Affidavit Complaint

REPUBLIC OF THE PHILIPPINES}
BAGUIO CITY
}S.S.
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AFFIDAVIT-COMPLAINT
I, TREU G. KAUFER of legal age, Filipino Citizen, single
and a resident of 11 Munich Street, Baguio City, after having
been sworn in accordance with law hereby state that:
1. On April 25, 2019, I went to a newly opened cellular phone
store named Dito Orig located in Kayang Street, Baguio
City.
2. There I met the store owner who represented himself as
Johnny B. Goode, who later I found out that his real name
is Chuck Berry, and to him I inquired about the latest
model of Orange Phone.
3. He then showed me an unopened box of cellular phone
which appears to be Orange 6s plus, the latest model of
Orange Phones. The phone looked genuine upon
inspection.
4. When I asked about the genuineness of the product, he
told me that everything in the store is original hence the
store name. He added, Kung peke yan, naku! Hanapin mo
ako, Johhny B. Goode pangalan ko at sasamahan pa kita
sa mismong opisina ng Orange. May seal yan madam
kaya di natin mabuksan, para pakita ko sana sayo yung
marka ng Orange. Tignan mo naman yung pader ng store
namin, certications yung mga yan na kami ay lehitimong
distributor ng mga produkto nila.
5. Persuaded with the assurance of the seller, I depended on
his expertise. I bought the phone on its selling price of
Php200,000.
6. However, when I got home and tried inserting a sim card
to the Orange phone, the casing fell off and it appears
that it has been tampered with. The parts of the phone
have been replaced with inferior ones.
7. I went back to the store the day after but it was already
closed and found out that it had moved to a new location.
8. Upon reaching the new store location, there I found that
the sellers real name is Chuck Berry.
9. I confronted Chuck Berry but denied the transaction we
had nor had we previously met.
10. The unlawful acts by Mr. Berry cased damage to me in
the amount of Php200,000.00, and I spent Php50,000.00
for attorneys fees for filing this affidavit-complaint;
11. I am executing this affidavit to file a formal complaint of

Estafa through deceit or fraudulent acts against CHUCK
BERRY.
IN WITNESS WHEREOF, I have hereunto set my hand
this 1st day of May 2019, in the City of Baguio, Philippines.
TREU G. KAUFER
Affiant
SUBSCRIBED AND SWORN to before me, in the City
of Baguio, Philippines, this 1st day of May 2019, I further
Certify that I have personally examined the affiant and that I
am satisfied that she gave her statement freely and that he
understood the contents of her affidavit- complaint.
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BAGUIO CITY
}S.S.
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AFFIDAVIT-COMPLAINT
I, BENEDICT D. VERKUFER of legal age, Filipino
Citizen, single and a resident of 110 Munich St., Baguio City,
after having been sworn in accordance with law hereby state
that:
1. I know the person of STEVE N. BUSCEMI, who is a
resident of 112 Guisad Surong, Baguio City, Philippines;
2. That sometime in March 25, 2019, Mr. Buscemi
approached me to pay his outstanding balance from a
previous transaction thereby issuing a check post-dated
on April 10, 2019;
3. Said check is drawn against the account of Buscemi at
BDO SM Baguio branch with Account No. 100922;
4. He made the assurance and representation that the
said check is a good check and would have sufficient
funds when presented for payment;
5. When the check was presented on April 10, 2019, the
same was dishonored and returned by the bank to me
on the ground that the account had no funds at all. A
true machine reproduction of the said check is attached
hereto and marked as Annex A;
6. I immediately notified Buscemi of the dishonor of the
check and demanded that he make good of said check
within 10 days from his receipt of the demand letter. A
copy of the demand letter is attached hereto and
marked as Annex B;
7. Bach after receiving such letter responded to me by
saying Tado ka pala eh. Hinding hindi kita babayaran!
Hah! Wala naming kwenta yung benta mo sa akin!
8. I am therefore executing this affidavit-complaint in
support of the charges for violation of Batas Pambansa
Bilang 22 against STEVE N. BUSCEMI, who may be
served with subpoena and other processes of this Office
at his last known address at 112 Guisad Surong, Baguio

City, Philippines.

