REPUBLIC OF THE PHILIPPINES

PHILIPPINE HEALTH INSURANCE CORPORATION

ARBITRATION DEPARTMENT
PASIG CITY

PHILIPPINE HEALTH
INSURANCE CORPORATION PHIC CASE NO. HCP-III-16-2143
Complainant, For: Misrepresentation by
Furnishing False or Incorrect
versus Information, Filing of Multiple
Claims and Breach of Warranties of
AWESOMENESS, INC., Accreditation under Sections 144,
Respondent 145 and 150 of the Revised IRR of
RA 7875 as amended by RA 9241

MOTION TO LIFT ORDER OF DEFAULT

Respondent AWESOMENESS, INC. (AWESOMENESS), by

undersigned counsel, and unto this Honorable Office, most respectfully
alleges:

1. Respondent AWESOMENESS received a copy of the Order

dated 1 April 2020 sometime in 15 April 2020

2. However, the copy of the Order dated 10 May 2020 was not
immediately brought to the attention of the Medical Director or any member
of the management.

3. Thus, the case was referred to counsel only recently.

4. Due to the gravity of the charges and the impending imposition

of stiff penalties by reason of the failure of the respondent to file its Answer,
it becomes necessary for the Honorable Office to give the respondent a
chance to answer the same.

5. The respondent has a meritorious defense as the subject of both

claims refers to one and the same confinement of patient JC T. Cruz from 21
February 2020 to 23 February 2020 and the filing of the second set of
documents on 21 March 2020 was brought about by a well-founded belief
the first set of documents filed on 14 March 2012 were actually missing and
not filed.

6. The foregoing motion is not intended for delay but solely for the
reasons stated herein.

1
 WHEREFORE, it is respectfully prayed that the Honorable Office to
lift the Order of Default.

Respectfully submitted. Angeles City for Pasig City this 1st day of May
2020.

AK FERNANDEZ
Law Offices
Counsel for the Respondent
123 P. Nuqui St.
CLM, Angeles City
(045) 458-1234 to 35

By:

ANTHONY KARL FERNANDEZ

Attorney's Roll No. _____/Vol. No. _____/Page _____
PTR No. _____/_____/Angeles City
IBP No. _____/_____/Pampanga
MCLE Compliance No.: _____/_____
Email Address: ak.fernandez85@gmail.com
Mobile: 0995-197-2715

Copy Furnished:
ATTY. RODOLFO LAT
PHIC-FFIED
City State Center Building,
709 Shaw Boulevard, Barangay Oranbo,
Pasig City