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Republic of the Philippines

MUNICIPAL TRIAL COURT


Branch 5
Baguio City

ALEX PARKER,
Plaintiff, CIVIL CASE N0. 12-13254
For: Unlawful Detainer
v.

MILA COLIN,
Defendant,
x---------------------------------------x

C O M P L A I N T

Plaintiff, through undersigned counsel, and this Honourable Court
alleges:

1. That the plaintiff is single, Filipino citizen and residing at #37
Lower Dagsian, Baguio City, where he may be served with court
processes, motions ad decisions while the defendant is a Filipino
citizen, married and residing at No. 89 Everlasting St., Q.M.
Subdivision, Baguio City where he may be served with summons
and court processes;

2. That plaintiff is the owner of a land over which an apartment had
been constructed, located at Bakakeng Norte, Baguio City;

3. That by virtue of a contract of lease, plaintiff leased unto the
defendant the aforesaid apartment for a consideration of Php6,500
per month as rental to be paid within the first ten days of each
month starting January 1, 2014.

4. That the defendant failed to pay the agreed rental for several
months starting from May 2014 up to the present;

5. That on June 15, 2014, plaintiff sent a letter of demand to vacate
the apartment which was received by the defendant as shown in the
registry return receipt hereto attached; (Section 1, Rule16, par. J)

6. That despite said letter of demand which was repeated by oral
demands defendants failed and still refused to pay the agreed
amount of rentals and refused to vacate the apartment;


7. That by reason of the failure of the defendant to vacate the
premises and to pay the unpaid rentals, plaintiff was compelled to
file this complaint engaging the services of a counsel in the amount
of Php 15,000.

PRAYER

WHEREFORE, it is respectfully prayed that judgement be rendered
ordering the defendant to vacate the premises, to pay the rentals in the
amount of Php 26,000 and further rentals until the said defendant fully
vacates the premises and to pay the costs of the suit.

Plaintiff prays for such other remedy, as this Honourable Court may
deem just and equitable.

Baguio City, 13 August 2014.





ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the Plaintiff
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467



VERIFICATION and CERTIFICATION
AGAINST FORUM SHOPPING

JURAT

Republic of the Philippines
MUNICIPAL TRIAL COURT
Branch 2
Baguio City


SEAN PIPER,
Plaintiff,

v. CIVIL CASE No. 4598
For: FORCIBLE ENTRY
JONATHAN TAYLOR,
Defendant.

X----------------------------------------X


C O M P L A I N T


WITH UTMOST DEFERENCE TO THE HONORABLE COURT:

Plaintiff, by and through the undersigned Counsel unto the
Honourable Court, states:

1. Plaintiff is of legal age, Filipino, married, and a resident of #18
Valenzuela St., Salud Mitra, Baguio City;

2. Defendant is of legal age, Filipino, and a resident Wangal, La
Trinidad, Benguet, where he may be served with Summons and
other Court Processes;

3. Plaintiff is the owner of a parcel of land covered by Tax
Declaration No. 12345, declared under his name, and located at
#12 Maria Basa Compound, Baguio City, a copy of said Tax
Declaration is hereto attached as Annex A and made an
integral part hereof;

4. Sometime on 15 May 2014, without the Plaintiffs knowledge
and permission, Defendant, with several persons working under
them, through stealth and strategy, entered and fenced the
aforesaid property, photographs to this effect are hereto attached
as Annex B and made an integral part hereof;

5. Immediately upon learning of the Defendants act, Plaintiff
proceeded to the aforesaid property and confronted the
Defendant and their workers, however, Defendant ignored the
Plaintiff;

6. Thereafter, Plaintiff sought the assistance of Punong Barangay
Benny B. Dangpayan, but the same was futile because no
settlement was reached in said forum, thus, a certificate to file
action was issued, a copy of which is hereto attached as Annex
C and made an integral part hereof;

7. Up to the present time, Defendant and their workers are
continuously constructing the fence on the aforesaid property
against the will of the Plaintiff, in blatant violation of the right
of the Plaintiff;

8. The aforesaid act of the Defendant, if not restrained, would
work injustice to the Plaintiff;

9. 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
Honourable Court may fix;

10. As a consequence of Defendants malicious act and wrongful
deed as heretofore described, plaintiff suffered and will
continue to suffer sleepless nights, serious anxiety, wounded
feelings and grave moral shock for which she should be
compensated moral damages in the amount of P 50,000.00;

11. In order to deter Defendant and other persons from their ilk in
performing similar malicious acts, Defendant should be
assessed the amount of P 50,000.00 as and by way of exemplary
damages;

12. And finally, in filing this action in order to seek redress
for her grievances and recover damages, plaintiff was
compelled to engage the services of the undersigned Counsel
for an agreed fee of P 20,000.00 as and by way of acceptance
fee plus the sum of P1,500.00 as and by way of appearance fee
for each attendance in court during trial.

PRAYER


WHEREFORE, it is most respectfully prayed of this
Honourable Court that:

a. After due notice and hearing, a Preliminary Injunction be issued
forthwith to restrain Defendant from doing the act herein
complained of; namely, the fencing of the Plaintiffs
aforementioned property; and that after trial, said injunction be
made permanent;
b. After trial, judgment be rendered in favor of the Plaintiff
ordering Defendant to pay the Plaintiff:

The amount of P 50,000.00 as and by way of moral damages;
The amount of P 50,000.00 as and by way of exemplary
damages;
The amount of P 20,000.00 as and by way of attorneys fees,
plus the amount of P1,500.00 per attendance in Court as and by
way of appearance fees;

c. Costs.
d. Other reliefs, just and equitable under the premises, are likewise
prayed for.

