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Republic of the Philippines

National Capital Judicial Region


METROPOLITAN TRIAL COURT
Quezon City, Branch 32
Alabaster Graves,
Plaintiff-Appellant,
Criminal Case No. 01-975413
- versus Richter Belmont,
Defendant-Appellee,
x-----------------x
MOTION FOR BILL OF PARTICULARS
Defendant, through the undersigned counsel and unto this Honorable Court,
respectfully avers:
1. That the plaintiff's complaint in paragraph 5 alleges:
"From August 3 to December 2013, 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 simplify
the negotiations between the parties for an amicable settlement.

PRAYER
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.
Quezon City, Philippines, January 23, 2014
ATTY. ROMMELITO FRANCISCO
MACARAYO
counsel for the defendant
13-69 Barracks Building, Marikina
IBP NO. 87123-7/19/12-AC
PTR NO. 669913/21/12-AC
Roll No. 99998
MCLE Exempt
(Admitted to the bar: April 6, 2012)
NOTICE OF HEARING
Atty. Ezekiel Razon
Counsel for the Plaintiff
12-26 Marina Arcade, Mabalacat City
Greetings! Please take notice that the foregoing Motion for Bill of Particulars shall
be submitted for the consideration and approval of the Honorable Court on Friday,
January 24, at 10:00 AM or as soon as counsel and matter may be heard.
Atty. Rommelito Francisco Macarayo
EXPLANATION
The foregoing Motion for a Bill of Particulars is being filed with this Honorable
Court and served on the opposing counsel by registered mail in view of the
impracticability of personal filing and service due to distance considering that the office
of this Honorable Court is at Quezon City and that of the opposing counsel is at
Mabalacat City, while undersigned counsel holds office in Marikina.
Atty. Rommelito Francisco Macarayo
COPY FURNISHED:
Atty. Ezekiel Razon
Counsel for the Plaintiff
12-26 Marina Arcade, Mabalacat City

Republic of the Philippines


MUNICIPAL TRIAL COURT IN CITIES
10th Judicial Region
Malaybalay City
PEOPLE OF THE PHILIPPINES,
Plaintiff,

Criminal Case No. 100


FOR: THEFT

-versusPEDRO CRUZ,
Accused.
x----------------------------------------------------x
URGENT MOTION FOR POSTPONEMENT
COMES NOW, the undersigned counsel for the defendant and unto this
Honorable Court, most respectfully manifests:
1.

That a notice of hearing for the above titled case was received by the undersigned last
November 7, 2007 informing the undersigned for the scheduled hearing on November
21, 2007, 8:30 oclock in the morning. (Machine copy of the notice duly received by
the undersigned is hereto attached and marked as annexA);

2.

That on November 6, 2007, a day prior to the date when the abovementioned notice
was received, the undersigned counsel also received a another notice of hearing
scheduled on the same date, November 21, 2007, 8:30 oclock in the morning in a case
for Theft entitled People of the Philippines vs. John Doe filed by the City Prosecutor
of Valencia City docketed as Criminal Case No. 001, for which case the undersigned is
a counsel for the defendant. (Machine copy of the notice of hearing duly received
by the undersigned is hereto attached and marked as annex B);

3.

That there is therefore a conflict of schedule for the hearing scheduled on November 21,
2007, 8:30 oclock in the morning, for the two (2) cases handled by the undersigned
counsel ;

4.

That the undersigned counsel is constrained to appear on the case cited in paragraph
2 of this motion, the notice of which was received by the undersigned ahead of the
notice of the above titled case, on November 6, 2007.
WHEREFORE, premises considered, it is most respectfully prayed to this
Honorable Court that the scheduled hearing pf the above-entitled Criminal case on
November 21, 2007, 8:30 o clock in the morning be please cancelled and reset to
December 10, 2007 at 10:00 oclock in the morning.
Respectfully prayed for.

Malaybalay City, October 30, 2007


JENNY U. SALE, CPA
Counsel for the Defendant
Zone 4, Kalasungay, Malaybalay City
PTR No. 888888 - January 4, 2007
IBP No. 666666 - January 4, 2007
Roll No. 8080808
TIN 928-274-578
THE CLERK OF COURT
Municipal Trial Court in Cities
10th Judicial Region
Malaybalay City
Greetings:
Kindly submit the foregoing Motion for Postponement to the honorable Presiding
Judge immediately upon receipt hereof for the resolution of the same, sans oral
argument.
JENNY U. SALE, CPA
Notary Public
Zone 4, Kalasungay, Malaybalay City
PTR No. 888888 - January 4, 2007
IBP No. 666666 - January 4, 2007
Roll No. 8080808
TIN 928-274-578
Copy furnished:
ATTY. JAIME GARCI
City Prosecutors Office
Malaybalay City

