Civil Complaint (1993, 1994, 1996, 1997, 2000, 2001, 2009)

Republic of the Philippines

NATIONAL CAPITAL JUDICIAL
REGION REGIONAL TRIAL COURT
Makati City
S.
Plaintiff.

-versus- Civil Case No. 1

B, For: Sum of Money

Defendant.
X--------------------------------------X

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and to this
Honorable court respectfully alleges:

1. That plaintiff S, of legal age. Filipino citizen, residing at 211 Madison

Street, Greeenhills, Metro Manila and B, defendant, of legal age, Filipino
citizen residing at 24 Lontoc Street. Quezon City, where he maybe served
with summons;

2. That on October 5, 1994, defendant purchased a 1989 Lancer car from

the plaintiff in the amount of P250.000.00 payable on or before
December 30, 1995 with an interest of 36% per annum; and that in the
event of litigation, defendant shall pay P20.000.00 as attorneys fees.

A copy of said promissory note is hereto attached.

3. That after one year had expired, defendant failed to pay said promissory
note;

4. That despite demands both written and oral, defendant failed to pay the
value of said promissory note forcing plaintiff to file this case engaging
the services of counsel in the amount P20.000.00.
WHEREFORE, it is respectfully prayed that after due trial, defendant be
ordered to pay the amount of P250.000.00 plus 36% interest until the
amount is fully paid and P20,000.00 as attorneys fees.

Makati City, September 1, 1996.

J
Counsel for Plaintiff
PTR OR. No. 6321. January 7. 1996
IBP OR No. 1265, January 7, 1996

Complaint for Ejectment (1993, 1994, 1996, 1997, 2000, 2001, 2008)
Republic of the Philippines
NATIONAL CAPITAL JUDICIAL REGION
MAKATI CITY CITY COURT. Br. No. 1

REY CARREON
Plaintiff.

-versus- For: Ejectment

SIONY BELTRAN
Defendant,
X----------------------------------------X

COMPLAINT

COMES NOW, the plaintiff in the above entitled case, through the
undersigned counsel and to this Honorable Court, respectfully alleges:

1. That the plaintiff, of legal age, residing at 26 Real Street, Makati City,
that defendant is of legal age, residing at No. 2 Wilson. Makati where he
may be served with summons;

2. That the plaintiff is the owner of a market stall at Shoppersville.

Greenhills, Mandaluyong City, which was leased to defendant on March 1,
1993 to March 1995 at a monthly rental of PI5,000,00;

3. That defendant failed to pay the monthly rentals for 6 months, and
despite written and oral demands to vacate, defendant failed to pay said
rentals for 6 months in the amount of P90.000.00;

4. That due to the refusal of defendant to pay the rentals, plaintiff was
constrained to file the present action engaging the services of counsel, in
the amount of P 10,000.00.

WHEREFORE, it is respectfully prayed that after due trial defendant be

ordered to pay the amount of P90.000.00 with legal interest and to vacate
the premises.

Makati City, September, 24 1996.

Juan De La Cruz
Counsel for Plaintiff
PTRO.R. NO. 7755, January 10, 1996
IBP OR No. 7007, January 10, 1996

*Note that if the complaint is for Forcible Entry, there must be an

allegation of: (1) prior physical possession of the property by the plaintiff;
and (2) deprivation of said possession by another by means of force,
intimidation, threat, strategy or stealth (Abejar v. Caluag, G.R. No. 171277,
15 February 2007).
Criminal Information (1991, 1993, 1994, 1995, 1998, 1999, 2000, 2003,
2004, 2006, 2009, 2010)
REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
Branch II
Manila

PEOPLE OF THE PHILIPPINES,

Plaintiff,
- versus - Criminal Case No. 7
For: Homicide
DANILO PARAS,
Defendant

INFORMATION

The undersigned fiscal charges Danilo Paras of the crime of homicide

committed as follows: That on or about August 10, 1993 in the City of
Manila, the said accused did then and there willfully, unlawfully and
feloniously, with intent to kill, fire his 45 caliber gun upon Ricardo Santos
inflicting on him mortal wounds which immediately caused the death of
the said Ricardo Santos.

Contrary to law.

Domingo Velez
Assistant Fiscal

CERTIFICATION OF PRELIMINARY INVESTIGATION

I hereby certify that a preliminary investigation in this case had been

conducted by me in accordance with law; that I have examined the
complainants and their witnesses; that there is reasonable ground to
believe that the offense charged had been committed; that the accused is
probably guilty thereof; that the accused was informed of the offense
charged and was given the opportunity to submit controverting evidence;
and that the filing of this information is with the prior authority and
approval of the City Fiscal.

DOMINGO VELEZ
Assistant Fiscal

SUBSCRIBED AND SWORN to before me on this 2nd day of May 1993

in the City of Manila. Philippines.

JOSE PEREZ
City Fiscal

List of Witnesses: Jose V. Pedro

Bail Recommended: P20.000.