Respectfully submitted this 13
th
day of August 2014, in the City of
Baguio.

ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the Plaintiff
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467


VERIFICATION AND CERTIFICATION
AGAINST FORUM SHOPPING

JURAT
Republic of the Philippines
REGIONAL TRIAL COURT
FI RST J UDI CI AL REGI ON
Branch 8
Baguio City


PINES CITY MEDICAL
ENTERPRISES,
Plaintiff,
Civil Case No. 0168
v. For: Collection of Sum
of Money

GIANNA ALEXANDRA,
Defendant.
x-------------------------------------------------x


MOTION FOR BILL OF PARTICULARS


Defendant, through the undersigned counsel and unto this Honorable
Court, avers:

1. That the plaintiff's complaint in paragraph 5 alleges:

From January 3 to May 3 2014, defendant never
paid anything to herein plaintiff. The check that he
issued as partial payment for the first month also
bounced. x x x(underscoring supplied)

2. The said allegation is not averred with sufficient definiteness and
particularity, specifically it does not mention the amount of the check
therein mentioned, its check number, date, and the drawee bank;

3. That a more definite statement on the matters as above-indicated is
necessary in order to enable the defendant to prepare its responsive
pleading because from the very onset of this controversy, the main
dispute was on what was actually and exactly agreed upon by the
parties as the amount of monthly rentals on the lease of plaintiff's
property;

4. However, due to the fact that defendant corporation had to transfer its
liaison offices depending on its project sites, the check stub where the
above-mentioned check came from was probably misplaced and could
no longer be found;

5. That a bill of particulars or a more definite statement as to particulars
of the said check which was allegedly issued by the defendants as
partial payment for the first month would definitely simplify the
issues in this case and hopefully expedite the negotiations between the
parties for an amicable settlement.

P R A Y E R

WHEREFORE, defendant most respectfully prays that an order be
issued by this Honorable Court requiring the plaintiff to make more definite
statement as to the particulars of the check mentioned in paragraph 5 of his
complaint, particularly stating its amount, check number, date, and the name
of the drawee bank.




Baguio City, Philippines this 13
th
day of August 2014.




ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the defendant
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467


Copy Furnished:

ATTY. BABY TANGGOL
Counsel for Plaintiff
53 Laperal Bldg., Session Road,
Baguio City, Philippines


Republic of the Philippines
REGIONAL TRIAL COURT
FI RST J UDI CI AL REGI ON
Branch 6
Baguio City

CHRISTOPHER LINCOLN,
Plaintiff, Civil Case No. CV-24
For: Collection of
v. Sum of Money

ADRIAN KENNEDY,
Defendant
x-------------------------x

MOTION FOR JUDGMENT ON THE PLEADINGS

The PLAINTIFF, through the undersigned counsel and to this
Honorable Court respectfully alleges:

1. That on April 9, 2014, plaintiff filed a complaint for collection of
sum of money in the amount of FIVE HUNDRED THOUSAND
PESOS (Php350,000.00) against defendant;
2. That in her answer, the defendant admitted the obligation, but she
was asking for an extension of time to pay her obligation and
instead the herein complaint was filed;
3. That the said answer admits the material allegations of the
complaint and has not tendered any issue;
4. That in view thereof, a judgment on the pleadings can be rendered.

WHEREFORE, it is respectfully prayed of this Honorable Court to
render judgment on the pleadings.

Baguio City, Philippines, August 13, 2014.





ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the plaintiff
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467

REQUEST FOR and NOTICE OF HEARING

PROOF OF SERVICE (Opposing Counsel)


















Republic of the Philippines
REGIONAL TRIAL COURT
FI RST J UDI CI AL REGI ON
Branch 8
Baguio City

PEOPLE OF THE PHILIPPINES,
Plaintiff,
Crim Case NO. 1234
v. For: Unjust Vexation

CONNOR PEYTON,
Accused.
x- - - - - - - - - - - - - - - - - - - - - - - -x


MOTION FOR POSTPONEMENT


The undersigned counsel for the accused respectfully prays for
Postponement of Hearing in the above-entitled case and respectfully
manifests that:

1. That he received the Notice of Hearing for Promulgation of Decision
dated August 9, 2014, on August 13, 2014;


2. That in the said Notice, the promulgation of the decision is set on
August 13, 2014, 9 oclock in the morning;


3. Unfortunately, counsel cannot appear on such date and time as he had
earlier committed himself to appear before the Regional Trial Court of
La Trinidad, Benguet, Branch 8, in the following cases:
a. PP vs. Mama Matay, Crim. Case No. 12888-R
For: Murder; and
b. PP vs. Homi Cider, Crim. Case No. 12889-R
For: Frustrated Homicide

Hence, this motion;

4. That counsel will be available on August 25, 2014 at 8:30 oclock in
the morning;


5. That this motion is not interposed to delay the proceedings of the case
but due solely for the reason afore-cited and that counsel offers his
sincerest apology.


PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this
Honorable Court to grant this motion and that the scheduled hearing on
April 19, 2013 be cancelled and reset to August 25, 2014 at 8:30 oclock in
the morning.

A General Relief is likewise prayed for.

Baguio City, Philippines, 13 August 2014.




ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the defendant
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467


NOTICE OF HEARING

PROOF OF SERVICE (Office of the Prosecutor)








Republic of the Philippines
COURT OF APPEALS
City of Manila

BRODY MORGAN,
Petitioner, CA-G.R. SP. No. 81753

v.