Republic of the Philippines


REGIONAL TRIAL COURT
National Capital Judicial Region
Branch 85, Quezon City

Juan Dela Cruz y Mabini


Petitioner
x-----------------------------x

Sp. Proc. No. 12345


FOR: Adoption

JUDICIAL AFFIDAVIT OF PETITIONER


JUAN DELA CRUZ y MABINI
I, Juan Dela Cruz y Mabini, Filipino, of Legal Age, single, and a resident of No. 1,
Kalayaan Avenue, Quezon City, adopter in this case, states under oath that:
PRELIMINARY STATEMENT
The person examining me is ATTY. KEVIN JOHN DL. AMPUAN, with address at
1234, BonBon St., Quezon City Philippines, the examination is being held in the same
address. I am answering his questions voluntarily to the best of my knowledge and fully
conscious that I do under oath and may face criminal liability for false testimony and
perjury.
PURPOSE
This affidavit and/or testimony of Petitioner Juan Dela Cruz y Mabini is being
offered to prove that he has all the qualifications and none of the disqualifications for the
adoption of Juancho Magnolia. The petitioners testimony is also offered to prove the
grounds invoked which will suffice for his adoption:
1. Q: Please state your name and your other circumstances for the record.
A: I am Juan Dela Cruz y Mabini, of legal age, Filipino and single and a resident
of No. 1, Kalayaan Avenue, Quezon City, Philippines.
2. Q: Are you the same Juan dela Cruz y Mabini, the petitioner in this case?
A: Yes, sir.
3. Q: How are you related to Juancho Magnolia?
A: He is my nephew.
4. Q: What is your reason for wanting to adopt Juancho Magnolia?
A: I am his only living relative and I cared for him ever since his mother is still
alive.
5. Q: Are you in possession of your full civil capacity and legal rights?
A: Yes, Sir.
6. Q: Have you been convicted of any crime involving moral turpitude?
A: No, Sir.

7. Q: Do you have a job?


A: Yes, Sir. I am a Surgeon.
8. Q: Do you have children?
A: None, Sir.
9. Q: Do you attest to the truth of the foregoing answers, and if any be proven to be
false, you may be criminally charged for false statement?
A: Yes, Sir.
Further Affiant Sayeth None.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 13 th day of
December, 2016, at Manila City, Philippines.
Juan Dela Cruz y Mabini
Affiant
SUBSCRIBED AND SWORN to before me this 13 th day of December, 2016, at
the City of Manila, Philippines.
THIAGO SILVA
NOTARY PUBLIC
Until December 31, 2013
PTR No. 906760 - Jan. 3, 2013
IBP No. 918300
Roll No. 13466
SWORN ATTESTATION
The undersigned hereby attests that, as counsel of the witness, he faithfully
recorded the questions he asked and the corresponding answer of the witness and that
he did not coached the witness answers to the questions propounded.
Lito E. Palito
Counsel for the Plaintiff
Roll of Attorneys No. 512345
PTR No. 26-26-0-10, 04/23/2013
IBP No. 910205, 4/11/09, Cebu
Admitted to the Philippine Bar - April 11, 2009
SUBSCRIBED AND SWORN to this _____ day of ___________, 2013, at the
City of Cebu, Philippines.

Doc. No.
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Page No.
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Book No.
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Series of 2013

THIAGO SILVA
NOTARY PUBLIC
Until December 31, 2013
PTR No. 906760 - Jan. 3, 2013
IBP No. 918300
Roll No. 13466

SPECIAL POWER OF ATTORNEY


KNOW ALL MEN BY THESE PRESENTS:

I, JUNELYN R. BUNDA, of legal age, Filipino, with residence address at Block


106 Lot 11 Phase 2 C II Karangalan Village, Pasig City, and after being duly sworn in
accordance with law, do hereby NAME, CONSTITUTE AND APPOINT ATTY. JINGJING S. ROMERO to be my true and lawful attorney-in-fact, to appear for and on behalf
of me and/or represent me at the Preliminary Conference and all other proceedings in
the following case: Junelyn R. Bunda vs. Thomas Jefferson Go docketed as
___________, which is pending before Regional Trial Court Branch ___, Pasig City with
full and special power to do and perform any of the following:
1. To negotiate, conclude enter into and execute a compromise or amicable
settlement of the case under such terms and conditions as the law firm or any
of its lawyers may deem just and reasonable;
2. To agree on the simplification of the issues;
3. To amend the pleadings;
4. To obtain stipulations or admissions of facts and of documents to avoid
unnecessary proof;
5. To limit the number of witnesses;
6. To do and agree on such other matters as may aid in the prompt disposition
of the action; and
7. To perform any act or sign, execute, make and convey any document
necessary to give effect to the foregoing.
HEREBY GIVING AND GRANTING unto said attorney-in-fact full powers and
authority to do and perform every act and thing of whatever requisite and necessary to
be done in and about the premises, and hereby ratifying and confirming all that the 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 ____________ at
____________.
JUNELYN R. BUNDA
Affiant
SUBSCRIBED AND SWORN to before me this ______________, affiant
exhibiting to me her _________________.
Doc. No. ___;
Page No. __;
Book No. __;
Series of 2014.