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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


NATIONAL CAPITAL JUDICIAL REGION
Manila, Branch 0

ALFONSO B. CAMILLO,
Plaintiff-Appellant

-versus-

SC GR No. 206281
For: Collection of Sum of Money

METROPOLITAN BANK & TRUST COMPANY


Defendant-Appellant

x------------------------------------------------x

MOTION FOR EXECUTION

Plaintiff / Defendant, unto this Honorable Court, respectfully alleges that:


1. On February 27, 2014 a judgment was rendered by the Supreme Court, the dispositive
portion of which reads : In view of the foregoing premises, the Decision dated September 30,
2003 of the Regional Trial Court Branch 215, Quezon City, in Civil Case No. Q-96-29697, is
hereby AFFIRMED with MODIFICATION Defendant-appellant bank is ORDERED: a) to
RETURN to the plaintiff-appellant Camillo the amount of P102,820.01 plus legal interest of
15.31% per annum computed from August 31, 1981 up to October 15, 1981 until fully paid; b)
to PAY plaintiff-appellant Camillo, the legal interest of 6% per annum on the principal of
P102,280.01, plus the interest it gained from August 31, 1981 up to October 15, 1981, to be
reckoned from October 16, 1981 up to the actual payment of defendantappellant bank until
fully paid; c) to PAY plaintiff-appellants attorneys fees in the amount of P50,000.00; d) to
PAY P100,000.00 for moral damages and e) to PAY P20,000.00 for exemplary damages. Cost
against defendant-appellant bank. SO ODERED
2. The judgment is final an unappealable
3. The defendant / plaintiff has not complied with the judgment

WHEREFORE, premises considered, it is respectfully prayed that a writ of execution be


issued to implement the judgment of the Court dated January 2, 2015

Alfonso B. Camillo
Plaintiff/Defendant

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
Manila, Branch 0

MAXIMO KULITIPOT,

Civil Case No. 0007

Plaintiff,

For: Sum of Money

-versus-

PROCOPIO MAGALPOK,
Defendant,
x-----------------------------------x

COMPLAINT

THIS CASE, the plaintiff through the undersigned counsel and to this Honorable Court,
respectfully alleges:
1. That plaintiff Maximo Kulitipot is of legal age, single and a resident of 22 San Roque
St.,Quiapo, Manila, and defendant Procopio Magalpok is of legal age, single and a resident of 21
San Roque St., Quiapo, Manila;

First Cause of Action


2. On March 3, 2009, defendant obtained a loan from the plaintiff in the amount of
FIFTY THOUSAND PESOS (Php 50,000.00) for which he executed and delivered to plaintiff a
promissory note, a copy of which is hereto attached as Annex A, and made part of this
complaint, to wit: (copy PN)
3. Despite the lapse of the period for the payment of the amount stated in said note,
defendant has not paid the same, or any part thereof or interest thereon;
Second Cause of Action
4. Plaintiff herby incorporates the allegations of paragraph 1;
5. On October 3, 2009 defendant again obtained a loan from the plaintiff in the amount
of ONE HUNDRED THOUSAND PESOS (Php 100,000.00) for which he executed and
delivered to the plaintiff a promissory note, a copy of which is hereto attached as Annex B,
and made part of this complaint, to wit: (copy PN)
6. Despite the lapse of the period for the payment of the amount stated in said note,
defendant has not paid the same, or any part thereof or interest thereon;
WHEREFORE, it is respectfully prayed that judgment be rendered in favor of plaintiff
and against defendant for the sum of ONE HUNDRED FIFTY THOUSAND PESOS (Php
150,000.00) with interest at the rate of six per centum (6%) per annum on each of the aforesaid
notes, until paid; interest at legal rate on the interest due from the time of the filing of the
complaint and attorneys fees plus costs.
Such other reliefs as may be just and equitable under the premises are likewise prayed for.
City of Manila, Philippines, March 3, 2009