this 2nd day of May 2019, in the City of Baguio, Philippines.
BENEDICT D. VERKUFER
Affiant
of Baguio, Philippines, this 2nd day of May 2019, I further
am satisfied that he gave his statement freely and that he
understood the contents of his affidavit- complaint.
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BAGUIO CITY
}S.S.
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AFFIDAVIT-COMPLAINT
I, DAME Y. REISENDEN, of legal age, Filipino Citizen,
single and a resident of 05 Frankfurt Road, Baguio City, after
having been sworn in accordance with law hereby state that:
1. On March 5, 2019, I went to the MAAAN, DAA BEEES
office to submit documents for my application for a
work abroad as a maid;
2. Upon submission of my documents, WERBER H.
ILLIGALE the owner of the recruitment office, demanded
that I pay Php500,000.00 to secure my flight and to
guarantee that I already have a job waiting for me
when I get to Somalia come June 10, 2019;
3. I paid the Php500,000, for I much desire to have my
application completed at the earliest time possible;
4. On April 10, 2019, while I was checking my Facebook
account, a friend posted an article that MAAAN, DAA
BEEES had no valid license or authority required by
law to enable one to lawfully engage in recruitment and
placement of workers;
5. The unlawful acts of ILLIGALE caused damage to me in
the amount of Php500,000.00 and I spent the amount
of Php50,000.00 for attorneys;
support of the charges for Illegal Recruitment against
WERBER H. ILLIGALE.
this 3rd day of May 2019, in the City of Baguio, Philippines.
DAME Y. REISENDEN
Affiant

of Baguio, Philippines, this 3rd day of May 2019, I further
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BAGUIO CITY
}S.S.
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AFFIDAVIT-COMPLAINT
I, DAME Y. REISENDEN, of legal age, Filipino Citizen,
single and a resident of 05 Frankfurt Road, Baguio City, after
having been sworn in accordance with law hereby state that:
1. On April 30,2019, at about 4:30 in the afternoon while I
was shopping at SkyWorld in Session Road. I saw
WERBER H. ILLIGALE whom I met from a previous Illegal
Recruitment incident;
2. Unwilling to ignite confrontation, I walked away from his
direction;
3. While I was walking away, he suddenly kicked me on
my back, picked me up when I fell and slammed me on
a clothes rack and threw me down the stairs;
4. When I woke up, I woke up in a hospital bed;
5. Medical records show that I will not be able to go to
work for at least ninety days because of a broken
vertebra. Attached hereto is a copy of the medical
report made by Doctor Quack marked as Annex A;
support of the charges for Serious Physical Injuries
against WERBER H. ILLIGALE.
this 4th day of May 2019, in the City of Baguio, Philippines.
DAME Y. REISENDEN
Affiant

of Baguio, Philippines, this 4th day of May 2019, I further
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BAGUIO CITY
}S.S.
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AFFIDAVIT-COMPLAINT
I, SCHMUTZIGE POLITIKER of legal age, Filipino
Citizen, single and a resident of 178 Cologne Hills, Baguio
City, after having been sworn in accordance with law hereby
state that:
1. On April 21, 2019, I was at a conference on Leadership
and Good Governance held in Convention Center in
Baguio City;
2. The conference of which I was a guest speaker was
attended by several delegates from municipalities and
provinces in North Luzon;
3. When I was delivering my speech, Mr. JON SCHULTZ
grabbed the microphone and started shouting, Dilaw
na tae yang si gob! Parang yung boss nyang si Panot!
Wag kayong maniwala sa pinagsasasabi nyan, yung
pinangrehistro nyo sa conference dito pinang puta na
nya kagabi may kasama pang shabu at heroin kaya
lagging luting ang gung gong na yan, ganyan kadumi
itong tarantadong ito. Taeng dilaw!;
4. After such defamation, people from the crowd started
talking to each other, some left the hall and some were
crying in disappointment. Some even burned the huge
tarpaulin bearing my face outside the hall. Some who
were enraged even attempted to physically harm me as
I was escorted out of the hall;
support of the charges for oral defamation against Mr.
JON SCHULTZ.
SCHMUTZIGE POLITIKER
Affiant

