Professional Documents
Culture Documents
Entry of Appearance As Counsel: Republic of The Philippines Family Court Branch 9
Entry of Appearance As Counsel: Republic of The Philippines Family Court Branch 9
Respondent,
x--------------------------------------------------x
-Versus-
BOGS DAGOHOY,
Defendant.
x----------------------------------------x
WITHDRAWAL OF COUNSEL WITH SUBSTITUTION
THE CLERK OF COURT
Regional Trial Court of the City of Baguio
Branch 10
ATTY. MARIA PHOENIX M. CHOA, counsel on record for the Defendant and to
this Honorable Court respectfully moves to withdraw as counsel of said defendant with
the express consent of said defendant as shown in this motion;
That in the substitution thereof, ATTY. AVERY CLAIRE L. DE MARCO, whose
services have been engaged by defendant hereby enters her appearance as counsel
for the defendant;
That upon approval of this Honorable Court, all pleadings, notices and papers in
connection with this case be addressed to new counsel ATTY. AVERY CLAIRE L. DE
MARCO with address at Unit 5C, 5th Floor PortaVaga Bldg., Session Rd., Baguio City.
Baguio City, Philippines, this 7th day of September, 2014.
OLD COUNSEL
ATTY. SHERYLLE T. ONG
Counsel for the Defendant
12 Quezon Hill, Baguio City
(074) 300- 3030 / 0923-2334423
PTR No. 050183/Baguio City/12-31-14
Roll of Atty. No. 73222
IBP Lifetime Membership No. 12344
MCLE Compliance No. 71234
NEW COUNSEL
ATTY. AVERY CLAIRE L. DE MARCO
Unit 5C, 5th Floor, PortaVaga Building
Session Road, Baguio City
(074) 421-8977/ 09475530284
PTR No. 157821; 1-15-10/Baguio City
Roll of Attorney No. 128948; 1-15-10/Baguio City
IBP Lifetime Membership No. 12900231;
Baguio-Benguet
MCLE No.II1-0000998/07-21-11
TIN: 189-789-754
PRAYER
WHEREFORE, PREMISES CONSIDERED, Eagle Eye Aviation, Inc. respectfully
requests that I-Temp Technology Inc., be cited to appear and answer and that, upon
final trial hereof, Plaintiff have the following:
1. Rescission of the Contract under which the Aircraft was sold from Defendant to
Plaintiff, including any ancillary agreements related thereto;
2. Damages sustained by the Plaintiff amounting to Php20,000,000.00
3. Costs of suit;
4. Attorneys fees.
2. That I have caused the preparation and filing of the foregoing Petition;
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 7 th day of
September 2014.
JOHN BRAD P. SMITH
Affiant
SUBSCRIBED AND SWORN to before me in the City of Baguio this 7th day of
September 2014 byJOHN BRAD P. SMITH, who has satisfactorily proven his identity to
me through his Passport No. SS787895421 valid until June 21, 2017, that he is the
same person who personally signed the foregoing affidavit before me and
acknowledged that he executed the same.
Doc.Notary
No. Public
47;
31-14
Roll No. 73222
Page No. 09 ;
Baguio
City, Philippines
Book No.
01;
12344
Series of 2014.
71234
__________________________________
ATTY. SHERYLLE T. ONG
Notary Public for the City of Baguio
until December 31, 2014
12 Quezon Hill, Baguio City
Com. No. 2014 - 023
PTR No. 050183/Baguio City/12Roll of Atty. No. 73222
IBP Lifetime Membership No.
MCLE Compliance No.
6. That, for the preparation of said project-plan of partition, plaintiff paid said Engr.
Gilbert M. Mangliwan the sum of P25,000.00 which is the reasonable
compensation for the latters services;
7. That notwithstanding repeated demands of plaintiff, defendant refused and still
refuses, without justifiable cause or reason, to accede to the partition of said
property;
PRAYER
WHEREFORE, it is respectfully prayed that judgment issue:
1. Ordering the partition of the parcel of land mentioned and described in Paragraph
2 of this complaint, adopting for the purpose of said partition, the project-plan
prepared by Engr. Gilbert M. Mangliwan, copy of which will be presented at the
day of the trial;
2. Ordering that the determination as to which of the two (2) parcels in said projectplan should pertain to either party be done by the choice of the parties, and,
should they pick the same lot, that it be done by lottery;
3. Ordering defendant to execute and sign all necessary papers or deeds which
shall give validity and effect to this partition;
4. Ordering defendant to pay plaintiff the sum of P12,500.00 which is equivalent to
50% of the amount paid by plaintiff to the licensed surveyor for the preparation of
the project-plan;
5. Other reliefs just and equitable under the premises are likewise prayed for.
Respectfully submitted this 7th day of September 2014, done in the City of Baguio,
Philippines.
