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Republic of the Philippines

COURT OF APPEALS
2nd Division
City of Manila

STARK INDUSTRIES, Inc.,


Plaintiff-Appellee,

- versus - CA GR CV No. 111222


RTC Civil Case No. 123-345
WAYNE CORPORATION, For: Breach of Contract
Defendant-Appellant.
x-------------------------------------------x

MOTION FOR EXTENSION OF TIME TO FILE BRIEF

Defendant-Appellant, by undersigned counsel, and unto this Honorable Court, most


respectfully states that:

1. Defendant engaged the services of counsel only on February 1, 2017;

2. Defendant received a Notice to File Appellants Brief from this Honorable Court on
December 27, 2016 and thus has until February 10, 2017 within which to file his
appellants brief to the same;

3. However, due to volume and pressure of work, coupled with other equally important
and urgent professional commitments, the undersigned will not be able to meet the
said deadline;

4. Undersigned counsel is constrained to request for an additional period of 10 days


from expiration of said date within which to submit Appellants Brief. Moreover, this
additional time will also allow the undersigned to interview the available witness and
study this case further;

WHEREFORE, Defendant-Appellant prays that he be granted an additional ten (10)


days from February 10, 2012 or until February 20, 2017, within which to submit said Appellants
Brief.

Pasay City, Philippines. February 3, 2017.

Atty. OMAR KAREEM V. MAURICIO


Counsel for Defendant
NOTICE OF HEARING

THE BRANCH CLERK OF COURT


RTC - Branch 123
Quezon City

Greetings!

This is to respectfully request for submission of the foregoing motion for consideration
and approval of this Honorable Court immediately upon receipt hereof.

Atty. OMAR KAREEM V. MAURICIO


Counsel for Defendant

Copy furnished by registered mail:

Atty. HARVEY C. DENT


Counsel for Plaintiff
23 Gotham St.
Pasay City

Please take notice that counsel has requested for the approval of this motion
immediately upon receipt.

Atty. OMAR KAREEM V. MAURICIO


Counsel for Defendant
DEED OF DONATION

BY THESE PRESENTS:

This Deed of Donation, made and executed in the City of Pasay, Philippines, by BRUCE
B. WAYNE of legal age, single, Filipino citizen and with residence and postal address at 123
Wayne Manor, Gotham St., Pasay City hereinafter called the DONOR

- IN FAVOR OF -

JASON ROBIN A. TODD, of legal age, single, Filipino citizen and with residence and
postal address at 20 Gotham St., Pasay City, hereinafter called the DONEE

- WITNESSETH -

That the DONOR is the owner of that certain real property with an underground buildings
and improvements thereat, situated in 124 Gotham St., Pasay City and more particularly
described in Transfer Certificate of Title No. 123456 of the land registry of Pasay City as follows:

TRANSFER CERTIFICATE TITLE NO. 123456

A PARCEL OF LAND (Lot 20 Blk 54 of consolidation subdivision plan (LRC) Pcs-


13265, being a portion of the consolidation of Lots 4751-A and 4751-B situated in
the Wayne Manor Compound Pasay City, Is. of Luzon. Bounded on NE., point 4
to 1 by Wayne Manor; containing an area of 2,500 square meters more or less..."

That for and in consideration of the love and affection which the DONOR has for the
DONEE, the said DONOR, by these presents, transfers and conveys, by way of donation, unto
said DONEE, his heirs and assigns, the above described real property with all the buildings and
improvements thereat, free from all liens and encumbrances;

That the DONOR does hereby state, for the purpose of giving full effect to this donation,
that he has reserved for himself in full ownership sufficient property to support him in a manner
appropriate to his needs;

That the DONEE does hereby accept this donation of the above-described property, and
does hereby express gratitude for the kindness and liberality of the DONOR.

IN WITNESS WHEREOF, the DONOR and the DONEE have signed this deed on 7 July
2013 at Pasay City, Philippines.

BRUCE B. WAYNE JASON A. TODD


Donor Donee
SIGNED IN THE PRESENCE OF

ALFRED C. PENNYWORTH SELINA A. KYLE


Witness Witness

ACKNOWLEDGMENT

Republic of the Philippines)


City of Pasay ) S.S.

