HONORABLE COURT, that after due hearin', an order be issued C1D #efendant. C/D #irectin' the )ocal Civil Re'istrar of Bacolod City to cancel the "arria'e #eclarin' the annulment of marria'e bet-een the Plaintiff and the

Contract under Re'istry No. ___ of the Plaintiff and the #efendant in its Re'ister of "arria'es. C1D *llo- the Plaintiff to resume the use of her maiden name,

_____________, and, C4D premises. Bacolod City, Philippines, this ____. !uch other relief and remedy as may be fair, ;ust and e8uitable under the

Counsel for the Plaintiff

2Kerification and Certification on Non-Forum !hoppin'3 Copy furnished to

THE HON" SOLICITOR GENERAL ?ffice of the !olicitor Aeneral 114 *morsolo !t., )e'aspi Killa'e "a6ati City, "etro "anila Re'istry Rec:t No. ________. Re'istered on ___________. at the Bacolod City Post ?ffice.

NATIONAL CENSUS AND STATISTICS OFFICE 0ast *venue, MueIon City Re'istry Rec:t No. ________. Re'istered on ___________. at the Bacolod City Post ?ffice.

OFFICE OF THE CITY CIVIL REGISTRAR Bacolod City Received by ___________ #ate _________________

OFFICE OF THE CITY PROSECUTOR Bacolod City Ne'ros ?ccidental Received by ___________ #ate _________________

E,PLANATION (Pursuant to Sec. 11 !ule 1" of the 1##$ !evised !ules of Civil Procedure) ,his (onorable Court is respectfully informed that copies of the fore'oin' Petition -as served to the (onorable !olicitor Aeneral and the National Census and !tatistics ?ffice throu'h re'istered mail, by postin' the same at the Post ?ffice as indicated above. Personal service is not practicable considerin' the distance bet-een the offices of the addressee and the undersi'ned.

Counsel for the Plaintiff

9. Petition for *doption Republic of the Philippines R0A+?N*) ,R+*) C?@R, ?F N0AR?! ?CC+#0N,*) 7th Gudicial Re'ion Branch ____, Bacolod City +N ,(0 "*,,0R ?F ,(0 *#?P,+?N ?F "+N?R C(+)#R0N, N*"0)B !P0C. PR?C. N?. ___________

!P?@!0! ____, Petitioners. & N N N N N N N N N N NN N N N N N N N N N N N&

PETITION

P0,+,+?N0R!, throu'h the undersi'ned counsel, before this (?N?R*B)0 C?@R, most respectfully state that C1D ,he P0,+,+?N0R! are husband and -ife, both of a'e, and residents of ____. Photocopy of the Certificate of "arria'e is hereto attached as *NN0L $*% and made inte'ral part of the herein P0,+,+?N. C/D P0,+,+?N0R ___ is a Bel'ian citiIen havin' been 'ranted by the Board of Commissioners of the Bureau of +mmi'ration an admission status of permanent resident alien of the Republic of the Philippines as evidenced by his Certificate of *lien Re'istration and +mmi'rant Certificate of Re'istration both issued by the Bureau of +mmi'ration. Photocopies of the Certificate of *lien Re'istration and +mmi'rant

Certificate of Re'istration of ___ are hereto attached as *NN0L0! $B% and $C% and made inte'ral part of the herein P0,+,+?N. P0,+,+?N0R ___ is a Filipino citiIen by birth. ,he P0,+,+?N0R! have decided to establish their family home in ___ and they have been livin' thereon as husband and -ife for ____ years. C1D ,he P0,+,+?N0R! have no le'itimate children by their marria'e or