PINES CITY MEDICAL
ENTERPRISES, INC.
Respondents.
x------------------------------x

MOTION FOR RECONSIDERATION

Petitioner in the above-entitled case, by the undersigned attorney,
respectfully moves unto this Honorable Court to reconsider its order dated
December 31, 2013 and was received on January 8, 2014 on the following
grounds:

1) That the Employees Compensation rendered its Decision on August 28,
2013, consequently Petitioner filed a Motion for Reconsideration
however, it was denied and the decision of which was received by the
Petitioner on November 6, 2013;

2) That the undersigned admitted that she has inadvertently filed the Notice
of Appeal of the above entitled case to the ECC on November 20, 2013
to which a Notice of Appeal with Formal Entry of Appearance &
Motion for Extension of Time to File Petition with Payment of
Filing/Docket Fees was filed on December 18, 2013;

3) That the undersigned counsel prayed for an extension for filing the
petition, considering:
a. That he is saddled with out-of-town family affairs which include
inheritance matters;

b. That it is the policy of this Honorable Court of Appeals to certify
the documents of the case which will be taken from the office of
ECC in Manila, therefore the undersigned needs more time to
secure said documents in Manila; and

c. All government offices (ECC) were closed due to the Christmas
Holidays;

4) That the trend not to consider the delay in filing a claim for workmans
compensation as non-jurisdictional defect is justified by Article 24. The
employees compensation vis-a-vis the employer has always been a
marked disadvantage. (Central Azucarrera v. WCC, 133, Phil. 539)

There is a need of protecting the workman whose inferiority is
marked by his disadvantage. (Central Azucarrera Don Pedro v. WCC, 24
SCRA 484 [1968])

Art. 24 and 1332 of the Civil Code and the principles on contracts
of adhesion are exceptions to the general rule.

Art. 1332 which supplements Article 24 of the Civil Code reads:
When one of the parties is unable to read, or if the contract
is in a language not understood by him and mistake or fraud is
alleged, the person enforcing the contract must show that the terms
thereof have been fully explained to the former.

5) That to be candid with this Honorable Court, this counsel is a new
practitioner and her shortcomings should not bind the poor worker and
deprive him of justice;

6) That the Petition for Review was sent through registered mail on
December 20, 2013;

7) Thereby the undersigned counsel begs for the consideration of the
Petition for Review which was earlier sent on December 20, 2013.

PRAYER

WHEREFORE, it is respectfully prayed that the resolution on
December 31, 2013 be set aside and to consider the Petition for Review
which was earlier sent on December 20, 2013.

Baguio City, Philippines, this 13
th
day of August 2014.



ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the plaintiff
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467

JURAT

PROOF OF SERVICE (Opposing Counsel)

















Republic of the Philippines
REGIONAL TRIAL COURT
FI RST J UDI CI AL REGI ON
Branch 7
Baguio City

PEOPLE OF THE PHILIPPINES,
Plaintiff,

Criminal Case No. 144-A
v. For: Reckless Imprudence
Resulting in Damage
to Property
CHLOE JACOB,
Accused.
x----------------------------------------x


MOTION FOR REDUCTION OF BAILBOND


The accused, CHLOE JACOB, through the undersigned counsel in
the above-entitled case, and to this Honorable Court respectfully states that:


1. The accused, CHLOE JACOB, is charged for RECKLESS
IMPRUDENCE RESULTING IN DAMAGE TO PROPERTY
now pending before this Honorable Court with Criminal Case No.
144-A;

2. That the recommended bond for her provisional liberty is in the
amount of FIFTY THOUSAND PESOS (Php50,000.00);

3. That accused, considering that she is at this time suffering from
financial constraints, can only produce the amount of THIRTY
THOUSAND PESOS (Php30,000.00) CASH;

4. That accused needs her temporary liberty in order for her to gather
all the necessary evidence for her proper defense from this baseless
accusation which she cannot do if inside the prison;

5. That the accused together with her family is a permanent resident
of this City, particularly at 23 Salud Mitra, Baguio City, and
therefore the possibility for her to jump bail is too nil;

6. That the accused promise to attend all scheduled hearing in the
above entitled case and obeys all processes of this Honorable
Court.

PRAYER

WHEREFORE, premises considered and in view of the foregoing, it
is respectfully prayed to the Honorable Court that the recommended bond of
Php 50,000.00 will be reduced to Php30,000.00 CASH.


Other relief and remedies just and equitable under the premises are
likewise prayed for.

Baguio City, Philippines, this 13
th
day of August 2014.





ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the accused
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467


NOTICE FOR and REQUEST OF HEARING

PROOF OF SERVICE (Office of the Prosecutor)










Republic of the Philippines
REGIONAL TRIAL COURT
FI RST J UDI CI AL REGI ON
Branch 5
Baguio City


PETER SANTOS , CIVIL CASE NO. 6649-R
Plaintiff, For: Collection of Sum
v. of Money

MARIA DE CASTRO,
Defendant.
X-----------------------------------------------------X

MOTION TO DECLARE DEFENDANT IN DEFAULT

Plaintiff, by counsel and unto this Honorable Court, states that:

1. The records of the Honorable Court show that Defendant was served
with copy of the summons and of the complaint, together with
annexes thereto on July 18, 2014;
2. Upon verification however, the records show that Defendant MARIA
DE CASTRO has failed to file her Answer within the reglementary
period specified by the Rules of Court despite the service of the
summons and the complaint;
3. As such, it is respectfully prayed that Defendant MARIA DE
CASTRO be declared in default pursuant to the Rules of Court and
that the Honorable Court proceed to render judgment as the complaint
may warrant.