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BAGUIO CITY
}S.S.
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AFFIDAVIT-COMPLAINT
state that:
1. On April 28, 2019 at about 9 in the evening, I was
having a dinner with my family at Simi Tavern, a
restaurant which I own;
2. JON SCHULTZ, a known supporter of an opposing
political party, approached my table and started picking
foods from my plate;
3. Afterwards, he brought out his private part and started
urinating on our table before he was dragged out of the
restaurant by the security,
4. Bachs act caused annoyance, irritation, torment,
distress and disturbance to my mind;
support of the charges for unjust vexation against JON
SCHULTZ.
Affiant
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BAGUIO CITY
}S.S.
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AFFIDAVIT-COMPLAINT
state that:
1. I am the owner of a Nissan Infiniti QX30 and on April 28,
2019, I had a dinner with my family at Simi Tavern, a
restaurant which I own and I parked my car on the parking
lot of the restaurant,
2. When we decided to leave the place, I saw Mr. JON
SCHULTZ standing beside my car holding a baseball bat;
3. When he saw us coming out the building, Mr. Schultz
started smashing the windows of my car with the baseball
bat and then he flee.
4. The unlawful act of Schultz caused me Php500,000.00 in
damages;
support of the charges for malicious mischief against JON
SCHULTZ.
Affiant
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BAGUIO CITY
}S.S.
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AFFIDAVIT-COMPLAINT
I, ADOLF H. GOEBBELS of legal age, Filipino Citizen,
single and a resident of 20 Dresden Compound, Baguio City,
after having been sworn in accordance with law hereby
state:
1. That on May 1, 2019, at about 10 in the morning, I was
at my condominium unit having my yoga session when
a delivery boy who introduced himself as KLEINER DIEB
from Pizza Hot came in to deliver a pizza I ordered;
2. Not being able to attend Dieb for I did not want to be
interrupted in my meditation, I ordered him to just
place the pizza on the floor and leave at once since
there are no tables nor pieces of furniture or properties
in my condo unit except from the 40 inch Sony
television plugged on my wall.
3. After I finished my yoga session, I was surprised when I
opened my eyes that the television was missing nor
there were any pizza on the floor.
4. I immediately contacted the security personnel to check
the CCTV footage. Enclosed herein is an image from
security camera showing Dieb exiting the building with
my Television and pizza as Annex A.
support of the charges for theft against KLEINER DIEB.
ADOLF H. GOEBBELS
Affiant

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BAGUIO CITY
}S.S.
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AFFIDAVIT-COMPLAINT
I, ADOLF H. GOEBBELS of legal age, Filipino Citizen,
single and a resident of 20 Dresden Compound, Baguio City,
state:
1. That on May 2, 2019 at about 8 in the evening, my
daughter and I hailed a taxi at Session Road;
2. Mr. SUPAHAI S. PEED driving a taxi with plate number
AAA-111 stopped to convey us to our destination;
3. While on our way, Peed was driving at a very high
speed and said Kayat yu makakita ti legit nga drift
kasla jay pelikula?;
4. Before I could even protest, Peed attempted the risky
stunt which caused the vehicle to spin and of such
violent motion my daughter was thrown out of the
window and hit her head on the pavement killing her;
5. By reason of the unlawful act of Peed, my daughter
died;
support of the charges for reckless imprudence
resulting to homicide against SUPAHAI S. PEED.
ADOLF H. GOEBBELS
Affiant
SUBSCRIBED AND SWORN to before me, in the City of

Baguio, Philippines, this 9th day of May 2019, I further Certify
that I have personally examined the affiant and that I am
satisfied that he gave his statement freely and that he
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BAGUIO CITY
}S.S.
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AFFIDAVIT-COMPLAINT
I, BENEDICT D. VERKUFER of legal age, Filipino
Citizen, single and a resident of 110 Munich St., Baguio City,
after having been sworn in accordance with law hereby state
that:
1. That on May 8, 2019 at about 2 in the afternoon, I was
walking down along Session Road corner Mabini St.,
waiting for the stoplight to turn green;
2. When the light turned green I started crossing the
pedestrian lane then suddenly a motorcycle coming
along Mabini St. hit me;
3. I did not have the time to avoid the incoming vehicle
because it was traveling fast;
4. The rider turned out to be JANE D. GRACIA, a former
girlfriend;
5. By reason of the unlawful act of Gracia, I sustained
injuries as evidenced by the medical report attached as
Annex A;
support of the charges for reckless imprudence
resulting to slight physical injury and damage to
property against JANE D. GRACIA.
BENEDICT D. VERKUFER
Affiant