Forms asked in the Bar

1. Chattel Mortgage with Affidavit of Good Faith (1997, 1999)
2. Complaint for ejectment (1993, 1994, 1996, 1997, 2000, 2001) include
Prayer for Preliminary Injuction/ complaint for a boundary dispute.
3. Criminal Information (1991, 1993, 1994, , 1995, 1998, 1999, 2000, 2003,
2004, 2006) with certificate of Preliminary investigation.
4. Motion to disqualify a judge (2001)
5. Motion for support pendente lite (2001)
6. Affidavit to bar proceedings in Lupon Tagamayapa (2001)
7. Motion for an extension of time with proof of service and notice of
hearing (2002)
8. Formal entry of appearance (2002)
9. Motion to dismiss an action
10. Civil complaint (1988, 1990, 1995, 1996, 2003)
11. Attestation of a notarial will (2004)
12. Special Power of Attorney (1992, 2005, 2009, 2010)
13. Deed of Sale of Real Property (1991, 2005)
14. Motion for withdrawal of counsel w/ or w/o conformity of client
15. Notice of Appeal (2005)
16. Affidavit of desistance (2006)
17. Affidavit of self-adjudication (2006)
18. Clause stipulating a right of first refusal (2007) - It is hereby agreed
that if the Lessor should decide to sell the leased premises during the
period of this lease, he shall first offer the same in writing to the Lessee
who shall have the right to accept the offer within a period of thirty (30)
days from receipt of the same. Should the Lessee fail or refuse fail to
accept, the Lessor may offer to sell the property to any other person,
provided that he cannot offer the same at a lower price without first
extending the same right of first refusal to the Lessee.
19. Affidavit of merit in a petition for relief
20. Arbitration clause - Any dispute that may arise between the parties
hereto concerning the interpretation of this contract and/or on the rights,
duties or liabilities of any party arising hereunder, shall be exclusively
referred to arbitration by a committee of three (3) arbitrators. Each party
shall nominate one arbitrator and the two so nominated shall choose the
third arbitrator. If they cannot agree on the third arbitrator within sixty
(60) days from the date that the last of them was nominated, the
Executive Judge of the Regional Trial Court of Manila shall be asked to
appoint such third arbitrator. Any decision of the Arbitration Committee
shall be final, enforceable and binding on the parties.
21. motion for postponement (1987)
22. Resolution of a corporation (1987)
23. Promissory note (1991, 1994)
24. Petition for a writ of Habeas Corpus (1992, 2010)
25. Reconstitution of title (1992)
26. Verification (1994)
27. Acknowledgment (1994)
28. Motion for consolidation (1994)
29. Notarial Prohibition (1995)
30. Motion to lift order of default (1996)
31. Prepare a demand letter preparatory to filing an ejectment case (2009)
32. Draft a complete deed of donation of a piece of land (2009)
33. Prepare a motion to declare Jamero in default (2009)
34. Petition for Letters Rogatory (2010)
35. Petition for the Issuance of a Writ of Habeas Data (2010)
36. Draft a Petition for Bail (2010)
(2008 Bar) Q: Ian Alba owns a house and lot at No. 9 West Aguila, Green
Cross Subdivision, Quezon City, which he leased to Jun Miranda for a
term of two years starting May 1, 2006, at a monthly rental of P50,000.
Jun defaulted in the payments of his rentals for six (6) months, from
January 1, 2007 to June 30, 2007. [a] Prepare a demand letter as lawyer
of Ian Alba addressed to Jun Miranda preparatory to filing an
ejectment case. (3%) A:
July 10, 2007
Mr. Ian Alba
No. 9, West Aguila St.
Green Cross Subdivision
Quezon City
Dear Sir:
This is with reference to your lease of the house and lot of my client, Mr.
Jun Miranda, located at your above stated address.
You leased the said property for a period of two years starting from May
1, 2006, at a monthly rental of P50,000.00. However, you have defaulted
in the payment of the said rentals for six months already, from January 1,
2007 to June 30, 2007.
In view thereof, my client is hereby terminating your lease, and demand is
hereby made upon you to vacate the leased premises and pay your rentals
in arrears within five (5) days from your receipt hereof.
Yours truly,
Atty. X

(2008 Bar) Q: Draft a complete deed of donation of a piece of

land in accordance with the form prescribed by the Civil Code. (8%) A:
DEED OF DONATION

KNOW ALL MEN BY THESE PRESENTS:

That, for an in consideration of the love and affection which I bear for
the donee, I, Mr. A.B., Filipino, of legal age, single and a resident of No.
7, West Aguila St, Green Cross Subdivision, Quezon City, Manila, have
donated, as I hereby donate, to the Donee, Miss C.D., of legal age, single
and a resident of No. 11, West Agiuila St., Green Cross Subdivision,
Quezon City, that certain parcel of land and the improvements thereon
located at No. 9, West Aguila St. , Green Cross Subdivision, Quezon City,
covered by Transfer Certificate of Title No. 12345 of the Registry of
Deeds of Quezon City, and which is more particularly described as
follows:

(technical description)

And I, the above-named donee, do hereby accept this donation with deep
gratitude to the donor.