PRAYER

WHEREFORE, it is respectfully prayed that Defendant MARIA DE
CASTRO be declared in default pursuant to the Rules of Court and that the
Honorable Court proceed to render judgment as the complaint may warrant.

Other reliefs just and equitable are likewise prayed for.

Baguio City, Philippines, this 13
th
day of August 2014.




ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the plaintiff
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467

NOTICE OF and REQUEST FOR HEARING

PROOF OF SERVICE PROOF OF SERVICE:
1. Clerk of Court
2. Opposing Counsel



































Republic of the Philippines
REGIONAL TRIAL COURT
FI RST J UDI CI AL REGI ON
Branch 5
Baguio City


PEOPLE OF THE PHILIPPINES,
Plaintiff,
Crim. Case No. 11-1589-1617
v. For: Frustrated Murder


ENRIQUE CASTILLO,
and ROCKY ANDRADA
Accused-Appellants.
x---------------------------------------------x


MOTION FOR EXTENSION
OF TIME TO FILE MEMORANDUM


ACCUSED-APPELLANTS, through the undersigned counsel and
unto this Honorable Court, most respectfully manifests:

1. That on August 4, 2014, the undersigned counsel received the
Order of the Honorable Court dated July 25, 2014 requiring the accused-
appellants to file their Memorandum;

2. That the fifteen (15) day period within which to file the
Memorandum is due today August 10, 2014;

3. That due to heavy pressure of work, loads in preparing pleadings to
equally important cases and almost daily court appearances and attendance
of preliminary conferences as well as the voluminous record of the case, he
will not be able to finish and file the Memorandum;

4. That the undersigned most respectfully request for an extension of
at least ten (10) days counted from today August 10, 2014 until August 20,
2014 within which to file their Memorandum;

5. That this motion for extension is not intended to delay the
proceedings of the Honorable Court but due to the above-mentioned
reasons.


PRAYER

WHEREFORE, premises considered it is most respectfully prayed
unto this Honorable Court to allow the accused-appellants to file the
Memorandum within ten (10) days from today or until August 20, 2014.

Baguio City, Philippines. August 20, 2014.



ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the accused
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467


NOTICE OF HEARING

PROOF OF SERVICE:
1. Office of the Prosecutor
2. Clerk of Court

















Republic of the Philippines
REGIONAL TRIAL COURT
FI RST J UDI CI AL REGI ON
Branch 4
Baguio City

VICTORIA AQUINO,
Plaintiff,
Civil Case No. 559
V For: Collection of Sum
of Money with
Damages

MARY GRACE VALDEZ,
Defendant.
x - - - - - - - - - - - - - - - - - - - - - x


MOTION FOR EXECUTION OF JUDGMENT


Plaintiff, by the undersigned counsel, in the above-entitled case, and
unto this Honorable Court, states:

1. That a decision has been rendered in this case on July 9, 2014 in
favor of the Plaintiff and against the Defendant;

2. That the period for appeal has already expired without the
defendant having perfected an appeal from said decision;

3. That the said decision is now final and executor.


PRAYER


WHEREFORE, it is respectfully prayed that an order of execution of
the decision be issued.
Baguio City, August 13, 2014.


ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the palintiff
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467

NOTICE OF HEARING

PROOF OF SERVICE:
1. Clerk of Court
2. Opposing Counsel

































Republic of the Philippines
REGIONAL TRIAL COURT
FI RST J UDI CI AL REGI ON
Branch 8
Baguio City


PEOPLE OF THE PHILIPPINES,
Plaintiff, CRIM. CASE No. 1458
For: OTHER DECEITS under
v. Art. 318 of the Revised
Penal Code
CONRAD OCAMPO,
Accused.
x-----------------------------------------x

MOTION FOR RE-INVESTIGATION

Private Complainant through undersigned Private Prosecutor and
under the direct control and supervision of the Public Prosecutor and unto
this Honorable Court respectfully states:

1. That in an Information filed by the Office of the Prosecutor dated June
22, 2014, Accused, CONRAD OCAMPO was charged for ESTAFA
under other deceits of Article 318 of the Revised Penal Code in a
Complaint filed by the Private Complainant, RAMIL ASUNCION;
2. That the basis of the Honorable Public Prosecutor in charging the
Accused with Estafa is the provision on other deceits under Article
318 of the Revised Penal Code stating among others that, the
respondent or even her corporation do not actually own the lot sold to
the Private Complainant, the respondent must be held liable under
Article 318 of the Revised Penal Code.
3. That the Accused should have been charged for ESTAFA under
ARTICLE 315 Paragraph 2a of the Revised Penal Code and not
under Article 318 which provides that, ESTAFA could be committed
by means of false pretenses or fraudulent acts executed prior to or
simultaneously with commission of the fraud by using a fictitious
name, or falsely pretending to possess power, influence,
qualifications, PROPERTY, credit, agency, business transactions; or
by means of other similar deceits;
4. That the Affidavit Complaint of the Private Complainant stated
therein that the Accused obtained money from the Private
Complainant in the amount of FOUR HUNDRED THOUSAND
PESOS (PHP400,000.00) to be used to build a house over a property
which the Accused offered to the Private Complainant. It turned out
however that the land was not the property of RAMIL ASUNCION or
in the name of his corporation. With all the representations and false
pretenses made by the Accused that he owned a property and
assuming the obligation to build a house thereon but subsequently no
property or building was erected, shows that indeed the Accused only
deceived the Private Complainant to obtain his money;
5. That the act of the Accused in misrepresenting that he is the owner of
a lot being the subject of a house and lot package to obtain money
from the Private Complainant and misappropriating the same
constitutes the crime of ESTAFA under ARTICLE 315 Paragraph
2a of the Revised Penal Code;
6. That the Private Complainant, RAMIL ASUNCION respectfully
requests that a RE-INVESTIGATION be conducted on the above-
entitled case to resolve whether or not the case falls within the ambit
of ARTICLE 315 Paragraph 2a constituting the crime of ESTAFA
by falsely pretending to possess property and not ARTICLE 318 of
the Revised Penal Code;
7. That this Motion is not in any manner intended to cause delay in the
speedy disposition of this instant case or to frustrate the ends of
justice.