ATTY. DEANNE C. MANADAO
Counsel for Plaintiff
Unit 3B, 3rd Floor, Porta Vaga Building
Session Road, Baguio City
(074) 422-4388/ 09057037608
PTR No. 052108; 1-15-10/Baguio City
Roll of Attorney No. 808310; 1-15-10/Baguio City
IBP Lifetime Membership No. 1029338; Baguio-Benguet
REPUBLIC OF THE PHILIPPINES }
DONE: IN THE CITY OF BAGUIO } S.S.
X ============================ X
VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING
I, JODEA RUTH S. MARTIN, after having been duly sworn to in accordance with
law, hereby depose and state:
5. That I am of legal age, Filipino citizen and a resident of # 245 Military Cut-Off
Road, Baguio City, Philippines;
6. That I have caused the preparation and filing of the foregoing Petition;
7. 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;
8. 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 7 th day of
September 2014.
JODEA RUTH S. MARTIN
Affiant
SUBSCRIBED AND SWORN to before me in the City of Baguio this 7th day of
September 2014 by JODEA RUTH S. MARTIN, who has satisfactorily proven her
identity to me through herPassport No. MM89214589valid until November 30, 2015, that
she is the same person who personally signed the foregoing affidavit before me and
acknowledged that she executed the same.
__________________________________
Doc.Notary
No. Public
47;
31-14
Roll No. 73222
Page No. 09 ;
Baguio
City, Philippines
Book No.
01;
12344
Series of 2014.
71234
-versusANTONETTE G. GUANZON
Defendant.
x--------------------------------------------------x
COMPLAINT
WITH UTMOST DEFERENCE TO THE HONORABLE COURT:
PLAINTIFF, by and through undersigned counsel, respectfully state:
1. Plaintiff is a corporation duly organized and existing under Philippine Laws, having its
principal office at #21 Harrison Road, Baguio City, Philippines;
2. That defendant is of legal age, Filipino, and a resident of No. 45 Lower Brookside,
Baguio City, Philippines, where she may be served with summons and other Court
processes;
3. That on July 25, 2011, the defendant obtained a loan from the plaintiff in the sum of
Php50,000.00 (FIFTY THOUSAND PESOS) to be fully paid on October 25, 2011, as
evidence by a Promissory Note executed on October 25, 2011, a copy of which is
hereto attached as Annex A;
4. That the defendant was able to pay only the amount of Php2,500.00 from the
principal amount and despite the lapse of period to pay the loan, the defendant
failed to pay her total obligation thereby entitling the plaintiff to be paid of the unpaid
principal in addition to the agreed 30% per annum by way of interest and 30% per
annum by way of penalty, a copy of Statement Account is hereto attached as Annex
B and made an integral part hereof;
5. That said loan now long overdue despite of repeated demands and she failed and
refused and continue to fail and refuse to pay the FLOR-ANN
same as evidenced
by the
A. CAJAYON
Demand Letter sent by the Banks Legal Counsel, a copyNotary
of which
is
Public hereto
attached as Annex C;
3F Piao Yan Bldg., Bonifacio St.,
Baguio City
6. That repeated demands were madefor the defendant to Tel.
pay her
obligation
but failed
No.:(074)
434-9870
to pay.
PTR No. 98765; 1/03/2014; Baguio City
IBP OR No.: 98567; 1/03/13; Baguio City
Roll of Attorneys No. 317120; 3/18/2004
Commission Serial No.: 56-NC-12
MCLE Compliance No.: IV-36286; 4/28/12
TIN No: 226-753-759
PRAYER
WHEREFORE,Plaintiff respectfully prays for judgment in its favour through a
Decision directing the defendant:
a. To pay Plaintiff the sum of (Php47,500) FORTY SEVEN THOUSAND FIVE
HUNDRED PESOS with interest at 30% as penalty from July 25, 2011 until the full
amount is paid;
b. Attorneys Fees of Php45,000;
c. The cost of this suit.