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BAGUIO CITY
}S.S.
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AFFIDAVIT-COMPLAINT
I, EUGENE D. HOLMES of legal age, Filipino Citizen,
single and a resident of 112 Guisad Surong, Baguio City,
state:
1. That on May 5, 2019 at around 1 in the morning, I was
at the residence of my brother ALFRED HOLMES when I
heard a commotion at the living room of the house;
2. When I went down to check what was happening I saw
VINCENT G. REMIAH pointing a hammer at my brother
who was then at the floor pleading for Vincent to stop
what he is planning to do;
3. I asked Vincent to drop the hammer and for us all to
have a peaceful talk but he looked at me and said,
Huwag kang makialam sa problema namin ng darling
ko. Sorry Alfred mahal kita pero niloko mo ako, Niloko
niyo ako ni Dennis. My brother looked at me. He was
speechless and afraid. I was stunned.
4. Vincent then took up the hammer to smite ALFRED.
There was way for me to stop what had transpire.
Before I could even reach Vincent, my brother brain is
all over the floor;
5. Vincent ran off and my brother was lying there lifeless;
support of the charges for homicide against VINCENT G.
REMIAH.

EUGENE D. HOLMES
Affiant
am satisfied that he gave her statement freely and that he

DONE: IN THE CITY OF BAGUIO } S.S.
X =========================== X
COMPLAINT-AFFIDAVIT
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I, ERMITTLER P. ANKLGER, an Investigating

Page
No. _____; have good reason to believe that, MORD M.
Prosecutor,
MRDER,
Book
No. _____;who is hereafter called Defendant, on the 28th
day of April, 2019 in the City of Baguio, did unlawfully
commit the offense of Murder, to wit, did then and there
intentionally and knowingly cause the death of, Ttung
Opfer by the Defendant contrary to Article 248 of the
Revised Penal Code.
Affiant has learned the following facts:
1. I, ERMITTLER P. ANKLGER, am a commissioned
Investigating Prosecutor in Baguio City, since January
2015. I am employed by the City of Baguio Prosecutors
Office.
2. On April 28, 2019, at approximately 10:00 in the
evening the Police Department responded to a medical
call involving a stabbing incident at Berlin Street
located within the City of Baguio.
3. During the interview on April 30, 2019 that I conducted
to witness Augen Z. Uege, a copy of the Sworn
Statement is hereto attached as Annex A, MORD M.
MRDER, a resident of No. 18 Dsseldorf Hills, Baguio
City, is charged of murder and committed as follows:
a. At about 9:30 in the evening of April 28, 2019,
Augen Z. Uege was in the front porch of his home
enjoying his tobacco. Across the street is the
house of the victim, Ttung Opfer. He then saw the
victim, tied on a cross singing the Amazing
Grace and appearing to be asking for mercy from
the defendant while the latter was gathering
pieces of wood, branches and twigs and he was
laying them around the cross.
b. Believing that it was just a rehearsal of a stage
play, since the victim is a renowned stage actor,
the witness went inside his home and grabbed a
bucket of popcorn to enjoy what he was beholding.
When he came back to his porch, the defendant
was dousing which the witness believed to be
gasoline on the branches and twigs laid around
the cross. The witness remembers the victim