PRAYER

WHEREFORE, premises duly considered, it is most respectfully
prayed of the Honorable Court to GRANT this Motion for RE-
INVESTIGATION and to issue an Order for the RE-INVESTIGATION of
the above-entitled case.

Such other relief as law and justice may warrant are likewise prayed
for.

Respectfully submitted this 13
th
day of August 13, 2014 in the City of
Baguio, Philippines.

ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the palintiff
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467
With my conformity:
FRANCE MONTALBAN
Public Prosecutor

NOTICE OF HEARING

PROOF OF SERVICE:
1. Office of the Prosecutor
Opposing Counsel




































Republic of the Philippines
REGIONAL TRIAL COURT
FOURTH J UDI CI AL REGI ON
BRANCH 4
Palayan City, Nueva Ecija


PEOPLE OF THE PHILIPPINES,
Plaintiff,
CRIMINAL CASE No. 1234
v. For: Murder

KEVIN RAMOS,
Defendant.
x---------------------------------------------x


MOTION FOR JUDICIAL DETERMINATION OF PROBABLE
CAUSE


Accused KEVIN RAMOS, by undersigned counsel, most
respectfully move that this Honorable Court conduct a determination of
probable cause pursuant to Article III, Section 2 of the 1987 Constitution
and in support thereof state the following:

PREFATORY

The obvious involvement of political considerations in the
actuations of respondent Secretary of J ustice and respondent prosecutors
brings to mind an observation we made in another equally politically
charged case. We reiterate what we stated then, if only to emphasize the
importance of maintaining the integrity of criminal prosecutions in
general and preliminary investigations in particular, thus:

[W]e cannot emphasize too strongly that prosecutors should not
allow, and should avoid, giving the impression that their noble office is
being used or prostituted, wittingly or unwittingly, for political ends, or
other purposes alien to, or subversive of, the basic and fundamental
objective of observing the interest of justice evenhandedly, without fear or
favor to any and all litigants alike, whether rich or poor, weak or strong,
powerless or mighty. Only by strict adherence to the established procedure
may be publics perception of the impartiality of the prosecutor be
enhanced.

1. The Supreme Court, in a recent case also involving herein accused has
made the foregoing strong admonition against public prosecutors.

2. It is unfortunate that despite the admonition, the panel of prosecutors who
conducted the preliminary investigation of the instant cases chose to defy
such clear warning by no less than the Supreme Court, as will be discussed
below.

I n the conduct of preliminary investigation, the members of the
I nvestigating Panel committed grave prosecutorial misconduct which
deprived accused of their right to due process.
------------------------------------------------------


3. The preliminary investigation proceeding, like court proceedings, is
subject to the requirements of both substantive and procedural due process.

4. As an indispensable requirement of due process, the investigating
prosecutors must possess the cold neutrality of an impartial judge.

5. In the instant cases, however, accused-movant was denied due process
when the panel of public prosecutors committed the following grave
misconduct which also clearly showed that they did not possess the cold
neutrality of an impartial judge.

5.1. Despite failure to comply with the requirement under Rule 112,
Section 3 (a) of the Revised Rules of Criminal Procedure that the
affidavits of the complainants and his witnesses shall be subscribed and
sworn to before any prosecutor x x x, the investigating prosecutors
gave due course to the criminal complaints of the alleged widows,
instead of dismissing them outright.

5.2. The Investigating Panel refused to grant clarificatory hearing
despite the existence of important issues and matters to be clarified
before a fair resolution of the complaints may be made.

5.2.1. While it is true that the conduct of clarificatory hearing is not
mandatory, Rule 112, Section 3(e) directs that it be conducted when there
are facts and issues that must be clarified before the prosecutors can resolve
the cases.

5.2.2. Accused-movant repeatedly requested and insisted on the panel of
investigating prosecutors the need to require the complainants and their
witnesses to appear for confrontation with the accused-movant and for
clarificatory questioning.

5.2.3. Accused-movant identified the following important issues and crucial
facts that needed clarification:

a) Re the confession of Julius Caesar, the specific dates of the alleged
meetings attended by the accused-movant.

It is well to note that the accused-movant was linked by Julius Caesar to the
three killings as the alleged masterminds who had allegedly ordered the
liquidation of former CPP/NPA/NDFP members who were supporting
AKBAYAN party-list. Accused-movant pointed out that Julius Caesar failed
to specify the dates in which the alleged meetings were held and in this
connection manifested their intention to pose clarificatory questions.

b) Re the submission of the investigation report of the Philippine National
Police of Nueva Ecija on the deaths of Felipe, Peralta and Bayudang.