descendants and hereby desire to ;ointly adopt t-o 2/3 abandoned minor children namely _____________, 1 years old, le'itimate child of !pouses ____________ and _______________ and _______________, / years old, le'itimate child of !pouses ___________ and ___________________. C4D Prior to this adoption proceedin's, the above-named minor children -ere abandoned by their respective parents and -ere ta6en care of and under the care and custody of !t. ___________ in !um-a', Bacolod City, Ne'ros ?ccidental, Philippines, and the -hereabouts of their respective parents are un6no-n. C5D ,hat the P0,+,+?N0R! are 8ualified to adopt the said minor children and have sufficient income and properties to financially and morally brin' up and educate said minor children, properly and ade8uately. C7D )ast ___, the _____________ si'ned ___________ and the custody and care of the above-named minor children -ere released and transferred by __________ to the herein P0,+,+?N0R!. *s of the filin' of the herein P0,+,+?N, the P0,+,+?N0R! have been e&ercisin' parental custody to _______________ and ___________ and a preadoption measure to ensure that the P0,+,+?N0R! are properly and ade8uately capable of performin' their obli'ations ad adoptin' parents to the aforementioned minor children. >(0R0F?R0, premises considered, it is most respectfully prayed of this (?N?R*B)0 C?@R, that upon due notice and hearin', ;ud'ment be entered ad;ud'in' that the minor children, namely _____________ and ____________________ be freed from all le'al obli'ations of obedience and maintenance -ith respect to their respective natural parents, and that they be declared to all le'al intents and purposes, the child of the herein P0,+,+?N0R!, and that their surname be chan'ed to that of the P0,+,+?N0R!.

!uch other and further relief and remedies ;ust and e8uitable under the premises. Bacolod City for Ba'o City, Philippines, this ____________.

Counsel for the Petitioners 2K0R+F+C*,+?N *N# C0R,+F+C*,+?N ?F N?N-F?R@" !(?PP+NA3 Copy furnished ,(0 !?)+C+,?R A0N0R*) ?ffice of the !olicitor Aeneral 114 *morosolo !t., )e'aspi Killa'e 1//= "a6ati City #ate _________________ Re'istry Receipt No. __________JBacolod City Post ?ffice ,(0 N*,+?N*) C0N!@! *N# !,*,+!,+C! ?FF+C0 0ast *venue, MueIon City #ate _________________ Re'istry Receipt No. __________JBacolod City Post ?ffice ?FF+C0 ?F ,(0 C+,B C+K+) R0A+!,R*R Bacolod City, Ne'ros ?ccidental By _____________________ #ate ___________________ #0P*R,"0N, ?F !?C+*) >0)F*R0 *N# #0K0)?P"0N, By _____________________ #ate ___________________ 0LP)*N*,+?N ,he fore'oin' P0,+,+?N is copy furnished to the ?ffice of the !olicitor Aeneral and the National !tatistic ?ffice via re'istered mail, instead of personal delivery, due to the distance of the address of the addressee -ith that of the undersi'ned.

Counsel for the Petitioners

<. "otion 2Case ,itle3

MOTION FOR POSTPONEMENT ,he Plaintiff, thou'h the undersi'ned counsel, before this (onorable Court, most respectfully states that 1. ,he above case is set for hearin' on ____ at < 1E in the mornin'. /. (o-ever, the undersi'ned counsel is already scheduled to attend the pre-trial of Civil Case No. ______ , entitled ____ before the Re'ional ,rial Court, Branch 4<, Bacolod City on the said date and time. 1. Considerin' the nature of the proceedin' in Civil Case No. ___ and the fact that it -as set earlier than the hearin' of the instant case, the plaintiff is constrained to re8uest for a resettin' to such other dates most convenient -ith the (onorable Court, preferably on the last -ee6 of *pril /EE<. 4. ,his motion is not intended to delay the prompt disposition of the above case. WHEREFORE, in vie- of the fore'oin', the plaintiff most respectfully prays that the hearin' on ____ be moved to !eptember 1E, /EE9 at < 1E in the mornin' or to another date most convenient -ith this (onorable Court, preferably on the last -ee6 of *pril /EE<. !uch other relief and remedies ;ust and e8uitable in the premises are li6e-ise prayed for.

Bacolod City for !ipalay City, Philippines, this /9th day of *u'ust /EE9.

Counsel for the Plaintiff THE CLER- OF COURT ",CC !ipalay City Counsel for the #efendant GREETINGS$ ,he Plaintiff is submittin' the fore'oin' "otion for Postponement for the consideration of the (onorable Court on ______ at < 1E o:cloc6 in the mornin', -ithout further oral ar'ument and presence of counsel.

Counsel for the Plaintiff Copy furnished to Counsel for the #efendant *ddress By ________________ #ate ______________ 0LP)*N*,+?N ,he instant motion -as filed -ith the (onorable Court via re'istered mail due to distance, thus, ma6in' personal service impracticable.