screaming for help then the defendant stuffed a
mound of dirt into the victims mouth to silence
him. The witness watched in awe.
c. The defendant then reached for a long piece wood
and lighted it with fire. The witness then heard the
defendant shouting in angry tone, Sa impiyerno
mo na dalhin ang mga pangarap mo, bayut ka!
Oh! Ano, di ka makapagsalita? Bagay sayo lupa
ang kinakain hindi puro titi! Nagka impeksyon pa
ako sa kahayupan mo, bakla!
d. The defendant then lit fire on the doused branches
which quickly engulfed the victim, while the latter
was helpless. Believing it was still a staged act,
the witness, in astonishment, exclaimed and
shouted, Tangina! Ang galling, Solid!
e. Right then that the defendant realized that they
were being watched, he ran away from the house
of the victim and away from the defendant. The
witness, confused of the action of the defendant,
approached the burning victim and only then that
he knew nothing was staged.
4. Dr. Ottop C. Mann, Medico-Legal Officer of the National
Bureau of Investigation, performed an autopsy on the
cadaver of Ttung Opfer and signed his Autopsy report,
attested that indeed Ttungs cause of death was due
to smoke inhalation. A copy of the Postmortem Findings
is hereto attached as Annex B;
5. Based on the foregoing, it is beyond cavil that
respondent MORD M. MRDER committed the crime
of Murder, qualified by committing the said act by
means of fire under Article 248 of the Revised Penal
Code.
IN WITNESS WHEREOF, I have affixed my signature
this 1st day of May, 2019 in Baguio City, Philippines.
ERMITTLER P. ANKLGER
Affiant/Assistant Prosecution Attorney II
SUBSCRIBED AND SWORN to before me in the City of
Baguio, this 1st day of March 2019.
ATTY. STEVEN JAN K. SAB-IT
Investigating Prosecutor
CERTIFICATION
I hereby certify that I have personally examined the
above named affiant and that the foregoing statements were
given by her voluntarily and of her own free will and that she
understood her affidavit.
Investigating Prosecutor

BAGUIO CITY
}S.S.
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AFFIDAVIT-COMPLAINT
I, TREU G. KAUFER of legal age, Filipino Citizen,
single and a resident of 11 Munich Street, Baguio City,
state that:
1. That on May 3, 2019, at exactly 3:25 in the morning, I
was walking along Burnham lake;
2. Afterwards, a man who was identified later to be IRON
MANIAC pointed a gun to my face and said, Ilabas mo
pera kung ayaw mong ito na ang huling lakad mo sito
sa parke.
3. I was trembling and afraid that he would pull the
trigger, I gave my wallet containing Php30,000;
support of the charges for robbery against IRON
MANIAC.
TREU G. KAUFER
Affiant

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BAGUIO CITY
}S.S.
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AFFIDAVIT-COMPLAINT
state that:
1. I am the owner of a Nissan Infiniti QX30 which I parked
outside my house as my garage was under
construction;
2. As I was opening the shades of my window in the
morning of May 10, 2019, I saw PABLO S. KOBAR, my
former driver, forcibly entering my car by smashing the
windows;
3. Through certain method he was able to start the car
and ran off before I could even get out and stop him;
4. 30 minutes after I reported the incident, I received a
call from the Baguio City Police Office that PABLO was
apprehended;
support of the charges for carnapping against PABLO S.
KOBAR.
Affiant
am satisfied that he gave her statement freely and that he
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BAGUIO CITY
}S.S.
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AFFIDAVIT-COMPLAINT
I, SCHNE FRAU, of legal age, Filipino Citizen, single
and a resident of 535-80 Stuttgard Homes, Baguio City, after
having been sworn in accordance with law hereby state:
1. That on April 30 at 10 in the evening, I took the elevator
to my apartment which is on the 535th floor of Stuttgard
Uber Apartments;
2. Upon entering the elevator, the attendant on duty,
RONIC ALBERT, greeted me. I ignored the compliment for
I am usually shy and that I secretly had a crush on him.
3. He then said, Wag ka naming suplada madam. Ganda
pa naman ng T-back mong suot, kita dito sa likod. Di ba
yan makati sa puki?
4. Flattered by such remarks, I stayed silent and pretended
that I did not hear a word.
5. When we were on the 150th floor, RONIC ALBERT
suddenly grabbed my butt, pulled me close to him and
tore my shirt, pants and undergarments. He then said to
me, Wala ka nang kawala miss, matagal na kitang
pinagnanasahan!
6. Right then I knew of his intentions but I was not ready for
it and I was forced against my will. Shouting for help
would be useless in such a small, contained chamber.
7. He then proceeded to insert his penis into my vagina, he
has struggled to do so but I felt it was nearly in.
8. Before he could even successfully penetrate me, the
elevator door opened at the 535th floor.
9. RONIC ALBERT in urgency ran off the stairs shouting,
Tang ina naman oh! Ulo lang! Muntik na!
support of the charges for rape by sexual assault against
RONIC ALBERT.
SCHNE FRAU
Affiant
am satisfied that she gave her statement freely and that she
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BAGUIO CITY
}S.S.
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AFFIDAVIT-COMPLAINT
I, Hsslich E. Hdini, of legal age, Filipino Citizen,
single and a resident of 88 Bremen Road, Baguio City, after
having been sworn in accordance with law hereby state:
1. That on May 3, 2019, I met with CHIZ S. KUDERO who I
previously had transaction with regarding household
furniture;
2. We met at Tamli Taverns restaurant and from there he
escorted me to his van since he asked me to check on
some pieces of furniture that he said to be in his
partners loft;
3. While on the van, someone grabbed me from the back
and me inhale some chemical sprayed on a
handkerchief;
4. When I woke up, I recognized the place since it was
there where we had our previous transactions, my
hands were tied as well as my feet;
5. I overheard some of the men Kudero with saying,
Mukhang malaki ang kita natin dito sa nap-kidnap
nating ito ah. And the voice of Kudero saying, Oo
pare, sureball tayo dyan.
6. Little did they know I was trained in body contortion
that escaping was never a problem to me, only that I
had to wait for the perfect time to escape. And that
time came only 8 days after.
support of the charges for kidnapping against AL B.
BACH and four other unidentified men.

