The foregoing Position Paper is not filed to harass, cause unnecessary delay, or

needlessly increase the cost of litigation; and that the factual allegations therein have
evidentiary support, or if specifically so identified, have evidentiary support after a
reasonable opportunity for discovery;

That I further certify that: I have not theretofore commenced any other action or
proceeding or filed any claim involving the same issues or matter in any court, tribunal, or
quasi-judicial agency and, to the best of my knowledge, no such action or proceeding is
pending therein; if I should thereafter learn that the same or similar action or proceeding has
been filed or is pending before the Supreme Court, the Court of Appeals, or any other
tribunal or quasi-judicial agency, I undertake to report such fact within five (5) days
therefrom to the court or agency wherein the original pleading and sworn certification
contemplated herein have been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this

__________________at ___________________, Philippines.

SUBSCRIBED AND SWORN to before me this ________________ at

____________________, Philippines by affiant who is personally known to me to be the
same person who executed the foregoing document and acknowledged to me that the same
is his true and voluntary act and deed.

Doc. No. ____;

Page No. ____;
Book No. ____;
Series of 2023.