Despite various written and verbal demands, it appears that you have

continually failed to fulfill your obligation to pay your due and demandable
obligations to PPM in the amount of One Hundred and Forty-Eight Million,
Nineteen Thousand Two Hundred Pesos (Php 148,019,200.00). The said amount
excludes interests and other damages and only represents the unpaid services
performed by PPM for you in relation to the AEU Piling Work, JG Summit
Expansion Project PKG 2. (the “Project”).

1. We are the Private Complainants in the above-captioned case;

2. We have caused the preparation and filing of the foregoing Verified

Motion for Reconsideration.

3. We have read the foregoing Verified Motion for Reconsideration, the

contents of which are true and correct based on our own personal
knowledge and authentic records which we examined and reviewed;

4. The pleading 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, will likewise have
evidentiary support after a reasonable opportunity for discovery;

5. We further certify that we have not commenced any action or proceeding

involving the same issue or subject matter in the Supreme Court, the
Court of Appeals or any other tribunal or agency; and that if should I learn
thereafter that a similar action or proceeding has been filed or is pending
before these courts or tribunal or agency, I undertake to report that fact to
the Honorable Court within five (5) calendar days therefrom.

IN WITNESS THEREOF, we have hereunto affixed my signature this

________________ 2024 at City of Manila, Philippines.

JOSEPH PATRICK A. DE BORJA MELYN D. DEQUIÑA

Affiant Affiant

SUBSCRIBED AND SWORN TO before me, a Notary Public commissioned in and

for the City of Manila this ___________, 2024, affiant(s) exhibited to me her valid
I.D. ______________, with ID No. _____________, issued on _________, valid
until _____________ as competent evidence of identity.

Doc No. _______;

Page No. ______;
Book No. ________;
Series of 2024.