Accused-movant also pointed out that witnesses Alvaro Maximo, Cleopatra
Anthony and Julius Caesar executed their Sinumpaang Salaysay only March
18, 2013. The first two executed their Sinumpaang Salaysay on March 19,
2013 while Caesar executed his the following day.

After comparing the accounts of the above three witnesses with those who
gave their statements shortly after the alleged killings, accused-movant
noted glaring contradictions which support a reasonable conclusion that
there existed a pattern of suppressing evidence that were executed or
prepared shortly after the killings and that the suppressed evidence were
replaced by recent statements taken only in March 2013.



Given the above and considering that accused-movant was charged with
non-bailable crime of two counts of murder, the investigating panel should
have subpoenaed the complete result of the original police investigations on
the killings.

c) The need to establish the identity of the complaining witnesses

This Honorable Court can take judicial notice of the fact that when the
herein complaining witnesses filed a petition to disqualify accused-movants
party-lists for last years electoral contest, the same witnesses appeared
before the COMELEC with their faces covered with scarves. They refused
to remove these scarves on the shallow pretext of personal security, thereby
rendering questionable their real identities.

The panel of investigating public prosecutors should have dispelled doubts
over the complainants identities by requiring them to appear and making
themselves available for questioning in the presence of the accused-movant.

As stated in accused-movants letter dated 14 January 2013 addressed to the
panel of investigating prosecutors, what actually happened during the
supposed preliminary investigation was a hide and seek type of
proceedings whereby the complainants surreptitiously appeared before the
public prosecutors without notice to the accused-movant. A big question
remains: Was the panel able to confirm the identity of the complaining
witnesses?

d) There were material gaps, ambiguous and sweeping statements and
serious inconsistencies in the affidavits of Julius Caesar and the
complaining witnesses.

Accused-movant enumerated in their counter-affidavits and their subsequent
pleadings and letters submitted to the panel the material gaps and
inconsistencies in the claims of the newly surfaced witnesses with those of
the first-hand accounts of witnesses whose testimonies or statements were
secured shortly after the killings.

e) Lastly, considering that accused-movant has sufficiently shown that the
instant cases are part of the existing pattern to neutralize them, the panel of
investigators could have addressed this by making the complainants
available for questioning by the accused-movant.

In the same letter dated 14 January 2013, accused-movant insisted that a
clarificatory hearing with the appearance of the complainants and their
witnesses in an open public hearing was necessary considering that the
complainants and their witnesses are under the custody and control of their
military handlers.

Prosecution witnesses Alvaro Maximo, Cleopatra Anthony and Julius Caesar
claimed to be rebel returnees who have surrendered to and are likely to be
under the custody or protection of the military.

A clarificatory hearing could have given the public prosecutors and the
defense the opportunity to test the voluntariness and credibility of the
complainants and their witnesses. The panel of investigating prosecutors did
not only refuse to consider the foregoing reasons for accused-movant
request for clarificatory questioning, the panel even went to the extent of
accusing accused-movants of delaying the proceedings.

5.3. The need for clarificatory hearing is even admitted by panel
member Assistant Provincial Prosecutor Eddie Gutierrez who wrote by
hand his comment in the Joint Resolution dated 15 January 2013 that I
concur with the conclusion but I would have been more than satisfied if
the witnesses for the prosecution were present.

5.4. The panel readily dismissed accused-movants manifestation and
request to allow them to submit a Memorandum.

Although the submission of a Memorandum is not required, Section 33 of
the DOJ Manual for Prosecutors allows the filing of the same in cases
involving difficult or complicated questions of law or fact.

5.6. Despite express manifestation, the panel did not give the accused-
movants the opportunity to avail of their right to file a Motion for
Reconsideration pursuant to and within the period provided under
Section 56 of the Manual for Prosecutors.

The evidence submitted by the prosecution is insufficient to establish
probable cause against accused-movants.
------------------------------------------------------
6. An analysis of the evidence presented by the prosecution against each
accused-movant reveals the impossibility of the accused having participated
in the alleged killings.

PRAYER

WHEREFORE, premises considered, in the interest of justice and to
uphold the rule of law, accused KEVIN RAMOS prays for the proper
judicial determination of probable cause on this case.

Other forms of relief that are just and equitable under the premises are
also prayed for.
Baguio City. August 13, 2014.


ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the respondent
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467

NOTICE OF HEARING
PROOF OF SERVICE:
1. Clerk of Court
2. Opposing Counsel

























Republic of the Philippines
REGIONAL TRIAL COURT
FI RST J UDI CI AL REGI ON
BRANCH 4
Baguio City


PEOPLE OF THE PHILIPPINES,
Plaintiff,
Criminal Case No. 00567
v. For: Theft


ALVIN GARCIA,
Accused.
x ------------------------------------------ x


MOTION TO QUASH


THE ACCUSED, by counsel, respectfully moves to quash the
Information for the crime of theft on the following:

GROUNDS

1. IT CONTAINS AVERMENTS WHICH, IF TRUE,
WOULD CONSTITUTE A LEGAL JUSTIFICATION;

2. THIS COURT IS WITHOUT JURISDICTION.

In support, the accused respectfully states that:

ARGUMENT

The Information alleges that the accused ALVIN GARCIA is eleven
years old and without any known address. Under Article 12, paragraph 3 of
the Revised Penal Code, a person over nine years of age and under fifteen,
unless he acted with discernment, is exempt from criminal liability.