ATTY. MAB A. HO
Counsel for Plaintiff

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
Manila, Branch 0

RALPHY COTEK,

Civil Case No. 0008

Plaintiff,

For: Sum of Money

-versus-

IAN DELA CRUZ,


Defendant,
x-----------------------x

PRE-TRIAL BRIEF

THIS CASE, the defendant by counsel and to this Honorable Court, respectfully
submits this pre-trial brief in compliance with the trial courts order date 22 February 2010,
containing the following:
1. Defendant is willing to enter into an amicable settlement of the case, under terms
and conditions which are agreeable to both parties. Defendant is willing to submit the technical
issues for resolution by technical experts.
2. Defendant admits the following facts:
2.1) the personal circumstances of the parties stated in the Answer
2.2) receipt of a demand letter dated October 30, 2009.
3. The issues which defendant raises are as follows:
3.1) Plaintiffs personality to seek legal relief;
3.2) Plaintiffs entitlement to the amount claimed;
3.3) Plaintiffs bad faith in filing this suit;
3.4) Defendants entitlement to the claims made in his compulsory counterclaim
as a result of plaintiffs bad faith.
4. Defendant intends to present the following documents, in connection with which
the defendant requests from plaintiff their admission of their execution and due
authenticity:
4.1) Exh.1 a receipt for the amount of ten thousand pesos (Php 10,000.00)
issued to defendant, dated November 3, 2009 as proof of payment of
defendants obligation;
4.2) Exh.2 a receipt for the amount of twenty thousand pesos (Php 20,000.00)
issued to defendant, dated November 7, 2009 as proof payment of defendants
obligation.
5. Defendant manifests his intention to resort to discovery procedures.
6. Defendant does not intend to amend his answer.
7. Defendant intends to present the following witnesses:
a.) Mr. Michael Villariza, secretary of plaintiff
b.) Defendant Ian Dela Cruz, himself
WHEREFORE, defendant prays that the foregoing be taken cognizance of.
City of Manila, Philippines. March 3, 2010

SIGNATURE OF COUNSEL
COPY FURNISHED

PROOF OF SERVICE

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
Manila, Branch 0

ANDREW ASAYTUNO,

Civil Case No. 0009

Plaintiff,

-versus-

JESSIELYN LAO,
Defendant,
x-----------------------x

COMPLAINT WITH PRAYER FOR ISSUANCE OF PRELIMINARY INJUNCTION

Plaintiff, by the undersigned counsel, respectfully states that:


1. Plaintiff, Andrew Asaytuno, of legal age, single, and a resident of 18 Recto Ave. Manila;
defendant Jessielyn is of legal age, single and a resident of 17 Recto Ave. Manila;
2. Plaintiff, engaged in the sale of general merchandise entered into an exclusive dealership and
distribution agreement with ROD INC. whereby plaintiff would exclusively sell ROD INC.s products
into the Philippines;
3. Defendant, also engaged in the sale of general merchandise, began selling the products of
ROD INC. in the Philippine without authority to do so
4. As a result of defendants acts, plaintiff suffered damages and his sale of the products of
ROD INC. has been diminishing, to such an extent that plaintiff has been losing profits of no less than
P500,000.00 a month starting January 12, 2010;
5. Defendant continues to commit the act illegally interfering with the agreement executed
between plaintiff and ROD INC;
6. That the plaintiff is entitled to the relief demanded and the whole or part of such relief
consists in restraining the commission of continuance of the acts complained of, either for a limited
period or perpetually;
7. That the commission or continuance of some act complained of during the litigation would
probably work an injustice to the plaintiff
8. That the plaintiff hereby applies for a writ of preliminary injunction to restrain the defendant
from the act herein complained of, and for this purpose hereby offers a bond in such sum as this
Honorable Court may affix
PRAYER
WHEREFORE, it is respectfully prayed that, after due notice and hearing a preliminary
injunction be issued forthwith to restrain defendant from doing the act herein complained of; namely, to
cease and desist from selling the products of ROD INC. in the Philippines; and that after trial, said
injunction be made permanent, with costs, and with such further orders that are just and equitable in the
premises.

City of Manila, March 3, 2010

SIGNATURE OF COUNSEL

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

REPUBLIC OF THE PHILIPPINES


COURT OF APPEALS
Manila

BOG VOGUE,
Petitioner,

CA-G.R. SP No. 000009


-versus-

MAN D. ARAYA,as
presiding judge, Branch 0, Manila,
VINO BOMBA, and the REGISTER
OF DEEDS, Manila
Respondents,
x-----------------------x

PETITION FOR CERTIORARI

The petitioner, by the undersigned counsel, respectfully alleges that:


