April 20, 2020

MS. ANGEL REYES

# 123, 1st Street, San Miguel
City of Manila

FINAL DEMAND

Madam:
We are writing on behalf of our client, JUAN DELA CRUZ, on the matter of your non-payment of your obligation.

Records disclose that you have an outstanding obligation with our client in the amount of Php100,000.00, with
interest at 8% per annum, and that despite repeated demands, you have failed and continuously fail to pay the aforesaid
amount.

Accordingly, FINAL DEMAND is hereby made upon you to settle the amount of Php100,000.00 within five (5)
days from receipt of this letter. Otherwise, we will be constrained to file the necessary legal action against you to
protect the interest of our client.

We trust that you will give this matter your prompt and preferential attention to avoid the expense and
inconvenience of litigation.

Truly yours,
(sgd.) ATTY. PEDRO SANTOS

AUTHORIZATION LETTER

Date: April 20, 2020

Dear Sir/madam,
I, JUAN DELA CRUZ, married, with residence at #123, 1 st Street, San Miguel, Manila and who is presently an
Overseas Filipino Worker based in Hong Kong, do hereby authorize ANGEL REYES-DELA CRUZ, my wife, of legal age, and
with residence at #123, 1st Street, San Miguel, Manila to file my Calamity Loan Assistance Application duly signed by me,
to sign and receive the Disclosure Statement under the Calamity Loan Assistance Program, and to receive the check in
my behalf.
(sgd.) JUAN DELA CRUZ
Member
SS No. 14344

(sgd.) Angel Reyes-Dela Cruz April 20, 2020

ATTACHMENTS
 A. Contract of Sale

DEED: TAF- CASSA

DEED OF SALE

THE PUBLIC IS INFORMED;

I, PROCOPIO C. CRUZ, of legal age, married, and residing at 12 Apo St. Quezon City, for and in consideration of
the sum of Php 100,000.00, hereby sell on an ‘as is where is’ basis my car, more particularly described as follows;

Make: Toyota Corolla 1987 Motor: EMC23456

Serial/Chassis: CDC09890 File: 233456
Reg. Cert.: 23455EC Plate: PPA 434

to Ricardo Lim, of legal age, married and residing at 2 Bangkal St., Manila

SIGNED this July 8, 2019 in Quezon City.

(SGD.) PROCOPIO C. CRUZ
Seller
With my consent:
(SGD.) Helen Y. Cruz
Spouse

Accepted: RICARDO LIM

Signed in the presence of :

(SGD.) JUAN L. MENDEZ (SGD.) ANITA K. WARD

ACKNOWLEDGEMENT

REPUBLIC OF THE PHILIPPINES )

CITY OF MANILA ) S.S

Procopio C. Cruz personally appeared before me this July 8, 2019 and I identified him through his Driver’s License
N12-2345-345 that expires on 24 May 2022. He executed the foregoing deed of sale and acknowledged to me that his
signature on it proves his voluntary act for the purposes stated in the document.

(sgd.) ATTY. NATHANIEL BONIFACIO

Notary Public for Manila
Commission Serial No. 1234
Until December 31, 2019
Roll of Attorney no. 1234
IBP No. 123/ Jan. 1, 2015/ City of Manila
PTR No. 123/Jan. 1, 2019/ City of Manila
Doc. No. 1;
Page No. 1;
Book No. 1;
Series of 2019.
 DEED OF SALE

THE PUBLIC IS INFORMED;

I, PROCOPIO C. CRUZ, of legal age, married, and residing at 12 Apo St. Quezon City, for and in consideration of
the sum of Php 1,000,000.00, hereby sell my one hectare parcel of land in Libmaan, Camarines Sur, more particularly
described as follows:

(Insert Technical Description here)

to Ricardo Lim, of legal age, married and residing at 2 Bangkal St., Manila

SIGNED this July 8, 2019 in Quezon City.

(SGD.) PROCOPIO C. CRUZ

Seller

ACKNOWLEDGEMENT

REPUBLIC OF THE PHILIPPINES )

CITY OF MANILA ) S.S

Procopio C. Cruz personally appeared before me this July 8, 2019 and I identified him through his Driver’s License
N12-2345-345 that expires on 24 May 2022. He executed the foregoing deed of sale and acknowledged to me that his
signature on it proves his voluntary act for the purposes stated in the document.

(sgd.) ATTY. NATHANIEL BONIFACIO

Notary Public for Manila
Commission Serial No. 1234
Until December 31, 2019
Roll of Attorney no. 1234
IBP No. 123/ Jan. 1, 2015/ City of Manila
PTR No. 123/Jan. 1, 2019/ City of Manila
Doc. No. 1;
Page No. 1;
Book No. 1;
Series of 2019.

