Professional Documents
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ALFONSO B. CAMILLO,
Plaintiff-Appellant
-versus-
SC GR No. 206281
For: Collection of Sum of Money
x------------------------------------------------x
Alfonso B. Camillo
Plaintiff/Defendant
MAXIMO KULITIPOT,
Plaintiff,
-versus-
PROCOPIO MAGALPOK,
Defendant,
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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;
ATTY. MAB A. HO
Counsel for Plaintiff
RALPHY COTEK,
Plaintiff,
-versus-
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
ANDREW ASAYTUNO,
Plaintiff,
-versus-
JESSIELYN LAO,
Defendant,
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SIGNATURE OF COUNSEL
BOG VOGUE,
Petitioner,
MAN D. ARAYA,as
presiding judge, Branch 0, Manila,
VINO BOMBA, and the REGISTER
OF DEEDS, Manila
Respondents,
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SIGNATURE OF COUNSEL
Copy furnished
Annie Batumbakal_,
Plaintiff,
vs.
Celso Suave,
Defendant
.
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_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.
Annie Batumbakal
PLAINTIFF
MAXIMO KULITIPOT,
Plaintiff,
-versus-
PROCOPIO MAGALPOK,
Defendant,
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RECORD ON APPEAL