1. The petitioner is of legal age, single and with residence at 5 Recto Ave., Manila. He is the
defendant in Civil Case No. 67890, Branch 0, RTC, Manila; respondent Vino Bomba is of legal age,
single with residence at 9 Recto Ave., Manila, where he may be served with legal processes. He is the
plaintiff in said Civil Case no.678909; respondent Man D. Araya is of legal age and is the Presiding Judge
of Branch 0, Manila who issued the questioned orders and is sued in his official capacity as such;
respondent Register of Deeds of Manila City being used in its official capacity.
2. Petitioner Bog Vogues TCT covering a parcel of land in Manila was cancelled and a new
TCT was issued in favor of respondent Vino Bomba
3. Under the Land Registration Decree, in involuntary registration of deed and in case the
judgment debtor refuses to deliver his owners duplicate certificate of title, an entirely different and
separate action has to be filed in the RTC, acting as a cadastral or land registration court, for the issuance
of an order cancelling the judgment debtors TCT and ordering the Register of Deeds to issue new title to
the judgment creditor as purchaser of the land in the auction sale to satisfy the judgment debt, and not an
order from the RTC that rendered judgment for a sum of money, the latter order being null and void;
4. The respondent judge acted with grave abuse of discretion amounting to lack of jurisdiction
in issuing the questioned orders;
5. There is no appeal or any plan and speedy remedy in the ordinary course of law other than
instant petition;
6. Petitioner receive a copy of the questioned order on February 3, 2010; petitioner filed a
motion for reconsideration on February 5, 2010; and, petitioner received a copy of the decision denying
the motion for reconsideration on February 7, 2010;
7. The instant petition is filed within 60 days from the receipt of said order.
WHEREFORE, petitioner prays that the petition be given due course and such other reliefs as
may be just and equitable in the premises.

City of Manila; Philippines, March 3, 2010.

SIGNATURE OF COUNSEL
Copy furnished

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING


PROOF OF SERVICE

REPUBLIC OF THE PHILIPPINES


MUNICIPAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
Manila, Branch 0

Annie Batumbakal_,
Plaintiff,

vs.

Civil Case No. 4141513


For: Collection of Sum of Money

Celso Suave,
Defendant
.
x----------------------x

MOTION TO PLEAD AS INDIGENT

_I, Annie Batumbakal_, unto this Honorable Court, respectfully alleges that:
1. I am resident of _____Tondo, Manila_______;
2. My gross income and that of my immediate family does not exceed_____P300.00_____;
3. I do not own real property with an assessed value of more than (amount as provided in the
Revised Rules of Court, as amended) as shown by the attached Certification issued by the Office
of the City/Municipal Assessor and the City/Municipal Treasurers Office;
4. Due to financial constraint, I cannot afford to pay for the expenses of a court litigation as I do
not have enough funds for food, shelter and other basic necessities;
5. Should the court render judgment in my favor, the amount of the docket and other legal fees
which I was exempted from paying shall be a lien on the judgment, unless the court orders
otherwise.

WHEREFORE, premises considered, it is respectfully prayed that I be exempted from the


payment of docket and other legal fees as indigent pursuant to Section 21, Rule 3 in relation to
Section 18, Rule 141 of the Revised Rules of Court. Other reliefs just and equitable under the
premises are likewise prayed for.

Annie Batumbakal
PLAINTIFF

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
Manila, Branch 0

MAXIMO KULITIPOT,

Civil Case No. 0007

Plaintiff,

For: Sum of Money

-versus-

PROCOPIO MAGALPOK,
Defendant,
x-----------------------------------x

RECORD ON APPEAL

BE IT REMEMEBERED, that on the dates herein respectively mentioned, the following


proceedings were had in the Regional Trial Court of ____Manila______:
1. That on October 1, 2013, the plaintiff-appellee filed a complaint against the defendantappellant, in the following:
(Copy complaint)
2. That Procopio Magalpok, the defendant-appellant filed his Answer to said complaint, as
follows:
(Copy complaint)
3. That after due hearing, the court, on October 16, 2013 rendered the following decision:
(Copy Decision)
4. That on October 19, 2013, defendant-appellant filed a motion for reconsideration of the
following tenor:
(Copy Motion for reconsideration)
5. That on October 21, 2013, the court issued an order denying the said motion for
reconsideration, to wit:
6. That on October 24, 2013, defendant-appellant received notice of the said order denying his
motion for reconsideration, and on October 27, 2013 filed his Notice of Appeal to the Court of
Appeals as follows:
(Copy notice of appeal)
WHEREFORE, the defendant-appellant prays for the approval of this Record on Appeal and that
the same be transmitted to the Court of Appeal, together with all the oral and documentary
evidence give and presented at the trial of the above-entitled case.
(Venue, date, signature)

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