NOTE: BONA FIDES OF CORPORATE ENTITY

SEEMON ENTERPRISES, INC. (SEI), a Philippine corporation with principal office at 10 S.E. Jayme St., Pakna-an, Mandaue
City, represented here by its Credit and Collection Manager, Ma. Narsisa C. Logomora, as confirmed by the attached
authority.
 B. Contract of Lease

Deed Form: TAF - CAS - SA

LEASE DEED
THE PUBLIC IS INFORMED:

I, TOMAS S. BALATAN, Filipino, of legal age, and residing at 1432 Mindanao Avenue, Quezon City, for and in consideration of
the monthly rent of Php 8,000.00 do hereby lease the apartment unit I own located at 1437 Mindanao Avenue, Quezon City for
one year from the signing date to JUAN N. BUELTA, Filipino, of legal age, and residing at 789 Craig St., Smapaloc Manila.

Added Warranties: Juan warrants that he received the apartment in good and habitable condition and undertakes not to sublet the
apartment to anyone without Tomas’s written consent.

SIGNED this 10th day of April 2019 in Quezon City

(SGD.) TOMAS S. BALATAN

Lessor
With my consent:
(SGD.) JUAN N. BUELTA
Lessee

Signed in the presence of:

(SGD.) JACINTO C. DEL PILAR (SGD.) FELICITO F. NANLUMO

ACKNOWLEDGEMENT
Tomas S. Balatan personally appeared before me this 10 th day of April 2019. I identified him through his Driver’s License ID No.
1234566 that expires on May 30, 2022. He executed the foregoing Lease Deed and acknowledged to me that his signature on it
proves his voluntary act for the purposes stated in the document.

Contract Form: TAA-RAC-SA

LEASE CONTRACT
The Public is Alerted:

This contract is executed between:

TOMAS S. BALATAN, Filipino, of legal age, and residing at 1435 Mindanao Avenue, Quezon City;
-and-
JUAN N. BUELTA, Filipino, of legal age, and residing at 789 Craig St., Sampaloc, Manila.

Tomas want to lease the residential apartment he owns located at 1437 Mindanao Avenue, Quezon City and Juan
expressed his desire to lease it from Tomas.

Consequently, the Parties mutually agree as follows:

1. Tomas shall lease to Juan the apartment unit for one year from the signing date of this contract.
2. Juan shall pay Tomas Php8,000.00 monthly rental payable in advance within the first five days of each month.
3. Juan warrants that he received the apartment in good and habitable condition.
4. Juan shall not sublet the apartment to anyone without Tomas’s written consent.
The deficiency of this contract shall be supplemented by existing law.

SIGNED this 10th day of April 2019, Quezon City

(SGD.) TOMAS S. BALATAN (SGD.) JUAN N. BUELTA

Signed in the present of

(SGD.) JACINTO C. TIRAPA (SGD.) FELICITO F. NANLUMO

(ACKNOWLEDGMENT)
 C. Special Power of Attorney

SPECIAL POWER OF ATTORNEY

The public is alerted:

I, Cesarmon Thanos, of legal age, and residing at 7 Special Street, Lidcombe, New South Wales, Australia, do
hereby appoint, Mung Goh, Filipino, of legal age, and residing at Kalipayan Street, Sagkahan, Tacloban City, to perform
for me any of the following acts:

1. To sell a parcel of land, registered in my name, consisting of 3.13 hectares more or less located at Alangalang,
Leyte, particularly described and covered by Transfer Certificate of Title T-1234 of the Registry of Deeds of Leyte;

2. In connection with the foregoing, to make, sign, execute, and deliver contracts and documents with any third
persons or entities upon terms acceptable to him; and

3. To receive in trust from the proper counter-party any form of payment (preferably in cashier’s check) for the
sale of the above-described property.

SIGNED THIS 2nd day of May 2019 in Tacloban City, Leyte

(SGD.) CESARMON THANOS

Principal
With my consent
(SGD.) MUNG G. GOH
Attorney-in-fact

Signed in the presence of:

(SGD.) Sansa Y. Stark (SGC.) Jorah T. Mormont

ACKNOWLEDGEMENT
REPUBLIC OF THE PHILIPPINES )
) S.S.

SPECIAL POWER OF ATTORNEY

KNOW ALL MEN BY THESE PRESENTS:

I, JOSEP, President of Barcelona, Inc. (the “Corporation”), a domestic corporation duly organized and existing
under and by virtue of the laws of the Republic of the Philippines, by virtue of and pursuant to the Resolution of the
Board of Directors of the Corporation passed and approved in its regular meeting on <<any date>> (a copy of which is
attached), do hereby name, constitute and appoint Atty. Xavi, to be my true and lawful attorney in-fact to act for and
in my behalf, to do and execute all or any of the following acts, deeds and things:
1. to represent the Corporation in all proceedings in, relating to, or arising out of the case filed by Mr. Leo,
entitled “Leo v. Barcelona, Inc. and Josep” (hereafter, “the Case”);
2. with full power to settle or dismiss the Case either totally or partially and perform, on behalf of the
Corporation, any act and deed which the Corporation could legally do and perform;
3. including the power to consider and agree on, among others, the possibility of an amicable settlement and
such other matters as may aid in the speedy and summary disposition of the case; and such matters as are
provided for in the pertinent provisions of the Rules of Court of the Philippines and/or the DOLE/NLRC Rules
of Procedure, as may be applicable.