BEFORE ME, a Notary Public, for and in the City of Pasay, this 25th day of July 2013
personally appeared:

Name ID Issued at/on


BRUCE B. WAYNE Passport No. 123456 Aug. 14, 2015
JASON A. TODD Passport No. 789012 Sept. 23, 2016

all known to me to be the same persons who executed the foregoing instrument and hereby
acknowledged to me that the same is their free and voluntary act and deed.

This instrument consisting of two ___ pages, including this page on which this
acknowledgment is written refers to a DEED OF DONATION and has been signed by the
parties and their witnesses and sealed with my notarial seal.

WITNESS MY HAND AND NOTARIAL SEAL.

Atty. OMAR KAREEM V. MAURICIO


Notary Public

Doc. No. ____


Page No. ____
Book No. ____
Series of 2017.
REAL ESTATE MORTGAGE

BY THESE PRESENTS:

This Real Estate Mortgage, made by and between:

BRUCE B. WAYNE, of legal age, single, and a resident of 123 Wayne Manor Gothm St.,
Pasay City, Philippines, hereinafter known as the MORTGAGOR;

- and -

TONY A. STARK, of legal age, single, and a resident of 54 Stark Towers, New York St.,
Pasay City, Philippines, hereinafter known as the MORTGAGEE;

WITNESSETH; That:

The MORTGAGOR is indebted unto the MORTGAGEE in the sum of Four Million Pesos
(P 4,000,000.00), receipt of which is acknowledged by the MORTGAGOR upon the signing of
this instrument, payable to the order of the MORGAGEE without need of prior demand or notice
within a period of Four (4) years, at One Million (P 1,000,000.00) annually starting on January
2018 and on every year thereafter until fully paid, with interest thereon at the rate of Six Percent
(6%) per annum.

NOW, THEREFORE, for and consideration of the afore-mentioned indebtedness, and to


assure the performance of said obligation to pay, the MORTGAGOR does hereby convey and
DELIVER by way of MORTGAGE unto the MORTGAGEE, (his/her) heirs, successors and as
signs, the following parcel of land, together with all the improvements found and standing
thereon, more particularly described as follows:

TRANSFER CERTIFICATE TITLE NO. 123456

A PARCEL OF LAND (Lot 20 Blk 54 of consolidation subdivision plan (LRC) Pcs-


13265, being a portion of the consolidation of Lots 4751-A and 4751-B situated in
the Wayne Manor Compound Pasay City, Is. of Luzon. Bounded on NE., point 4
to 1 by Wayne Manor; containing an area of 2,500 square meters more or less..."

That it is the condition of this Mortgage that should the MORTGAGOR perform the
obligation to pay the afore-cited indebtedness of Four Million Pesos together with accrued
interest thereon, within the agreed term, this Real Estate Mortgage shall be discharged and
shall at once become null and void and of no effect whatsoever, otherwise, it shall subsist and
remain in full force and effect and be subject to foreclosure in the manner and form prescribed
by law.

IN WITNESS WHEREOF, we have have hereunto set their hands, this 3rd day of
February in Pasay City, Philippines.

BRUCE B. WAYNE TONY A. STARK


Mortgagor Mortgagee
SIGNED IN THE PRESENCE OF:

ALFRED C. PENNYWORTH PEPPER R. POTS


Witness Witness

ACKNOWLEDGMENT

BEFORE ME, a Notary Public, for and in the City of Pasay, this 3rd day of February 2017
personally appeared:

Name ID Issued at/on


BRUCE B. WAYNE Passport No. 123456 Aug. 14, 2015
TONY A. STARK Passport No. 789012 Sept. 23, 2016

all known to me to be the same persons who executed the foregoing instrument and hereby
acknowledged to me that the same is their free and voluntary act and deed.

This instrument consisting of two ___ pages, including this page on which this
acknowledgment is written refers to a REAL ESTATE MORTGAGE and has been signed by the
parties and their witnesses and sealed with my notarial seal.

WITNESS MY HAND AND NOTARIAL SEAL.