Counsel for the Plaintiff

=. 0&-Parte "otion

E,-PARTE MOTION TO SET THE CASE FOR PRE-TRIAL

PLAINTIFF, throu'h the undersi'ned counsel, before this (onorable Court, most respectfully states that C1D ,he #efendant -as served -ith !ummons and a copy of the Complaint in

the above case on _____ but up to the filin' of the instant motion, the defendant failed to file her *ns-er despite the lapse of the re'lementary period for filin' thereof. C/D !ection 1, Rule 1< of the 1==9 Rules of Civil Procedure provides that after

the last pleadin' has been served and filed, it shall be the duty of the plaintiff to promptly move e&-parte that the case be set for pre-trial. WHEREFORE, premises considered, the plaintiff respectfully prays that the above case be set for pre-trial on any date most convenient -ith the (onorable Court, preferably on _____ at < 1E o:cloc6 in the mornin'. Bacolod City for Oaban6alan City, Philippines, this ___.

Counsel for the Plaintiff

THE BRANCH CLER- OF COURT R,C, Branch 71 Oaban6alan City GREETINGS$ Please submit the fore'oin' 0&-Parte "otion to !et the Case for Pre-,rial immediately upon receipt hereof.

Counsel for the Plaintiff

E,PLANATION ,he fore'oin' 0&-Parte "otion to !et the Case for Pre-,rial -as filed before this (onorable Court throu'h re'istered mail due to distance.

Counsel for the Plaintiff

1. Complaint for e;ectment Republic of the Philippines M*n)&).a' T#)a' C *#( (ini'aran, Ne'ros ?ccidental _______________, Plaintiff, - versus __________________, #efendants. &----------------------------& COMPLAINT COMES NOW PLAINTIFF, throu'h the undersi'ned counsel, before this (?N?R*B)0 C?@R, most respectfully states that C1D PLAINTIFF is of le'al a'e, Filipino, married and a resident of Bacolod City, Ne'ros ?ccidental, Philippines, -here she may be served -ith pleadin's, orders and other processes of this (onorable Court. C)/)' Ca0% N " __________ For @nla-ful #etainer 1M%d)a(ab'%2

C/D DEFENDANTS are all of le'al a'e, Filipinos, married and residents of (ini'aran, Ne'ros ?ccidental, Philippines, -here they may be served -ith summons and a copy of the Complaint, court orders, and other processes. C1D ,he P)*+N,+FF is the re'istered o-ner of a parcel of land located at (ini'aran, Ne'ros ?ccidental, Philippines, and more particularly described as follo-s 2insert description of lot3 ,he photocopy of the ,ransfer Certificate ,itle No. ,- ___ is hereto attached as *nne& $*: and made an inte'ral part hereof. C4D ,he #efendants -ere allo-ed to build their houses on portions of the

above-described property by the plaintiff:s late mother durin' her lifetime on the condition that said that they -ould vacate the premises -hen the o-ner should demand them to vacate. C5D !ometime in "ay /EE7, the plaintiff informed the defendants that she no-

need the property as she -ill be developin' it to a beach resort. C7D ,he defendants openly ob;ected to vacate the area and manifested to the

plaintiff:s attorney-in-fact that they -ill only leave -hen there is a court order. C9D Conse8uently, plaintiff referred the matter to her undersi'ned counsel -ho

sent final demand letters to vacate dated Gune 17, /EE7 to all the defendants by re'istered mail. #efendants received the aforementioned demand on the same date, Gune //, /EE7. ,he photocopies of the final demand letters to vacate dated Gune 17, /EE7, Certification dated /E !eptember /EE7 issued by the Postmaster of (ini'aran, Ne'ros ?ccidental, are hereto attached as *nne&es ______, respectively, and made inte'ral parts hereof. C<D ,he period of fifteen 2153 days from receipt of the demand -ithin -hich

defendants are bein' demanded to vacate the portion of the sub;ect property -hich they are occupyin' has lon' lapsed, yet, the defendants continue to occupy the disputed premises and obdurately and contumaciously refuse to vacate the same up to the filin' of the instant Complaint, to the 'reat dama'e and pre;udice of the plaintiff.