HEREBY GIVING AND GRANTING unto said attorney-in-fact full power and authority whatsoever requisite or proper to be
done in or about the premises, as fully to all intents and purposes as I might or could lawfully do if personally present
and hereby ratifying and confirming all that my said attorney in-fact shall do or cause to be done under and by virtue of
these presents.

IN WITNESS WHEREOF, I have hereunto set my hand this this <<any date prior to hearing>> day of November 2020 at
<<any city>>.

JOSEP
Principal

ACKNOWLEDGMENT
REPUBLIC OF THE PHILIPPINES )
) S.S.

BEFORE ME, a Notary Public for and in <<any city>> on this <<any date prior to hearing>> day of November 2020,
personally appeared JOSEP with <<government issued ID type and number>> known to me and to me known to be the
same person who executed the foregoing Special Power of Attorney consisting of One (1) page including this page, and
acknowledged to me that the same is his own free and voluntary act and deed as well as the free and voluntary act and
deed of the corporation herein represented.

WITNESS MY HAND on the date and at the place first above-written.

NOTARY PUBLIC
Doc. No. ________ ;
Page No. ________ ;
Book No. ________ ;
Series of 2020.
VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

REPUBLIC OF THE PHILIPPINES )

CITY OF MANILA ) S.S.

I, Juan T. Dela Crus, of legal age, and a resident of #123, 1 st Street, San Miguel, Manila, plaintiff in the above-
entitled case, state under oath that:
1. I have read the above complain and that the allegations therein are true and correct of my own personal
knowledge and/or based on authentic records;
2. The pleading is not filed to harass, cause unnecessary delay or needlessly increase litigation costs;
3. The pleading’s factual allegations have evidentiary support;
4. I have not previously filed any action involving the same issues in any court, tribunal, or quasi-judicial agency
and that, to the best of my knowledge, no such action is pending in any of them; and
5. If I should later learn about the filing of such action, I shall report it to the court within five calendar days from
notice.

10 May 2020, Manila City

(SGD.) Juan T. Dela Crus
Affiant

JURAT
th
Signed and sworn to before me this 10 day of May, 2020 in the City of Manila, by Juan Dela Cruz with Passport
no. ED1234, issued on October 8, 2019, at DFA San Fernando, Pampanga.

(Notarial Certificate)

VERIFICATION & CERTIFICATION OF NON-FORUM SHOPPING

I, LEO, Filipino, of legal age, after having been sworn to in accordance with law, hereby depose and state that:

1. I am the complainant in the case entitled “Leo v. Barcelona, Inc. and Josep” docketed as NLRC Case No. 1010-10;

2. I have caused the preparation of this Position Paper;

3. I have read the contents herein and verify that the same are true and correct based on my own personal knowledge
and/or authentic records on hand;

4. I further certify that I have not commenced any other action or proceeding involving the same issue in any court or
any other tribunal or agency, and that to the best of my knowledge, no such action or proceeding is pending in any court
or any other tribunal or agency;

5. I further certify that should I learn that a similar action or proceeding, other than the aforementioned case, has been
filed or is pending before any court or any other tribunal or agency, I undertake to report such fact within five (5) days
therefrom to this Honorable Office.

LEO
Complainant-Affiant
 SUBSCRIBED AND SWORN to before me this <<any date prior to hearing>> day of November 2020 at <<any
city>>, Philippines, affiant exhibiting to me his <<competent evidence of identity>>

Notice of Hearing and Explanation in Motions

Republic of the Philippines

REGIONAL TRIAL COURT
National Capital Judicial Region
Branch 45, City of Manila

JUAN DELA CRUZ,

Plaintiff,
Civil Case No. 12345
-versus- For: Sum of Money

PEDRO SANTOS,
Defendant.
x-----------------------------------------------x
NOTICE OF HEARING

YOUR CASE IS SET for hearing before the Presiding Judge of this Court on April 24, 2020 at 1:30 OM.

YOU MUST ATTENT THE HEARING. IF YOU CANNOT ATTEND BECAUSE IT IS PHYSICALLY IMPOSSIBLE FOR YOU TO DO SO,
YOU MAY AUTHORIZE A REPRESENTATIVE WHO IS NOT A LAWYER TO APPEAR FOR YOU. FOR THIS PURPOSE, YOU SHOUL FILL UP
FORM 5-SCC (SPECIAL POWER OF ATTORNEY)

WITNESS, the HON. ANGEL REYES, Presiding Judge of this Court, this 1 st day of April, 2020, at Manila, Philippines.

JOANNA DELA CRUZ

Branch Clerk of Court

EXPLANATION
Due to the distance to the Plaintiff’s counsel and to manpower limitations, personal service is not practicable. The
undersigned counsel for the Defendant was constrained to file and/or serve this Motion by Registered mail.

