31 August 2022

CASE UPDATE

Case Title: Norma K. Ayache, et. al. vs. Philippine Japan

Christian Mission, Inc.
Case Number: Civil Case No. 70071
Nature of the Case: Annulment of Deed of Sale, Reconveyance
and Cancellation of TCT No. 52754
Status: Presentation of Rodolfo Ayache
Forum: RTC Branch 264, San Juan City

Dear Ma’am Lourdes;

This is to confirm our appearance for today’s scheduled hearing. Counsel for the
Plaintiff and witness Rodolfo Ayache is likewise present.

When our case was called, we manifested our objection to the continuation of the
proceeding. We reiterated that the issue surrounding the death of the plaintiff Norma
Ayache as well as her substitution to the case was not yet settled by Court and we
emphasized that the continuance of the trial without resolving these critical issues first
may result to a procedural infirmity that could further delay the case. We also
manifested that we intend to file a motion for reconsideration on the Court's Order
allowing recall of Rodolfo Ayache.

The Court allowed the presentation of the plaintiff's witness considering that we
have not filed a Motion for Reconsideration yet and that there is no standing TRO or
injunction to put the proceeding on hold. We manifested then that we will not conduct a
cross examination in order not to adopt a contradictory stance to our objection.

After Rodolfo Ayache was presented as witness, the Court propounded some
clarificatory questions covering, among others, the following matters:

- The personal knowledge of Rodolfo Ayache on the agreement between his

parents and Mr. Sachico Yokogawa covering the subject property and any
considerations or payment involved.

- The personal knowledge of Rodolfo Ayache on the alleged simulation of a

contract of Deed of Absolute Sale between his parents and Mr. Yokogawa
covering the subject property.
 - The alleged excess in the area covered by the chapel constructed on the subject
property in violation of their agreement.

The next hearing for defendant's presentation of evidence is on Sept 13, 2022 at
9am. Should you have any question with respect to this case, please do not hesitate to
contact our office.

Sincerely Yours,

ATTY. EDUARDO L. REYES

For the firm

Noted by:

ATTY. KIM ANGERIE B. AGUILERA

Supervising Lawyer