C=D ,he Plaintiff is entitled to the restitution of the premises and the sum ;ustly due to her as reasonable compensation for the use and occupation of the premises in the amount of P0!?! ?N0 ,(?@!*N# 2P1,EEE.EE3, Philippine currency, per month from each of the #efendant counted from Gune //, /EE7 -hen defendants: occupation, use and possession of the portion of plaintiff:s property became unla-ful up to the time that #efendants, their family members, a'ents and cohorts vacate the premises. C11D Prior to the filin' of the instant Complaint, the plaintiff referred the matter to the ?ffice of the )upon' ,a'apamayapa of Baran'ay _____, (ini'aran, Ne'ros ?ccidental. No amicable settlement bet-een the parties -as reached, hence, )uponJPan'6at Chairman of Baran'ay ________, (ini'aran, Ne'ros ?ccidental a Certificate to File *ction dated *u'ust 17, /EE7, the photocopy of -hich is hereto attached as *nne& $F% and made an inte'ral part hereof. C11D ,he instant controversy -as filed by the Plaintiff -ithin one 213 year from the defendants: receipt of plaintiff:s final demand letter to vacate dated Gune 17, /EE7.

PRAYER WHEREFORE, premises considered, it is most respectfully prayed of this (onorable Court that ;ud'ment be rendered in favor of the plaintiff and a'ainst the defendantsC1D DIRECTING the #efendants, their family members, a'ents and cohorts

to vacate the premises in dispute and to order the demolition of any structure or improvements that they have built thereon. C/D DIRECTING each of the #efendants to pay to the Plaintiff the reasonable compensation for their use of the property in the amount of P0!?! ?N0 ,(?@!*N# 2P1,EEE.EE3, Philippine currency, per month counted from Gune //, /EE7 -hen defendants: occupation, use and possession of portions of plaintiff:s property became unla-ful up to the time that #efendants, their family members, a'ents and cohorts vacate the portion of the disputed premises -hich they respectively occupy.

C1D !uch other and further relief and remedies ;ust and e8uitable under the premises are li6e-ise prayed for. Bacolod City for (ini'aran, Ne'ros ?ccidental, Philippines, this /9 th day of ?ctober /EE7.

Counsel for the Plaintiff

2>ith VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING by .'a)n()!!3

4. motion to 8uash

"?,+?N ,? M@*!( C?"0! N?> the *ccused, throu'h the undersi'ned counsel, before this (onorable Court, most respectfully states that C1D ,he *ccused has not yet been arrai'ned. @nder !ection 1, Rule 119 of the

Revised Rules of Criminal Procedure, at any time before enterin' his plea, the accused may move to 8uash the complaint or information. C/D *ccused is citin' as 'rounds for the dismissal of the above complaint,

para'raphs 2b3 and 2f3 of !ection 1, Rule 119 of Revised Rules of Criminal Procedure, -hich state that $ !ection 1. Arounds F ,he accused may move to 8uash the complaint or information on any of the follo-in' 'rounds 2a3 & & & & & 2b3 ,hat the court tryin' the case has no ;urisdiction over the offense char'e or the person of the accused. 2c3 & & & & & 2d3 & & & & & 2e3 & & & & &

2f3 ,hat the criminal action or liability has been e&tin'uished. 2'3 & & & & & 2h3 & & & & & $

ARGUMENTS AND DISCUSSION ,he *ccused is char'ed of the crime of )ess !erious Physical +n;uries 2@nder *rticle /75, para'raph 1 of the Revised Penal Code3 in relation to R.*. <17=. ,he *mended +nformation dated Guly 1, /EE/ in the above case states $,hat on or about the 4th day of *u'ust /EE1, in the City of Bacolod, Philippines, and -ithin the ;urisdiction of this (onorable Court, the herein accused, -ithout any ;ustifiable case or motive, did, then and there -illfully, unla-fully and feloniously assault, attac6 and stab -ith a bladed -eapon one ____, thereby inflictin' upon the person of the latter the follo-in' -ound, to -it P0R)*, 0?" intact. 1/ cm. +ncised -ound left parieto-occipital area. 4 cm. +ncised -ound occipital area. / cm. +ncised -ound biceps. / cm. +ncised -ound ri'ht paravertebral level ,/. 1 cm. +ncised -ound P*) 4th +.C.!. left