ATTY. NATHANIEL BONIFACIO

Counsel for Defendant
Unit 1, Building X, Mendiola, Manila
Roll No. 12345: 1/11/15 - Manila
IBP No. 12345: 1/11/15 - Manila
PTR No. 12345: 1/11/2019 - Manila

PROOF OF SERVICE

NOTICE OF HEARING
ATTY. ANNE CUTIES
Counsel for Plaintiff
Madam:
Please be informed that the undersigned counsel has set the foregoing motion for hearing on APRIL 22, 2019 AT 8:30 A.M.,
for the consideration of the Honorable Court or soon thereafter as counsel may be heard.
 (sgd.) ATTY. LIZA SOBRANGANO
Counsel for Defendant
Judicial Affidavit
Republic of the Philippines
REGIONAL TRIAL COURT
National Capital Judicial Region
Branch 45, City of Manila
PEOPLE OF THE PHILIPPINES,
Plaintiff,
Criminal Case No. 12345
-versus- For: Estafa

JUAN DELA CRUZ,

Defendant.

x-----------------------------------------------x
JUDICIAL AFFIDAVIT

(of Prosecution witness PEDRO SANTOS in lieu of Direct Testimony)

I, PEDRO SANTOS, 33 years old, employed as a businessman, residing at #123, 1 st Street, San Miguel Manila, after
having been duly sworn in accordance with law, hereby depose and state:

PRELIMINARY STATEMENT

That the person examining me is ATTY. NATHANIEL BONIFACIO with law office address at Unit 1, Building X,
Mendiola, Manila. My Judicial Affidavit is being taken at the above-mention place in the presence of ANGEL REYES and
my companions.

That the questions are asked in English language but are translated in the Tagalog dialect which I speak and fully
understand and I am giving my answers fully conscious that I do so under oath and I am aware that I may face criminal
liability for false testimony or perjury for false statements made or given by me.

OFFER OF TESTIMONY

The testimony of witness PEDRO SANTOS is being offered:

1. To prove that he is an eyewitness to the crime of Estafa;
2. To testify on the transaction he had with the accused last July 7, 2019;
3. To identify the accused in open court as the person who committed the crime.

DIRECT EXAMINATION
Q1: Mr. Witness, will you please tell the Honorable Court your name, age and other personal circumstances:
A1: I am Pedro Santos, 33 years old, a businessman, and a resident of #123, 1 st Street, San Miguel, Manila.

Q2: Why are you here now?

 A2: To have a sworn statement by way of a judicial affidavit which shall constitute as my direct testimony, in the
above-entitled case.

Q3: What is the nature of your business:

A3: I am engaged in the buying and selling of jewelry.

Q4: How long did you endeavor your business:

A4: It started in 2006 sir.

Q5 How do you know Juan dela Cruz, the accused?

A5: He is one of the agents in my jewelry business.

THAT WILL BE ALL FOR THE WITNESS YOUR HONOR.

IN WITNESS WHEREOF, I have hereunto set my hand this 20 th of May, 2020, at Manila, Philippines.

(sgd.) PEDRO SANTOS

ATTESTATION
I, ATTY. NATHANIEL BONIFACIO, of legal age, with office address at Unit 1, Building X, Mendiola, Manila,
do hereby certify that:

I propounded questions to PEDRO SANTOS and faithfully recorded or caused to be recorded, the questions I
have asked and the corresponding answers that PEDRO SANTOS gave, as above stated.

Neither I nor any other person then present or assisting the witness coached the latter regarding his answers.

IN WITNESS WHEREOF, I have hereunto set my hand this 20 th day of May, 2020 at Manila, Philiippines.

(sgd.) ATTY. NATHANIEL BONIFACIO

Unit 11, Building X, Mendiola, Manila
Roll No.
IBP No.
PTR No.

JURAT
th
SUBSCRIBED and sworn to before me this 20 day of May 2020, in the City of Manila, by Pedro Santos with
Passport No. EB23345, issued on September 13, 2019 at DFA San Fernando, Pampanga.

(sgd.) ATTY. OTARIANA GRANDE

Notary Public for Manila
Commission Serial No. 123
Until December 31, 2021
Roll No.
IBP No.
Doc. No.: 1 PTR No.
Page No.: 2
Book No.: 3
Series of 2020
NOTARIAL CERTIFICATES:
JURAT

SUBSCRIBED and sworn to before me this 20th day of May 2020, in the City of Manila, by JUAN DELA CRUZ with
Passport No. EB12345 issued on January 2, 2019 at DFA Pampanga.

(sgd.) ATTY. NOTARIANA GRANDE

Notary Public for Manila
Commission Serial No. 123
Until December 31, 2021
Roll No. 1234; 4/20/06
IBP No. 1234/ Jan. 1, 2015/ City of Manila
PTR No. 1234 / Jan. 1, 2015/ City of Manila
MCLE No. I – 001233; 9/09/2015
MCLE No. II – 0032455; 9/09/2015

Doc. No. 1;
Page No. 2;
Book No. I;
Series of 2020

ACKNOWLEDGMENT MADE BY AN INDIVIDUAL

ACKNOWLEDGEMENT

BEFORE ME, this 20th day of May, 2020, in the City of Manila, personally appeared JUAN DELA CRUZ with
Passport No. EB123455, issued on January 2, 2019 at DFA San Fernando, Pampanga, known to me to be the same
person who executed the foregoing instrument, and he acknowledged to me that the same is his free act and deed.