Atty. OMAR KAREEM V. MAURICIO


Notary Public

Doc. No. ____


Page No. ____
Book No. ____
Series of 2017.
Republic of the Philippines
REGIONAL TRIAL COURT
Branch 123
City of Pasay

PEOPLE OF THE PHILIPPINES,


Plaintiff,
CRIM CASE NO. 123-456
- versus - FOR: CHILDE ABUSE IN RELATION TO
R.A. 7610

BRUCE B. WAYNE,

Respondent
x-------------------------------------------x
JUDICIAL AFFIDAVIT
OF MR. DAMIAN A. WAYNE
I, DAMIAN A. WAYNE, 12 years old, single , residing at 123 Wayne Manor, Gotham St.,
Pasay City, after having been sworn to in accordance with the law do hereby depose and state:

That Fiscal OMAR KAREEM V. MAURICIO is the counsel who conducted and
supervised my examination as a witness at his office at the Office of the City Prosecutor Pasay
City, Metro Manila;

PURPOSE: That my testimony is being offered to:

Establish the identity of The Batman and prove that he and my father, BRUCE B.
WAYNE, who is the subject of herein criminal complaint are one and the same;

Prove that he has abused me by subjecting me to torture and rigorous physical training
to the detriment of my physical, emotional and mental well-being;

That I am answering the questions herein fully conscious that I do so under oath and
that I may be criminally liable for false testimony or perjury;

The following are the Questions propounded by Fiscal OMAR KAREEM V. MAURICIO
and my answers in English language:

Q1: Do you swear to tell the truth and nothing but the truth?
A1: Yes Sir.

Q2: Are you the same Damian A. Wayne, the private complainant in this case for Child
Abuse in Relation to R.A. 7610 now pending before the Regional Trial Court, Branch 123
of Pasay City
A2: Yes Sir

Q3: Do you personally know the accused in this case, Mr. Bruce Wayne?
A3: Yes Sir.

Q4: Where were you on December 1 at about 1:00 oclock in the morning?
A4: I was in a dark underground bunker which I later found out was below the Wayne Manor.

Q5: How did you know that it was below the Wayne Manor?
A5: Because on that same night, my father lead me to its exit which directly lead to the
Wayne Manor study room.

Q6: And what were you and your father doing in that underground bunker?
A6: My father strapped my hands and feet to chains and was coaxing me to get free of the
chains

Q7: Why was did he tie you up in chains?


A7: He said that he wanted to train me in martial arts and other skills that I will need when I
join him in crime fighting

Q8: Is this the first time that he has subjected you to this kind of training?
A8: No, he has been training me in different kinds of martial arts since I was 7 years old

Q9: Have you sustained any injuries because of these trainings?


A9: Yes. I have broken all my ribs at different occasions and even broke my legs and arms
for about 5 times, at different occasions also.

Q10: Did you father show any kind of remorse or concern while you sustained these injuries?
A10: I cant tell. He was wearing the Batman costume so I couldnt see much of his facial
expressions.

Q11: You mean to tell me youre not sure if the man who was training you and tying you in
chains is your father?
A11: No, I am sure it was him.

Q12: How can you tell?


Q12: Because when he finally unchained me and led me up to the study of the Wayne Manor,
he removed his masked and confessed to me that he was Batman.

Q13: What else would he normally do to you during these trainings?


Q13: He would punch me and kick me and throw me to the ground.

Q14: Did this affect your mental health in any way?


Q14: I used to have nightmares that he was trying to kill me. One time I even hit Alfred, our
butler when he was trying to wake me from these nightmares.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 3rd day of February
2017 in Pasay City, Philippines.

DAMIAN A. WAYNE
Private Complainant

SUBSCRIBED AND SWORN to before me this 3rd day of February 2017 in Pasay City,
Philippines.

Atty. OMAR KAREEM V. MAURICIO


City Prosecutor

ATTESTATION OF LEGAL COUNSEL


I, OMAR KAREEM V. MAURICIO, City Prosecutor of the City of Pasay, after having
been sworn to in accordance with the law do hereby depose and say:

1. That I have faithfully recorded or caused to be recorded the questions I asked and the
corresponding answers that Respondent, DAMIAN A. WAYNE, gave;
2. That I have not, nor any other person present or assisting coached the witness regarding
the witness answers; and
3. That I fully understand that any false attestation shall subject me to disciplinary action,
including disbarment.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 3rd day of February
in Pasay City, Philippines.

Atty. OMAR KAREEM V. MAURICIO


Counsel for the State

BEFORE ME, this 3rd day of FEBRUARY 2017, Pasay City.

Atty. OMAR KAREEM V. MAURICIO


Counsel for the State