10. That I have caused the preparation and filing of the foregoing Complaint;
11. 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;
12. 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 7 th day of
September 2014.
CHERRY D. GUZMAN
Affiant
SUBSCRIBED AND SWORN to before me in the City of Baguio this 7th day of
September 2014 byCHERRY D. GUZMAN, who has satisfactorily proven her identity to
me through her Professional Drivers License No. A01-45789valid until November 28,
2014, that she is the same person who personally signed the foregoing affidavit before
me and acknowledged that she executed the same.
Doc.Notary
No. Public
47;
31-14
Roll No. 73222
Page No. 09 ;
Baguio
City, Philippines
Book No.
01;
12344
Series of 2014.
71234
__________________________________
ATTY. SHERYLLE T. ONG
Notary Public for the City of Baguio
until December 31, 2014
12 Quezon Hill, Baguio City
Com. No. 2014 - 023
PTR No. 050183/Baguio City/12Roll of Atty. No. 73222
IBP Lifetime Membership No.
MCLE Compliance No.
-versusJANICEMONTRERAS CRUZ,
ALBERT L. CRUZand
THE REGISTER OF DEEDS,
Baguio City,
Defendants.
x-----------------------------------------------x
COMPLAINT
Plaintiff, through counsel and unto this Honorable Court, most respectfully states:
1. That Plaintiff is of legal age, Filipino citizen, widow, a permanent employeeof GSIS Baguio
City Branch, and a resident of #43 2nd Road, Quezon Hill, Baguio City, Philippines, while
herein Defendant Janice Montreras Cruz is of legal age, jobless and presently residing at #31
Magsaysay Road, Baguio City married to her co-Defendant Albert L. Cruz, who is hereby
impleaded pursuant to the provisions of the New Rules of Court; the Register of Deeds of
Baguio City is likewise impleaded in this action in his official capacity as such Register of
Deeds of Baguio City with office address at 3 rd Floor, City Hall Bldg., Baguio City where they
may be served with summons;
2. That the herein Plaintiff is the sister of Defendant Janice Montreras Cruz with whom the said
Defendant stayed and grew since she was a small girl until she got married to her coDefendant Albert L. Cruz sometime in October 2011;
3. That sometime in the month of April 2005, herein Plaintiff was offered to buy the lot she was
renting from the Spouses Coco M. Dela Cruz and Erich G. Dela Cruz and after the said
Plaintiff considered the offer, she decided to buy the same for future use of heronly child,
Margaux Rose Rivera, who was then only about 10 years of age, the value of which property
is more or less ONE HUNDRED FIFTY THOUSAND PESOS (Php150,000.00);
4. That since Margaux Rose Rivera was still a minor then, the Plaintiff was advised that the title
cannot be transferred in her name yet, and so to give her sister some sort of encouragement
in life and in order to develop the personality of her sister, Janice, she decided to transfer the
title in her name as per the herein attached photocopy of the Title No. T-89712 with the
understanding that it will be transferred in the name of Margaux Rose Rivera as soon as he
reaches the age of majority;
5. That when Margaux Rose Rivera, the only child of the Plaintiff finally reached her age of
majority, the herein Plaintiff suggested to her sister to transfer the title to her daughter, but
through the convincing words of Janice when she begged that it be done later for it will be
very embarrassing to her suitors and besides, they are sisters and she would never fool her,
Plaintiff acceded to the request and allowed the same property to remain registered in the
name of her sister;
6. That having considered the request of Janice to be valid and her earnest desire to help her
sister by giving her some sort of encouragement in life and to develop her personality, the
Plaintiff without any slight suspicion that her sister whom she reared and cared for since she
was a child until she got married at the mature age of 30 years old would someday be
afflicted with greediness, she acceded to allow the same parcel of land to remain registered
in her name;
7. That when the herein Plaintiff bought the property from the above named spouses, Coco M.
Dela Cruz and Erich G. Dela Cruz and even up to the present, Janice Montreras Cruz has
never been gainfully employed so as to be in the position to buy any piece of real property
and all the time, until she got married sometime in October 2011, she was a complete
dependent of the Plaintiff;
8. That recently, the herein Plaintiff experienced the biggest and humiliating surprise in her
whole life when the same Defendant demanded her to vacate the premises and the same
Defendant is now claiming the property to be her property and even went out to the extent of
dragging her sister-Plaintiff to the authorities;
9. That being sister, Plaintiff did almost everything to the extent of begging from the Defendant
Janice Montreras Cruz to cause the Transfer of Title of the above property to the name of her
10.