There is no allegation that the accused acted with discernment. Even
granting said discernment, the accused cannot be tried but instead proceeded
against under Article 80 of the Revised Penal Code, which provides that a
minor, unless sixteen years of age at the time of the commission of a grave
or less grave felony, cannot be tried but instead shall have the benefit of a
suspension of all proceedings against him. The duty of the court would be to
commit the minor to the custody or care of a public or private benevolent or
charitable institution for the care and education of homeless and delinquent
children or to the custody of the Department of Social Work and
Development.

PRAYER

WHEREFORE, it is respectfully prayed that the Information against
the accused be QUASHED and that the accused be released immediately
from detention.


City of Baguio. August 13, 2014.



ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the accused
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467


NOTICE OF and REQUEST FOR HEARING

PROOF OF SERVICE (Office of the Prosecutor)















ESTILLORE LAW OFFICE
285 Abanoa St., Baguio City
Cell No. 09328464813



August 22, 2014

Mrs. LEO KENDALL
San Fernando City,
La Union

GREETINGS:

We are writing you today in regard to the outstanding obligations owe
our client Mrs. JOSIE BUCLAY VALENZUELA. Our office has been
informed that the outstanding balance including stipulated interests amounts
to a total of Php 329,000.00.

Furthermore it has come to our attention that you have managed to
defraud our client of THIRTY FIVE THOUSAND PESOS ( Php 35, 000.00
) by ensuring payment thereof by means of a collateral that you had no right
over in the first place. Please see attached schedule for your refernce.

This serves as a final letter of demand for you to settle the
aforementioned obligations with our client within ten (10) days from receipt
of this notice. Failure on your part to comply within the period given will
constrain us to file the proper civil and criminal cases for ESTAFA against
you in court to exact performance of payment, plus damages, attorneys fees,
costs and probable conviction for the offense charged.

Please give this matter your most preferential attention to avoid
litigation and probable conviction.

Thank you.





Atty. Lawrence Patrick Estillore

Received by: ________________;
Date Received: ______________.









































REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 8, BAGUIO CITY

NOTICE OF ADVERSE CLAIM

The Register of Deeds
Baguio City

Sir:
The undersigned hereby files this adverse claim of undersigned on the
property covered by TCT No. 08190 of the Registry of Deeds of Baguio
City, and hereby states as follows:

The TCT No. 08190 covers a parcel of land which has the following
technical description:

A parcel of land situated at Quezon Hill, Baguio City,
bounded by the North by Lot No. 4852, on the East by the national
road; on the South by Lot No. 4816 and 4859 and on the West by Lot
No. 4818, containing an area of sixteen thousand (16,000) square
meters, more or less.

The undersigned bought said land from Daniel Padilla but since the
undersigned was a minor at the time of the purchase, he requested Mr.
Edwin Sawit, his uncle to register the same in his name for the
undersigneds benefit and to be held in trust for the undersigned, and his
uncle agreed and so the land was registered in his name.

The undersigned is the real and actual owner of said property, and not
the registered owner thereof, and to protect his interest thereto as actual
owner, this adverse claim is being registered on said TCT, to warn any third
person from buying the same.

Claimants address is #045, Central Pico, La Trinidad, Benguet.

Baguio City, Philippines, August 22, 2014.



_______________________
OLIVER SAWIT
Affiant




REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 8, BAGUIO CITY

GLADY MAE TALAN,
Plaintiff,

- versus- CIVIL CASE NO. CV - 1234

SHERLYN PAQUIT, For: Action to Recover Possession
Defendant. of Real Estate
x----------------------x
NOTICE OF COMMISSIONERS REPORT AND SETTING IT FOR
HEARING
_______________
Atty. CHRISTOPHER LINCOLN
Counsel for Plaintiff
2/F Porta Vaga Bldg.
Session Rd., Baguio City
_______________
Atty. ADRIAN KENNEDY
Counsel for Defendant
2/F Porta Vaga Bldg.
Session Rd., Baguio City

Please be notified that Commissioner HARRISON PAIGE has
submitted his report to the court on the issues referred to him by the order of
reference dated July 27, 2014. you are hereby given ten (10) days from
receipt hereof to signify your objections, if any, to the findings of the
commissioner.

After the 10-day period, please also be notified that the report will be
set for hearing on August 30, 2014 at 8:30 oclock in the morning, for
adopting, modifying or rejecting the report, in whole or in part, or requiring
the parties to present further evidence before the commissioner or the court.

Baguio City, Philippines, 22 August, 2014.






ATTY. LAWRENCE PATRICK P. ESTILLORE
Clerk of Court
Regional Trial Court
Branch 8, Baguio City
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 8, BAGUIO CITY

JASON BENTLY,
Plaintiff,

- versus- CIVIL CASE NO. CV - 1234

JACKSON ADDISON, For: Action to Recover Possession
Defendant. of Real Estate
x----------------------x

NOTICE OF DEATH OF PARTY

The undersigned counsel hereby gives notice that Mr. JACKSON
ADDISON died on August 15, 2014, his death certificate being attached
hereto as Annex 1.

The heirs or representatives of said deceased are the following:

1. Mrs. Linda K. Addison, who is the widower of the deceased and
presently residing at Km. 3, La Trinidad, Benguet;

2. Mr. Pablo Addison, the father of the deceased and residing at 355
Lower Brookside, Baguio City.

Baguio City, Philippines, 2 March, 2009.





ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the defendant
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467

Copy Furnished:

CARTER AVERY
Atty. For Plaintiff
2/F Porta Vaga Bldg.
Session Rd., Baguio City
REPUBLIC OF THE PHILIPPINES
MUNICIPAL TRIAL COURT
MAMBURAO, OCCIDENTAL MINDORO

PEOPLE OF THE PHILIPPINES,
Plaintiff, CRIMINAL CASE NO. CC-123

- versus- For: Theft

JEREMIAH QUIN,
Accused.
x-----------------------------x

NOTICE OF HEARING

ACCUSED, by counsel, hereby gives notice, within the required 15-
day period, that he is appealing the judgment of the Honorable Court, which
was promulgated on August 15, 2014, to the Regional Trial Court, the said
judgment being contrary to law and the facts.

Copy of this notice of appeal is served on the Office of the Prosecutor.

Accused moves and prays that the original bond for the provisional
liberty of the accused be considered and approved as his bond for his
provisional liberty during the pendency of the appeal.

WHEREFORE, accused prays that the records of the case be
elevated to the RTC for its action thereon, and that the original bond for the
provisional liberty of the accused be considered, maintained and approved as
his bond for his provisional liberty during the pendency of the appeal.

Mamburao, Occidental Mindoro, August, 22, 2014.

ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the defendant
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467


Copy Furnished:
____________
GIANNA ALEXANDRA
Atty. For Plaintiff
Office of the Prosecutor
Mamburao, Occidental Mindoro
REQUEST FOR & NOTICE OF HEARING

THE BRANCH CLERK OF COURT
Municipal Trial Court
Baguio City, Branch 6

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 Tuesday, 2 September 2014 at 8:30 in
the morning.

OLIVER SAWIT
44 Honeymoon Road
Baguio City

Please take notice that counsel has requested to be heard on Friday, 5
September, 2014 at 8:30 in the morning.



LAWRENCE PATRICK ESTILLORE
Counsel for Defendant
285 Abanoa St., Baguio City
































REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 8, BAGUIO CITY

PETER SANTOS,
Plaintiff,

- versus- CIVIL CASE NO. Cv-1234

MARIA DE CASTRO, For: Action to Recover Possession
Defendant. of Real Estate
x---------------------------x

NOTICE OF LIS PENDENS

To: Register of Deeds
Baguio City

Please be notified that on August 15, 2014, 2014, the plaintiff in the
above-entitled case filed an action, now pending trial in the RTC of Baguio,
for recovery of possession of real property of certain parcel of land is
situated in Quezon Hill, Baguio City, Philippines, and more particularly
described in TCT no. 08912 as follows, to wit:

A parcel of land situated at Quezon Hill, Baguio City,
bounded by the North by Lot No. 4852, on the East by the national
road; on the South by Lot No. 4816 and 4859 and on the West by Lot
No. 4818, containing an area of sixteen thousand (16,000) square
meters, more or less.

You are therefore requested to record this notice of the pendency of
the above-entitled action, for all legal purposes.


Baguio City, Philippines, August 22, 2014.




ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the plaintiff
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467

REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 8, BAGUIO CITY

MANUEL PACIO,
Plaintiff,

- versus- CIVIL CASE NO. CV - 1234

EMERSON APIDCHOR, For: Action to Recover Possession
Defendant. of Real Estate
x----------------------x

NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION
_______________
Atty. Sheera Manzano
Counsel for Defendant
3/F Porta Vaga Bldg.
Session Rd., Baguio City

Please take notice that on August 15, 2014 the undersigned counsel
for plaintiff in Civil Case No. CV-1234, entitled Action to Recover
Possession of Real Estate, RTC Baguio City, will take the deposition of
Ms. Mary Rose Milo, with address at # 56 Kayang Street, Baguio City,
before Notary Public Atty. Anna De Leon at the latters address on August
15, 2015 at 10:00 a.m., upon oral examination. The oral examination will
continue from day to day at the same time and place until the oral
examination is completed.

Baguio City, Philippines, 10 August, 2014.



ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the plaintiff
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467

Copy Furnished:
_______________ ___ _________________ ________________
Atty. Sheera Manzano Ms. Mary Rose Milo Atty. Anna De Leon
Counsel for Defendant # 56 Kayang St. 2/F Porta Vaga Bldg.
3/F Porta Vaga Bldg. Baguio City Session Rd., Baguio
Session Rd., Baguio City
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 8, BAGUIO CITY

CHLOE JACOB,
Plaintiff,

- versus- CIVIL CASE NO. CV - 1234

LILY JAMES, For: Action to Recover Possession
Defendant. of Real Estate

x----------------------x
NOTICE TO TAKE DEPOSITION UPON WRITTEN
INTERROGATORIES
________________
Atty. CARTER AVERY
Counsel for Defendant
3/F Porta Vaga Bldg.
Session Rd., Baguio City

Please take notice that on August 25, 2014 the undersigned counsel
for plaintiff in Civil Case No. CV-1234, entitled Action to Recover
Possession of Real Estate, RTC Baguio City, will take the deposition of
Mr. JACKSON ADDISON, with address at # 56 Kayang Street, Baguio
City, before Notary Public Atty. CONNOR PEYTON at the latters
address on August 25, 2014 at 10:00 a.m., upon written interrogatories and
to continue from day to day at the same time and place until the
interrogatories shall have been completed. Attached are the written
interrogatories.

Baguio City, Philippines, 22 August, 2014.

ATTY. LAWRENCE PATRICK P. ESTILLORE
Counsel for the plaintiff
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467