IN WITNESS WHEREOF, the parties hereto have signed these presents,

at Quezon City, Philippines, this 25th day of September, 2008.

A.B. C.D.
Donor Donee

WITNESSES:

_____________________
_________________________

REPUBLIC OF THE PHILIPPINES)

CITY OF QUEZON ) S.S.

ACKNOWLEDGMENT

In the City of Quezon, Philippines, this 25th day of September, 2008,

before me, a Notary Public in and for the said city, personally appeared
Mr. A.B., with Drivers License No. _____________ issued at Quezon
City, on _________________, and Miss C.D. with Passport No.
_____________, issued at Manila, on _________________, both of
whom are personally known to me and to me known to be the same
persons who executed the foregoing instrument, and they acknowledged
to me that the same is their free and voluntary act and deed.

I further certify that the foregoing instrument is a deed of donation of a

parcel of land with the improvements thereon located at No. 9 West
Aguila St., Green Cross Subdivision, Quezon City, and consists of pages,
including this page, and signed on each and every page by the said parties
and their instrumental witnesses.

WITNESS MY HAND AND SEAL.

NOTARY PUBLIC
Until December 31, 2010
(address & tel. no.)
(Attys. Roll No., date)
(IBP O.R. No., date/place issued)
( PTR O.R. No. date/place issued)

Doc No. _______;

Page No. ______;
Book No. ______;
Series of 2008.

(2009 Bar) Q: Alexander Sison, resident of 111 Libertad St.,

Sampaloc, Manila, engages your services as lawyer. He tells you that a
certain Mr. Juan Jamero of 222 Juan Luna St., Tondo, Manila, owes him
P1, 000, 000.00; that the debt is long overdue; and that, despite repeated
demands, Jamero has failed to comply with his obligation. He also shows
you a promissory note, executed on January 3, 2008, wherein Jamero
promises to pay the amount of P1, 000, 000.00, with 12% interest per
annum, within one (1) year from date of note. Sison agrees to pay you
attorneys fees in the amount of P75, 000.00 and a fee of P3, 000.00 for
every appearance in court. Assume that summons had been served on
Jamero, but no responsive pleading was filed within the reglamentary
period. Prepare a motion to declare Jamero in default. (4%) A:
REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
MANILA

ALEXANDER SISON
Plaintiff,
- Versus - CIVIL CASE NO.
____________________

JUAN JAMIRO,
Defendant.
x------------------------------x

MOTION TO DECALRE IN DEFAULT

PLAINTIFF, through undersigned counsel, through this Honorable

Court respectfully alleges:

1. That on September _____, 2009, defendant was served with

summons and a copy of the Complaint;

2. That the reglamentary period for the defendant to file an Answer

or motion to dismiss expired on ________________________,
without the defendant filing any such answer or motion.

3. That defendant may now be declared in default.

Wherefore, it is respectfully prayed that the defendant be declared in

default and the plaintiff be allowed to present his evidence ex-parte.

Manila, ___________________, 2009.

ATTY. _________________
Counsel for the Plaintiff
(address)
Attorneys Roll No. _______

Date ___________________________
PTR No., ______, Place/ Date of issue
IBP O.R. No. ____________________
Date/ Place issued ________________
MCLE Cert. No. _________________
Email address: __________________
NOTICE OF HEARING

Mr. Juan Jamero

222 Juan Luna St., Tondo
Manila
Sir:

Notice is hereby given that on _______________, at 8:30 a.m., the

foregoing motion will be submitted to the Honorable Court for its
consideration and resolution.

ATTY. ___________________

(2010 Bar) Q: Prepare the following: Petition for Letters Rogatory,

(5%).
(caption)

PETITION FOR LETTERS ROGATORY

PLAINTIF, through counsel, respectfully alleges:

1. That the above action is pending in this court and, for the purpose
of completing the evidence and presenting to the court all the facts
whereby a just decision can be arrived at, it is necessary that the testimony
of Mr. A.B., who is presently residing in 123 North Avenue, Vancouver,
British Columbia, Canada, he taken;

2. That the said witness will be unable to go to the Philippines to

testify in this case due to his ailment as certified to by his doctors sworn
certificate hereto attached as Annex A hereof;

3. That it is in the interest of justice that the testimony of the

aforementioned witness be taken and made part of the evidence in this
case.
WHEREOF, it is respectfully prayed that this court order the issuance by
the clerk of this court of letters rogatory to the proper judicial tribunal of
Vancouver, British Columbia, Canada, requesting the examination of Mr.
A.B. on the written interrogatories filed herewith.

Manila, September 6, 2010.

Atty. WY

Notice of Hearing

Atty. M.
Counsel for the defendant
(Address)

Sir:

Kindly take notice that the foregoing petition will be submitted to

the Honorable Court on September 27, 2010, for its consideration and
resolution.