11.
12.
13.
14.
only child, Margaux Rose Rivera, as the same property was really intended for her, but the
same Defendant vehemently refused and instead claims in bad faith absolute ownership
thereto to the prejudice of the Plaintiff;
That the above arrangement that led to the registration of title in the name of Defendant
Janice Montreras Cruz was known to the sellers of the property and other witnesses then,
such as Assistant Prosecutor Jason G. Araullo of the Prosecutors Office of Baguio City;
That despite of the Plaintiff having done everything possible as to convince her sister to
return to her the above described real property, the same Defendant failed and vehemently
refused to accede, thus, the Plaintiff was left with no other choice and had to take this last
recourse of bringing the case to the Court, and in the process she was constrained to engage
the services of the undersigned counsel with whom she agreed to pay a reasonable amount,
which we leave to the sound discretion of this Honorable Court to determine, for and by way
of attorneys fees;
That by the reason of the refusal of the Defendant Janice Montreras Cruz to return the
property to the Plaintiff, herein Plaintiff suffered sleepless nights, mental anguish, wounded
feelings and other form of moral damages, for which the Defendant should be held liable to
the Plaintiff for such amount, which we likewise leave to the sound discretion of this
Honorable Court to determine for and by way of moral damages;
That to set an example to others under the same situation, the Defendant should be made
liable to pay the Plaintiff a certain sum which we leave to the sound discretion of this
Honorable Court to determine for and by way of exemplary damages;
That there being no other way by which herein Plaintiff could enforce her right and protect her
interest as she had already exhausted all the possible remedies until she was left with no
other choice but to bring the case to court, the same Defendant should be made liable to pay
the costs of the suit.
PRAYE R
WHEREFORE, in view of the above premises, it is most respectfully prayed of this Honorable
Court that after due hearing of this case, the Honorable Court shall render a decision in favour of the
Plaintiff and against the Defendant:
1. By finding the plaintiff to be the lawful owner of the above described property;
2. By ordering the defendant, the Register of Deeds of Baguio City, to cancel the Transfer
Certificate of Title No. T-89712 covering the above real property involved, and that the
same defendant Register of Deeds of Baguio City be ordered to issue another Transfer
Certificate of Title to recover the same property in favour of and in the name of herein
plaintiff;
3. By ordering the defendants Janice and Albert Cruz to pay jointly and severally the plaintiff
of certain sum the amount of which we leave to the sound discretion of this Honorable
Court to determine as reasonable as attorneys fees;
4. By ordering the defendants Janice and Albert Cruz to pay jointly and severally the plaintiff
of certain sum the amount of which we leave to the sound discretion of this Honorable
Court to determine for and by way of moral damages;
5. By ordering the defendants Janice and Albert Cruz to pay jointly and severally the plaintiff
of certain sum the amount of which we leave to the sound discretion of this Honorable
Court to determine for and by way of exemplary damages;
6. By ordering the defendants Janice and Albert Cruz to pay jointly and severally, the costs
of suit, and plaintiff further prays for some other reliefs that may be just and equitable
under the premises.
Baguio City, Philippines, this 7th day of September 2014.
ATTY. DEANNE C. MANADAO
Counsel for Plaintiff
Unit 3B, 3rd Floor, Porta Vaga Building
Session Road, Baguio City
(074) 422-4388/ 09057037608
PTR No. 052108; 1-15-10/Baguio City
Roll of Attorney No. 808310; 1-15-10/Baguio City
IBP Lifetime Membership No. 1029338; Baguio-Benguet
Doc.Notary
No. Public
47;
31-14
Roll No. 73222
Page No. 09 ;
Baguio
City, Philippines
Book No.
01;
12344
Series of 2014.