-hich re8uired medical attendance for a period of fifteen 2153 days -ithin -hich to heal. *ct contrary to la-. $ ,he alle'ed crime too6 place sometime in 4 *u'ust /EE1 but the *mended +nformation dated 1 Guly /EE/ -as filed before this (onorable Court only on Guly 5, /EE/ or about eleven 2113 months after the alle'ed commission of the crime. *rticle =E of the Revised Penal Code provides that li'ht offenses, -hich include the crime of sli'ht physical in;uries, prescribe in t-o 2/3 months. +n addition thereto, *rticle =1 of the Revised Penal Code states that computation of prescription of offenses is computed as follo-s $,he period of prescription shall commence to run from the day on -hich the crime is discovered by the offended party, the authorities or their a'ents, and shall be interrupted by the filin' of the complaint or information, and shall commence to run a'ainst -hen such proceedin's

terminate -ithout the accused bein' convicted or ac8uitted, or are un;ustifiably stopped for any reason not imputable to him. &&&&&$ *s the above *mended +nformation -as filed after the lapse of the t-o 2/3 months prescriptive period or about eleven 2113 months after the alle'ed commission of the crime, the criminal liability had already been e&tin'uished. Conse8uently, this (onorable Court, -ith all due respect, has no authority to entertain the above-entitled case for it is barred by the statute of limitations. * court can only ac8uire ;urisdiction to try a criminal case upon compliance of the re8uirements stated hereunder, as specified in the case of Gibin *rula vs. Bri'adier Aeneral Romeo C. 0spino, et. al. 2/< !CR* 54E, 5793, to -it $T .a#a.4#a0%$ b%y nd (4% .a'% ! d)0a+#%%5%n( )0 (4% '%+a' (%n%( (4a( a & *#( a&6*)#%0 7*#)0d)&() n ( (#y a &#)5)na' &a0% n'y w4%n (4% ! '' w)n+ #%6*)0)(%0 & n&*#$ 893 (4% !!%n0% )0 n% w4)&4 (4% & *#( )0 by 'aw a*(4 #):%d ( (a;% & +n):an&% !, 8<3 (4% !!%n0% 5*0( 4a/% b%%n & 55)((%d w)(4)n )(0 (%##)( #)a' 7*#)0d)&() n, and 8=3 (4% .%#0 n &4a#+%d w)(4 (4% !!%n0% 5*0( 4a/% b%%n b# *+4( )n ( )(0 ! #*5 ! # (#)a', ! #&)b'y by wa##an( ! a##%0( # *. n 4)0 / '*n(a#y 0*b5)00) n ( (4% & *#(" > > > > > 8Und%#')n% 0*..')%d ! # %5.4a0)03 >(0R0F?R0, premises considered, the *ccused respectfully prays that the above criminal case be dismissed for havin' prescribed. !uch other relief and remedies are li6e-ise prayed for. Bacolod City , Ne'ros ?ccidental this 1Eth day of ?ctober /EE/.

Counsel for the *ccused

THE BRANCH CLER- OF COURT Branch +++, ",CC (all of Gustice Aatuslao !t., Bacolod City THE HON" CITY PROSECUTOR ?ffice of the City Prosecutor 1rd Floor (all of Gustice

Aatuslao !t., Bacolod City GREETINGS$ ,he *ccused shall be submittin' the instant "otion for Reconsideration for the consideration and resolution of the (onorable Court on "arch /, /EE9 at < 1E o:cloc6 in the mornin'.

LEON G" MOYA, ?R"

Copy furnished to

THE HON" CITY PROSECUTOR ?ffice of the City Prosecutor 1rd Floor (all of Gustice Aatuslao !t., Bacolod City 4. +nfoJestafa

+NF?R"*,+?N ,hat on or about the ___________ and prior and subse8uent thereto, in the City of Bacolod, Philippines, and -ithin the ;urisdiction of this (onorable Court, the herein accused, bein' then the o-ner of a 2motor vehicle3, and 6no-in' fully -ell that he has previously sold it to ___________, did, then and there -illfully, unla-fully and feloniously enter into a contract of sale of said property for the amount of _________ -ith the herein offended party, __________, by falsely representin' that he still o-n the property and the said offended party relyin' on the representations of the accused, -illin'ly purchased the said property and had already paid the total amount of ________ -hen he came to 6noabout the said fact, to the dama'e and pre;udice of the said offended party in the total amount of __________. *ct contrary to la-. 2Bold hi'hli'ht supplied.3