Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 30 Manila City

ZRC TRAINING CENTER PHIL., INC. Rep. by its President, RODELIO J. LAGAT, Plaintiff,

-versus-

Civil Case No. 11-126155

ARTURO T. SANTOS, Defendant. x-----------------------------------------------------------x

ANSWER TO REQUEST FOR ADMISSION

DEFENDANT Arturo T. Santos respectfully submits his Answer to plaintiffs Request for Admission, as follows: Will the defendant admit the existence and due execution of

1.

Certificates of Program Accreditation Certificate Nos. ACC-2010-169, ACC-2010219, ACC-2010-220, and ACC-2010-221 [Annex C of the Complaint];

ANSWER:

Yes. Will the defendant admit the existence and due execution of Show

2.

Cause Order dated May 31, 2011 of the Maritime Training Counsel (MTC) [Annex D of the Complaint];

ANSWER:

Yes Will the defendant admit the existence and due execution of the

3.

Monitoring Report dated July 4, 2011 of the Maritime Training Counsel (MTC) [Annex F of the Complaint]; ANSWER: Yes

2 4. Will the defendant admit the existence and due execution of the

Order dated July 5, 2011 of the Maritime Training Counsel (MTC) [Annex G of the Complaint];

ANSWER:

Yes

ARTURO T. SANTOS

SUBSCRIBED AND SWORN TO BEFORE ME, this 8th day of November 2011, at _________________, affiant exhibiting to me his Drivers License No: ________________________________ Notary Public

Doc. No. Page No. Book No. Series of 2011

Copy furnished: SARMIENTO TAMAYO BULAWAN LAW OFFICES Counsel for the Plaintiff Suite 29 3/F. Legaspi Towers 300 2600 Roxas Blvd., corner P. Ocampo St., Malate, Manila For lack of time and adequate personnel, counsel for plaintiff was furnished a copy of the above by registered mail.