71234
__________________________________
ATTY. SHERYLLE T. ONG
Notary Public for the City of Baguio
until December 31, 2014
12 Quezon Hill, Baguio City
Com. No. 2014 - 023
PTR No. 050183/Baguio City/12Roll of Atty. No. 73222
IBP Lifetime Membership No.
MCLE Compliance No.
-versus-
ANDREI D. ARAULLO,
Respondent.
x----------------------------------------------------x
PETITION
WITH ALL DUE RESPECT to the Honorable Court, Petitioner through counsel
respectfully alleges that:
1. That the petitioner, SAMANTHA TAYLOR-ARAULLO, is of legal age, Filipino
Citizen, with residence and postal address at No. 89 M. Roxas St., Lower
Brookside, Baguio City where she may be served with summons and other
processes of the Honorable Court;
2. That the respondent, ANDREI D. ARAULLO, is also of legal age, Filipino
Citizen, with residence and postal address at No. 18 Purok 3, TandangSora,
CamdasSubd., Baguio City where he may be served with summons and other
processes of the Honorable Court;
3. That she and the respondent are wife and husband, who were married in a
civil ceremony officiated by Honorable Janice Toni G. Guitelen, Presiding
judge of the Regional Trial Court of Baguio City, Branch 21, on August 21,
2000, which was solemnized according to Roman Catholic rites officiated by
Reverend Father Mike Seys, CICM, on August 21, 2001 at St. Anthony de
Padua Church in Pacdal, Baguio City. A copy of their marriage contract is
hereto attached as Annex A and made an integral part hereof;
4. A year later, she gave birth to the children of respondent, namely, Alessandra
Rose, 11 years old, born on January 1, 2002 and Atasha Jewel, 9 years old,
born on September 14, 2004. Both are enrolled at Berkeley School at No. 30
CM Recto Road, Navy Base, Baguio City;
5. By their joint efforts and industry, petitioner and respondent acquired real and
personal properties consisting of 5,000 square meters residential land,
located along RichviewSubd., Bakakeng, Baguio City, covered and described
in TCT No. T-1112 (Annex B) issued by the City Registrar of Baguio, and
registered both in their names; 10,000 square meters of agricultural land in
Tarlac, covered and described in TCT No. T-1212 (Annex C) issued by the
Registry of Deeds of Tarlac and registered both in their names; residential
house and lot at Maria Basa, Pacdal, Baguio City, four sets of computer, two
sets of laptop, four television set, one Starex Van with Plate no. CAD 214,
one ToyotaFortuner with Plate no. TXS 189, and other personal properties;
6. Few months later after Atasha Jewel was born, the respondent showed acts
of marital irresponsibility. He started to stay out late at night; he started to
drink heavily alcoholic beverages; he continually became irritable and picked
quarrels or blurted verbal abuses at every turn while at home. As months
passed, his behavior worsened from bad to worse. He came home in the wee
hours of the morning, drunk, irrational in many ways in his utterances and
actions to a point that, on many occasions, he inflicted physical violence
coupled with verbal abuse, for no apparent reason, so much so that the
petitioner suffered physical injuries, mental anguish, emotional distress and
she could hardly have a restful sleep on any given night. She lost weight. She
became morose. She was almost always on pins and needles. Lately,
respondent would leave the conjugal home for days on end. Petitioner found
out that respondent is living with another woman at No. 18 Purok 3,
TandangSora, CamdasSubd., Baguio City. Respondent stopped giving
support to the petitioner and his two children. Having discovered the infidelity
of the respondent she had consult with a marriage counselor, a psychiatrist,
and her confessor and sought their advice.
7. By the last week of March 2012, respondent abandoned the conjugal home.
She learned later from well-meaning and concerned friends and relatives that
respondent is living for some time with his common-law wife, Trisha Vargas,
without any justifiable reason, with whom respondent has begot a baby boy
who was christened Trina.
8. Respondent is a well-known practicing lawyer, engaged in the litigation of
corporate, land disputes, high profile criminal cases, in the City of Baguio and
the surrounding municipalities and provinces, and is retained legal counsel by
five Corporations in La Union, on a monthly retainer, where he derives a
monthly income of P100,000.00 from which respondent can well afford to
support Alessandra Rose, Atasha Jewel, and the petitioner.