this 16th day of July 2019, in the City of Baguio, Philippines.
Hsslich E. Hdini
Affiant
of Baguio, Philippines, this 16th day of July 2019, I further
am satisfied that she gave her statement freely and that she
understood the contents of her affidavit-complaint.
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REPUBLIC OF THE PHILIPPINES

FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 1
Baguio City
PEOPLE OF THE PHILIPPINES
Plaintiff,
CRIMINAL CASE NO.
11-2
-versus-
FOR: Violation of
Domicile
JON D. SCHULTZ
Accused.
x--------------------------------------------------x
APPLICATION FOR PROBATION
The accused, thru counsel, states;
1. He is of legal age, single, Filipino citizen, and a resident
of 112 Frankfurt Square, Baguio City, Philippines;
2. On April 28, 2019 the Court rendered a Judgment on the
case convicting him of the crime of Violation of Domicile
and sentencing him to suffer the penalty of
imprisonment, the dispositive portion read as follows:
WHEREFORE, judgment is hereby rendered,
finding the accused guilty of Violation of
Domicile, penalized under Article 128 of the
Revised Penal Code, who is hereby sentenced to
suffer an indeterminate sentence from two (2)
years and four (4) months of prision correccional,
as minimum, to four (4) years, nine (9) months
and ten (10) days of prision correccional, as
maximum.
SO ORDERD.
3. In view of the foregoing judgment, the accused hereby
applies before the Court for probation;
4. The accused further states that he is not one among
those offenders disqualified to avail of the benefits of
probation, as provided under Section 9, of Presidential

Decree No. 968, as amended, to wit:
Section 9. Disqualified Offenders. The benefits of
this Decree shall not be extended to those:
(a) sentenced to serve a maximum term of
imprisonment of more than six years;
(b) convicted of any offense against the
security of the State;
(c) who have previously been convicted by
final judgment of an offense punished by
imprisonment of not less than one month and
one day and/or a fine of not less than Two
Hundred Pesos;
(d) who have been once on probation under
the provisions of this Decree; and
(e) who are already serving sentence at the
time the substantive provisions of this Decree
became applicable pursuant to Section 33
hereof.
5. The accused has not perfected nor does he intend to
perfect an appeal from the aforementioned judgment of
the Honorable Court;
6. He further undertakes to faithfully and religiously
comply with the conditions of the probation as provided
for under P.D. 956 (Probation Law of 1976) or as may be
ordered by the Honorable Court should this application
for probation be granted.
PRAYER
WHEREFORE, it is prayed that this pleading be noted
and made part of the records of the above-entitled case and
that this Application for Probation filed by the accused JON D.
SCHULTZ be granted.
Baguio City, Philippines this 17th day of May, 2019.