IN WITNESS WHEREOF, I set unto my hand and seal on the date and place above written.

(sgd.) ATTY. NOTARIANA GRANDE

Notary Public for Manila
Commission Serial No. 123
Until December 31, 2021
Roll No. 1234; 4/20/06
IBP No. 1234/ Jan. 1, 2015/ City of Manila
PTR No. 1234 / Jan. 1, 2015/ City of Manila
MCLE No. I – 001233; 9/09/2015
MCLE No. II – 0032455; 9/09/2015

Doc. No. 1;
Page No. 2;
Book No. I;
Series of 2020
ACKNOWLEDGMENT MADE BY A CORPORATION

ACKNOWLEDGEMENT

BEFORE ME this 20th day of May, 2020, in the City of Manila, personally appeared Pedro Garcia, representing to
be the President of ABC Corporation, known to me to be the same person who executed the foregoing instrument for
and in behalf of the said corporation, and he acknowledged to me that the same is the corporate act and deed of ABC
Corporation, and that he is duly authorized to sign the same. The same Pedro Garcia exhibited to me his [Competent
Evidence of Identity] issued by [Official Agency] on [Date of Issuance].

IN WITNESS WHEREOF, I set unto my hand and sea on the date and place above written.

(sgd.) ATTY. NOTARIANA GRANDE

Notary Public for Manila
Commission Serial No. 123
Until December 31, 2021
Roll No. 1234; 4/20/06
IBP No. 1234/ Jan. 1, 2015/ City of Manila
PTR No. 1234 / Jan. 1, 2015/ City of Manila
MCLE No. I – 001233; 9/09/2015
MCLE No. II – 0032455; 9/09/2015

Doc. No. 1;
Page No. 2;
Book No. I;
Series of 2020

JURAT ACKNOWLEDGMENT
Refers to an act in which an individual on a single occasion: Refers to an act in which an individual on a single occasion:
1. Appears in person before the notary public and 1. Personally appears before the notary public and
presents an instrument or document; presents an integrally complete instrument or
2. Is personally known to the notary public or document;
identified by the notary public through competent 2. Is attested to by a person known to the notary
evidence of identity as defined by these Rules; public or identified by the notary public through
3. Signs the instrument or document in the presence competent evidence of identity as defined by
of the notary; and these Rules; and
4. Takes an oath or affirmation before the notary 3. Represents to the notary public that the signature
public as to such instrument or document on the instrument or document was voluntarily
affixed by him for the purposes stated in the
instrument or document, declares that he has
executed the instrument or document as his free
and voluntary act and deed, and, if he acts in a
 particular representative capacity, that he has the
authority to sign in that capacity.

Republic of the Philippines

REGIONAL TRIAL COURT
National Capital Judicial Region
Branch 45, City of Manila
STEVE ROGERS,
Plaintiff,
Civil Case No. 12345
-versus- For: Sum of Money

SUNRISE DEVELOPMENT CORPORATION

Defendant.

x-----------------------------------------------x
MOTION FOR EXTENSION OF TIME
TO FILE AN ANSWER

Defendant Sunrise Development Corporation (SDC), by counsel, states:

1. SDC’s Answer is due on May 7, 2020, after it received both the summons and a copy of the Complaint on April 7, 2020. But
since the matter has been referred to its counsel on April 29, 2020, for representation, counsel needs added time to study
the case and confer with SDC’s officers as regards its defenses.

2. It is, consequently, constrained to ask for an additional 30 days from May 7, 2020, or until June 6, 2020, within which to file
its Answer.

ACCORDINGLY, SDC asks the Court for an extension of 30 days from June 7, 2020 or until July 7, 2020 within which to file its Answer.
Other reliefs just and equitable are also asked for.

Manila, Philippines. May 5, 2020

(sgd.) ATTY. NATHANIEL BONIFACIO
Counsel for Defendant
NOTE: A non-litigious motion, such as a motion for Unit 1, Building X, Mendiola, Manila.
extension to file answer, “shall not be set for hearing and Roll No. 12345
IBP No. 123456:
shall be resolved by the court within FIVE CALENDAR DAYS PTR No. 12456
from receipt thereon. MCLE I
MCLE II

Notice and Copy Furnished;

ATTY. SUNDAY S. DOMINGO

Counsel for Plaintiff Steve Rogers
(Address)

Madam:

Please take notice that the undersigned counsel shall submit the foregoing motion for the Court’s resolution on
May 8, 2020, Friday, at 2:00 PM.

(sgd.) ATTY. NATHANIEL BONIFACIO

Counsel for Defendant

NOTE: Sec. 11, Rule 11 of the 2019 Amendments provides –

“Section 11. Extension of Time to File an Answer. – A defendant may, for meritorious reasons, be granted an additional period of not more than 30
calendar days to file an answer. A defendant is only allowed to file one motion for extension of time to file an answer.
A motion for extension to file any pleading, other than an answer, is prohibited and considered a mere scrap of paper. The court, however, may
allow any other pleading to be filed after the time fixed by these rules.”
Republic of the Philippines
REGIONAL TRIAL COURT
National Capital Judicial Region
Branch 45, City of Manila
PEDRO C. LABO,
Plaintiff,
Civil Case No. 12345
-versus- For: Sum of Money

JOKOY LINAW, OPC.