9. Petitioner, a part- time law professor at the University of the Cordilleras who
derived a monthly income of P20,000.00 is on leave for the school year 20112012, when the behavior of respondent palpably worsened, to take care of
Alessandra Rose and Atasha Jewel because their two household help left
them. She took over the daily chores of the house. She is not gainfully
employed right now and no income to meet the daily expenses of her two
children and other necessary expenses.
PRAYER
WHEREFORE premises considered, the Petitioner prays that after due hearing
judgment be rendered declaring a decree of legal separation between petitioner and
respondent, ordering the liquidation of the conjugal property and requiring the
respondent to give support to petitioner and her two children until they reached the
majority age or until they finished their college education, in such amount as the
Honorable Court may reasonably fix.
Petitioner further prays for such reliefs equitable and available as provided in law
and as may be just and fair under the premises.
Respectfully submitted this 7th day of September 2014 in the City of Baguio.
Doc.Notary
No. Public
47;
31-14
Roll No. 73222
Page No. 09 ;
Baguio
City, Philippines
Book No.
01;
12344
Series of 2014.
71234
__________________________________
ATTY. SHERYLLE T. ONG
Notary Public for the City of Baguio
until December 31, 2014
12 Quezon Hill, Baguio City
Com. No. 2014 - 023
PTR No. 050183/Baguio City/12Roll of Atty. No. 73222
IBP Lifetime Membership No.
MCLE Compliance No.
PRAYER
of Judgment are hereto attached as Annex B and Annex C, respectively, and the
envelope conatining the said documents is hereto attached as Annex D and made as
integral parts hereof;
10. That the said Judgment of Dissolution of Marriage and Entry of Judgment were sent to
counsel for Petitioner by the Superior Court of California as a response to the letter of
request sent by the undersigned counsel. Copy of the letter from the undersigned
counsel ias hereto attached as Annex E and made as integral parts hereof;
11. That as a consequence of the Judgment of Dissolution of Marriage of Petitioner and
Amanda Montejo Navarro, they are restored to status of single persons;
12. That there is a need for the judicial confirmation of the above-mentioned foreign
judgment of dissolution of marriage/divorce decree before it will be recognized in the
Philippines.
PRAYE R
WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court,
invoking hsutice and equity, that after publication, notice and hearing, judgment be rendered:
1. Recognizing the judgment of dissolution of marriage issued by the Superior Court of
California, County of Kern;
2. Ordering the Office of the Civil Registrar to make the necessary annotation on the
Marriage Certificate of Lawrence Danile F. Navarro and Amanda Montejo; and
declaring the Petitioner to be capacitated to remarry.
Other just and equitable reliefs are also prayed for.
Baguio City, Philippines, this 8th day of September 2014.
ATTY. DEANNE C. MANADAO
Counsel for Petitioner
Unit 3B, 3rd Floor, Porta Vaga Building
Session Road, Baguio City
(074) 422-4388/ 09057037608
PTR No. 052108; 1-15-10/Baguio City
Roll of Attorney No. 808310; 1-15-10/Baguio City
IBP Lifetime Membership No. 1029338; Baguio-Benguet
REPUBLIC OF THE PHILIPPINES}
DONE: IN THE CITY OF BAGUIO } S.S.
X ============================ X
VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING
I, LAWRENCE DANIEL F. NAVARRO, of legal age, Filipino, Filipino citizen and a
resident of #345 Maria Basa, Pacdal, Baguio City, Philippines and after having been duly sworn
to in accordance with law, do hereby depose and state:
6. That I am the petitioner in the above-entitled petition;
7. That I personally caused the preparation of the foregoing petition;
8. That I have read and understood the contents of the foregoing petition and the
allegations therein are true and correct to the best of my own personal knowledge
and belief based on authentic documents;
Doc.Notary
No. Public
47;
31-14
Roll No. 73222
Page No. 09 ;
Baguio
City, Philippines
Book No.
01;
12344
Series of 2014.
71234
__________________________________
ATTY. SHERYLLE T. ONG
Notary Public for the City of Baguio
until December 31, 2014
12 Quezon Hill, Baguio City
Com. No. 2014 - 023
PTR No. 050183/Baguio City/12Roll of Atty. No. 73222
IBP Lifetime Membership No.
MCLE Compliance No.