Counsel for the Accused
281 Tamlee Bldg., Simi Street, Baguio City
Roll No. 615234; IBP No. 10191
PTR No. 101231 April 30, 2019

SN. 990123; Baguio City
MCLE Comp. No. 990123-221
REQUEST FOR AND NOTICE OF HEARING

THE BRANCH CLERK OF COURT
Regional Trial Court
Branch 1, Baguio City
Please submit the foregoing Motion to the Court for its
consideration and approval immediately upon receipt hereof
and kindly include the same in the courts calendar for
hearing on Monday, May 23, 2019 at 9:30 in the morning.

Copy furnished:
Office of the City Prosecutor
Baguio City, Philippines

Branch 1
Baguio City
PEOPLE OF THE PHILIPPINES
Plaintiff,
CRIMINAL CASE NO.
10-77
-versus-
FOR: Violation of
Domicile
JON D. SCHULTZ
Accused.
x--------------------------------------------------x
ENTRY OF APPEARANCE AS COUNSEL
The undersigned counsel states:
1. That the undersigned counsel has just been retained by
the accused in the above-entitled case;
2. That henceforth, he respectfully prays that all copies of
pleadings, notices and orders be furnished to the
undersigned at his address indicated below.
PRAYER
WHEREFORE, it is prayed that the appearance of the
undersigned be noted.
Baguio City, Philippines, this 18th day of May, 2019.
Roll No. 615234; IBP No. 10191
PTR No. 101231 April 30, 2019
Copy Furnished: (personal delivery)
OFFICE OF THE CITY PROSECUTOR

Baguio city, Philippines

Branch 1
Baguio City
Plaintiff,
CIVIL CASE NO. 00-7888
-versus-
FOR: Specific Performance
JON D. SHULTZ
Defendant.
x--------------------------------------------------x
MOTION TO WITHDRAW AS COUNSEL
The undersigned counsel state that:
1. The undersigned counsel has already terminated his
attorney-client relationship with the Defendant JON D.
SHULTZ, particularly because of the latters act of
insisting that he and the undersigned commit bribery in
order to have a favorable judgment in this case;
2. The undersigned had continuously explained to the
defendant that it is not how the judicial system of the
Philippines work. However, he insists on such action;
3. Rule 22.01 paragraph (a) of the Code of Professional
Responsibility states that a lawyer may withdraw his
services when the client pursues an illegal or immoral
course of conduct in connection with the matter he is
handling;
4. As such, undersigned requests that he ba allowed by
this Court to withdraw his appearance in this case as
counsel for the defendant JON D. SHULTZ without the
latters express conformity.
PRAYER
WHEREFORE, it is prayed that the undersigned be
allowed to withdraw his appearance in this case as counsel
for the defendant, dispensing with the latters express

conformity, and the he be relieved of all his responsibilities
relative to this case.
Baguio City, Philippines, this 19th day of May, 2019.

Counsel for the Defendant
Roll No. 615234; IBP No. 10191
PTR No. 101231 April 30, 2019

Branch 1
Baguio City
JON BO N. JABI
Plaintiff,
CIVIL CASE NO. 0066172
-versus-
FOR: Collection for Sum of

Money
JON D. SCHULTZ
Defendant.
x--------------------------------------------------x
MOTION TO WITHDRAW AS COUNSEL
The undersigned states that:
1. The undersigned counsel can no longer fully represent
the interest of the respondent due to the inability of the
defendant to consult regularly with the undersigned
considering the conflicting schedules of the defendant
and the undersigned;
2. The defendant also signified their intention to seek the
services of another lawyer such that the foregoing
motion is with the conformity of the defendant.
PRAYER
WHEREFORE, it is prayed to this Court that the
undersigned be now relieved of his duties as counsel for the
defendant.
Baguio City, Philippines, this 20th day of May 2019.
Roll No. 615234; IBP No. 10191
PTR No. 101231 April 30, 2019