Defendant.

x-----------------------------------------------x
MOTION TO DISMISS

Defendant Jokoy Linaw, OPC (JLO), by counsel, moves to dismiss the complaint filed by Pedro C. Labo(Pedro) on the sole
ground that the court has no jurisdiction on the subject matter of the complaint.

ARGUMENT

Undoubtedly, Pedro has been appointed as Vice-President for Special Concerns and Administration in JLO. But that office
was simply a creation of JLO’s President, Mr. Jokoy Linaw, pursuant to his function as sole director and president of JLO, a one
person corporation. Nothing in the Articles of Incorporation and by-laws that JLO submitted to the Securities and Exchange
Commission ever stated that Pedro’s position is a corporate office. Accordingly, Pedro was an ordinary, not a corporate officer. His
claims of illegal removal from office and recovery of his other benefits are thus well within the jurisdiction of another tribunal and
not this Court

Relief

ACCORDINGLY, JLO asks that Pedro’s complaint be dismissed fortwith for utter lack of jurisdiction.

Other reliefs just and equitable are also asked for.

Manila, Philippines. May 5, 2020

(sgd.) ATTY. NATHANIEL BONIFACIO
Counsel for Defendant
Unit 1, Building X, Mendiola, Manila.
Roll No. 12345
IBP No. 123456:
PTR No. 12456
MCLE I
MCLE II
Copy Furnished;
ATTY. SUNDAY S. DOMINGO
Counsel for Plaintiff Pedro C. Labo
(Address)

Madam:
Please take notice that the undersigned counsel shall submit the foregoing motion to dismiss for the Court’s
resolution on May 8, 2020, Friday, at 2:00 PM.
(sgd.) ATTY. NATHANIEL BONIFACIO
Counsel for Defendant
NOTE: Only four grounds now may justify the filing of a motion to dismiss, to wit: lack of jurisdiction over the subject
matter of the case, litis pendentia, res judicata, and prescription. Outside of these grounds, a motion to dismiss may be
denied forthwith.

Republic of the Philippines

REGIONAL TRIAL COURT
National Capital Judicial Region
Branch 45, City of Manila
STEVE ROGERS,
Plaintiff,
Civil Case No. 12345
-versus- For: Sum of Money

SUNRISE DEVELOPMENT CORPORATION.

Defendant.

x-----------------------------------------------x
MOTION TO DECLARE IN DEFAULT

Plaintiff Steve Rogers, by counsel, states:

1. Defendant Sunrise Development Corporation (SDC) received both summons and a copy of the Complaint on April 2, 2020, a fact certified
to by the court sheriff. SDC, therefore, has until May 2, 2020 to file its Answer.

2. More than 30 days have lapsed since it received the summons yet to date, SDC has not filed the requisite Answer nor has it filed any
extension motion for such purpose. Consequently, SDC deserves to be declared in default.

RELIEF

ACCORDINGLY, Steve asks the Court that after the due proceedings, an order be issued:
(a) Declaring SDC in default; and
(b) Setting a date convenient to the calendar of both the Court and Plaintiff’s counsel authorizing Steve to present its evidence ex-parte
before the branch clerk of court.

Other reliefs just and equitable are also asked for.

Manila, Philippines. May 10, 2020

(sgd.) ATTY. NATHANIEL BONIFACIO
Counsel for Defendant
Unit 1, Building X, Mendiola, Manila.
Roll No. 12345
IBP No. 123456:
PTR No. 12456
MCLE I
MCLE II
Copy Furnished;
The President
Sunrise Development Corporation
(Address)

Madam:
Please take notice that the undersigned counsel shall submit the foregoing motion for the Court’s resolution on May 11, 2020,
Friday, at 2:00 PM.
(sgd.) ATTY. NATHANIEL BONIFACIO
Counsel for Defendant

NOTE: In case of litigious motions such as motions to dismiss or motions to declare the defendant in default –
a. All motions shall be served by personal service, accredited private courier or registered mail, or electronic means so as to ensure their receipt
by the other party.
b. The opposing party shall file his/her opposition to a litigious motion within five calendar days from receipt thereof. No other submissions shall
be considered by the court in the resolution of the motion.
c. The motion shall be resolved by the court within 15 calendar days from its receipt of the opposition thereto, or upon expiration of the period
to file such opposition.
d. The court may, in the exercise of its discretion, and if deemed necessary for its resolution, call a hearing on the motion. The notice of hearing
shall be addressed to all parties concerned, and shall specify the tiem and date of the hearing.

QUITCLAIM IN LABOR CASES:

QUITCLAIM

I, LEO, Filipino, of legal age, and a resident of <<address>> hereby acknowledge receipt from Barcelona, Inc. and
Josep, the total amount of ONE MILLION PESOS (PhP1,000,000.00), as and by way of financial assistance and as full and
complete settlement/satisfaction of all my claims in connection with the Illegal Dismissal Case which I filed against
Barcelona, Inc. and Josep entitled “Leo v. Barcelona, Inc. and Josep,” docketed as NLRC Case No. 1010-10 (hereafter the
“Labor Case”).

In consideration thereof –

1. I release, remise and forever discharge the Barcelona, Inc., Josep and/or its affiliates, divisions, successors,
assigns and the employees, officers, directors and agents thereof (collectively, the “Released Parties”), of and from any
action, suits, claims, charges, complaints, promises and contracts (whether oral or written, express or implied from any
source), whatsoever, in law or equity, which I may now have or hereafter can, shall or may have against Barcelona, Inc..

2. I further warrant that neither I nor my heirs or assigns will institute any action against the Barcelona, Inc.
and/or its affiliates, divisions, successors, assigns and the employees, officers, directors and agents thereof, by reason of
Josep’s engagement of Los Blancos, Inc. Neither shall I participate, actively or inactively, in any present and future action
or claims filed against Barcelona, Inc. or its respective officers/agents, by any person or entity for whatsoever purpose or
end.

3. I shall not at any time and in any manner whatsoever directly or indirectly disclose to any person or entity the
terms and provisions of this document nor of any confidential information relating to the business or operations of the
Barcelona, Inc., unless upon prior written consent of its authorized officers. I acknowledge that any unauthorized
disclosure of any of the terms and conditions of this document may be a ground for an action for damages against me.

4. I agree that I will not in any way disparage Barcelona, Inc., its current and former officers, directors and
employees, or any Released Party, or make or solicit any comments, statements, or the like to the media or to others
that may be considered to be derogatory or detrimental to the good name or business reputation of any of the
aforementioned parties or entities.

5. I acknowledge that this Quitclaim shall be governed by Philippine laws.

6. I finally declare that I have read and fully understood this document entitled Quitclaim, and have affixed my
signature hereunder voluntarily and freely with full and complete knowledge of the import and intent of this document
and of my rights under existing laws and rules.

IN WITNESS HEREOF, I have hereunto signed this affidavit on the <<any date prior to hearing>> day of November
2020 in <<any city>>.
 LEO
Affiant

QUITCLAIM AND RELEASE (affidavit form)

I, Bernardo B. Sales, of legal age, married, and residing at 801 Naujan St., Calamba City, Laguna, state under oath:

1. I acknowledge to my full and complete satisfaction that I have received the sum of Php 50,000.00 by way of financial
assistance from Seize Tomorrow Corporation(STC), holding office at Balut, Tondo, Manila.

2. I now admit that I have no further claim or cause of action against STC, its officers or employees with respect to any matter
incident to or arising out of my previous employment. Consequently, I will institute no action with respect to it even as I
now release and forever discharge the company, its officers and employees from any claim, cause of action, or any further
obligation in connection with it. I fully acknowledge that the consideration received is and shall be the full and final
settlement of any and all such claims.

3. Finally, I declare that I have read this document and this document and the quitclaim given is made willingly and voluntarily
of any and all such claims.

SIGNED this 6th day of June 2019 in Calamba City, Laguna

(SGD.) Bernardo B. Sales
Affiant

SIGNED AND SWORN before me this 6th day of June 2019 by affiant whom I personally know.

(SGD.) Atty. Juan C. Mendoza

Notary for Calamba City, Laguna
Suite 212 Burke Building, Calamba City, Laguna
Commssion Serial 123455
Until Dec. 31, 2019
Roll of Attorney No. 12345
PTR No. 12345 1-12-19; Calamba City
IBP No. 12345 1-12-19; Calamba City

Doc. 1;
Page 2;
Book 3;
Series of 2019.

QUITCLAIM AND RELEASE (deed form)

THE PUBLIC IS INFORMED;

I, Bernardo B. Sales, of legal age, married, and residing at 801 Naujan St., Calamba City, Laguna, for and in consideration of
Php 50,000.00 by way of financial assistance that I just received, hereby admit that I have no further claim or cause of action against
Seize Tomorrow Corporation (STC), my former employer, that holds office at Balut, Tondo, Manila, its officers or employees with
respect to any matter further incident to or arising out of my previous employments.

Consequently, I will institute no action with respect to it even as I now release and forever discharge STC, its officers and
employees from any claim, cause of action or any further obligation in connection with it. I fully acknowledge that the consideration
received is and shall be the full and final settlement of any and all such claims.

SIGNED this 6th day of June 2019 in Calamba City, Laguna.

(SGD.) Bernardo B. Sales

Employee
Bernardo B. Sales, whom I personally know, appeared before me this 6 th day of June 2019. He executed the foregoing Quitclaim and
Release Form and acknowledged to me that his signature therein proves his voluntary act for the purposes stated in the document.

Promissory note

PROMISSORY NOTE

For value receive of Php 1,500,000.00, I, RICARDO C. GONZALES, of legal age, married, and residing at 1340
Amihan Road, Paseo de Encantadia, Cainta, Rizal, do hereby promise to pay ERNESTO G. ROMAN, of legal age, single
and residing at 2345 Zafiro Street, San Andres Bukid, Manila, the full amount that I received above plus interest of 12%
per annum exactly on the second year for the date of this note.