WITH CONFORMITY:
JON D. SCHULTZ
Defendant
Copy furnished:
ATTY. Primer A. Cambio
Counsel for Plaintiff
Unit 13C, 13rd Floor, SPECIFIC Building
Right There Road, Baguio City

Branch 1
Baguio City
CHARING G. TATUM
Plaintiff,
CIVIL CASE NO. HH-0077
-versus-
FOR: Specific Performance
JACK E. CHAN
Defendant.
x--------------------------------------------------x
MOTION TO WITHDRAW AS COUNSEL WITH
SUBSTITUTION
THE CLERK OF COURT
Regional Trial Court of the City of Baguio
Branch 1
ATTY. STEVEN JAN K. SAB-IT, counsel on record for
the defendant and to this Court moves to withdraw as
counsel of said defendant with the express consent of the
defendant as shown in this motion;
That in substitution thereof, ATTY. RONIC ALBERT D.
TREPTOR, whose services have been engaged by defendant
hereby enters his appearance as counsel for the defendant;
That upon approval of this Court, all pleadings, notices,
and papers in connection with this case be addressed to new
counsel ATTY. RONIC ALBERT D. TREPTOR with address at
Suite 420, Random Building, Session Road,
Baguio City
Baguio City, Philippines, this 21st day of May 2019.
OLD COUNSEL
Roll No. 615234; IBP No. 10191
PTR No. 101231 April 30, 2019

NEW COUNSEL
RONIC ALBERT D. TREPTOR
Roll No. 67777; IBP No. 101311
PTR No. 7777 April 30, 2019
SN. 670101-13-211; Baguio City
Suite 420, Random Building, Session Road,

Affidavit Complaint

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REPUBLIC OF THE PHILIPPINES}

11. I am executing this affidavit to file a formal complaint of

REPUBLIC OF THE PHILIPPINES}

at his last known address at 112 Guisad Surong, Baguio

IN WITNESS WHEREOF, I have hereunto set my hand

REPUBLIC OF THE PHILIPPINES}

SUBSCRIBED AND SWORN to before me, in the City

REPUBLIC OF THE PHILIPPINES}

SUBSCRIBED AND SWORN to before me, in the City

REPUBLIC OF THE PHILIPPINES}

SUBSCRIBED AND SWORN to before me, in the City

REPUBLIC OF THE PHILIPPINES}

REPUBLIC OF THE PHILIPPINES}

REPUBLIC OF THE PHILIPPINES}

SUBSCRIBED AND SWORN to before me, in the City

REPUBLIC OF THE PHILIPPINES}

SUBSCRIBED AND SWORN to before me, in the City of

REPUBLIC OF THE PHILIPPINES}

SUBSCRIBED AND SWORN to before me, in the City

REPUBLIC OF THE PHILIPPINES}

IN WITNESS WHEREOF, I have hereunto set my hand

REPUBLIC OF THE PHILIPPINES}

I, ERMITTLER P. ANKLGER, an Investigating

the cross. The witness remembers the victim

REPUBLIC OF THE PHILIPPINES}

SUBSCRIBED AND SWORN to before me, in the City

REPUBLIC OF THE PHILIPPINES}

REPUBLIC OF THE PHILIPPINES}

REPUBLIC OF THE PHILIPPINES}

IN WITNESS WHEREOF, I have hereunto set my hand

REPUBLIC OF THE PHILIPPINES

probation, as provided under Section 9, of Presidential

ATTY. STEVEN JAN K. SAB-IT

PTR No. 101231 April 30, 2019

REQUEST FOR AND NOTICE OF HEARING

ATTY. STEVEN JAN K. SAB-IT

REPUBLIC OF THE PHILIPPINES

Copy Furnished: (personal delivery)

OFFICE OF THE CITY PROSECUTOR

REPUBLIC OF THE PHILIPPINES

FOR: Specific Performance

for the defendant, dispensing with the latters express

ATTY. STEVEN JAN K. SAB-IT

REPUBLIC OF THE PHILIPPINES

FOR: Collection for Sum of

PTR No. 101231 April 30, 2019

REPUBLIC OF THE PHILIPPINES

FOR: Specific Performance

PTR No. 101231 April 30, 2019

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