In case of litigation arising from or in connection with this note, the venue for trial shall be the competent court
of the City of Manila to the exclusion of all others and an amount equivalent to 25% of the total claim shall be due and
demandable as attorney’s fees.

SIGNED this 9th day of June 2017, in Manila.

(SGD.) RICARDO C. GONZALES

Promissor/ Borrower

With my consent:
(SGD.) ROSELLE G. GONZALES
Spouse

ACKNOWLEDGEMENT
Ricardo C. Gonzales, whom I personally know, appeared before me this 9 th day of June 2017. He executed the foregoing
promissory note and acknowledge to me that his signature on it proves his voluntary act for the purpose stated in it.

PROMISSORY NOTE

FOR VALUE RECEIVED, I promise to pay to the order of ADAM, the sum of FIVE HUNDRED THIRTY THOUSAND
PESOS (PhP530,000.00) Philippine Currency, payable on 31 December 2022. Should I fail to pay on the due date, a late
penalty fee of two percent (2%) per month shall be added to the principal and interest starting from the due date
thereof until the principal and all interests are fully paid.
Sgd.
LeBron

April 20, 2020

P500,000

Ninety days after date, I promise to pay to the order of PEDRO SANTOS the sum of P500,000.00, with interest at 3% per
annum, until fully paid. The maker and indorsers severally waive presentment for payment, protest, and notice of non-
payment of this note.
 (sgd.) JUAN DELA CRUZ
Maker

RETAINER CONTRACT

KNOW ALL MEN BY THESE PRESENTS:

This CONTRACT is made and executed by and between;

JUAN DELA CRUZ, hereinafter referred to as the “CLIENT”;

- and -

REYES-REYES LAW OFFICE, a law firm organized under and by virtue of the laws of the Republic of the Philippines
as a general professional partnership, with principal office at Unit 1, Building Y, Malate, Manila, Philippines, and
represented in this act by its Managing Partner, ANGEL REYES; and hereinafter referred to as the “LAW FIRM”;

WITNESSETH:

WHEREAS, the LAW FIRM has offered its professional legal services to the CLIENT and CLIENT agrees to retain
the professional legal services of the LAW FIRM under a retainership basis, subject to the terms and conditions
hereinafter stipulated:

NOW THEREFORE, for and in consideration of the mutual covenants and agreements herein agreed upon, the
CLIENT and the LAW FIRM, by these presents, have entered, as they hereby enter, into a contract of services whereby
the LAW FIRM shall render legal services to the CLIENT, under the following terms and conditions:

1. The term or duration of this contract shall be for one year, effective upon signing of this agreement and shall
automatically be renewed on a year to year basis unless either party pre-terminates the same upon serving a 30
day prior written notice to the other party, without need of cause; the LAW FIRM, while in the performance of
its duties, shall be entitled to a fixed monthly retainer fee of P28,000.00;

2. The LAW FIRM shall make itself available for ready consultation by the CLIENT or its duly authorized officers in all
matters or business requiring legal advice and opinion affecting the said corporation in general. Written opinions
rendered by the LAW FIRM on matters affecting the business and operations of the corporation shall be subject
to confirmations;

3. The LAW FIRM shall render documentation and notarial services to the CLIENT as part of tis retainership. Client
documents shall be notarized free of charge while documents requiring the participation and signature of a
party other than the CLIENT shall be subject to additional fees and charges;

4. The LAW FIRM shall handle other cases as referred to it by the CLIENT for a fee that shall be determined by
mutual agreement of the LAW FIRM and the CLIENT, on a case to case basis, such as, but not limited to, all suits
or cases for or against the CLIENT, including officers and employees of the CLIENT sued in their official capacity;
 5. Clerical and routine expenses for mailing of demand letters, pleadings to court and copies thereof to adverse
parties, costs of photocopy or evidentiary documents, payment of stenographic notes, costs of publications of
notices, as well as filing fees and other legal expenses in court and other appropriate government offices shall be
for the account of the CLIENT;

6. The LAW FIRM shall not, either during the term of tis contract or any time thereafter, use or disclose to any
person, office, corporation or entity any confidential information concerning the affairs of the CLIENT which the
LAW FIRM may have acquired in the course of or as incident to this contract for its own benefit, or to the
detriment or probable detriment of the CLIENT;

7. Any violation of the terms and conditions of this contract by the LAW FIRM shall give the CLIENT the option to
rescind or cancel immediately the contract without necessity of judicial proceedings;

8. The LAW FIRM reserves the right to terminate this Agreement upon giving a 30-day written notice to the CLIENT;

9. Likewise, the CLIENT has the right to terminate this Agreement upon giving a 30-day written notice to the LAW
FIRM

IN WITNESS WHEREOF, the parties have signed this instrument this 20 th day of April, 2020, at the City of
Manil, Philippines.

JUAN DELA CRUZ

Client

ANGEL REYES
Managing Partner, Reyes-Reyes Law Office