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1. PLAINTIFF EMILIANO ROBLES 90, FILIPINO AND JAIME ROBLES OF LEGAL AGE,
YOUNGEST SON AND THE ATTORNEY IN FACT AND ARE RESIDING AT # 459 BUGARIN
HALAYHAYIN, PILILLA, RIZAL ARE COMPELLED TO COMPLAIN OF THEFT AND
MALICIOUS MISCHIEF WITH SERIOUS INTIMIDATION TO RENATO ROBLES 64,
MARRIED FILIPINO AND HIS CONSPIRATORS LOURDES ROBLES 66, CONRADO
ROBLES 65, RODANTE ROBLES 60, AND MARITES ROBLES 56, ALL MARRIED, FILIPINO
AND ALL RESIDING AT BUGARIN PILILLA, RIZAL.
EXPLANATIONS
3. IN AUGUST 1997 RENATO OPENNED A JOINT ACCOUNT WITH THE PLAINTIFF THREE
MONTHS AFTER ENTRUSTMENT IN THE AMOUNT OF ONLY 1,000,000 PHP AS RENATO
EXCLUDED THE 500,000 SINCE IT IS NO APPEARING OF THE RECORDS OF DEPOSIT AT
FILIPINAS BANK.
4(A). RODANTE ROBLES PURCHASED 1 UNIT PUJ VEHICLE IN MAY 1997 AND
CONRADO ROBLES OUT OF ENVIOUS INTENT HAS ALSO PURCHASED 1 UNIT
PUJ VEHICLE IN THE AMOUNT OF 320,000 PHP BEYOND DECEIT AND
DEFRAUD TO THE PLAINTIFF FROM A MALICIOUS TRICK THAT THE
VEHICLE IS INTENDED TO BE GIVEN TO JAIME ROBLES. BEYOND THIS
FRAUD ALIBI THE PLAINTIFF APPROVED THE SAID PURCHASE, HOWEVER
THE PLAINTIFF AND JAIME UPON KNOWING THE FRAUD OF CONRADO HAD
ORDERED THE CANCELLATION OF PURCHASE BUT SINCE THE VEHICLE IS
ALMOST COMPLETED THE PAYMENT WAS NOT BEEN RECOVERED, THE
INCIDENT BROUGHT THE PLAINTIFF INTO TEARS BUT CONRADO IS
DETERMINED TO CONTINUE HIS FRAUD AS AFTER THE COMPLETION OF
THE VEHICLE, CONRADO ATTEMPTED T REGISTER THE VEHICLE INTO HIS
NAME BUT WAS BEEN DENIED AND IN THE COURSE THAT THE TOTAL
AMOUNT PAID BY AVELINA ROBLES TO RENATO ROBLES IS REVEALED, WE
REQUEST THAT THE AMOUNT PAID SHOULD BE DECLARED ON THE
ACTUAL HEARING.
5. OTHER EXPENSES;
THE REMAINING BALANCE OF 56,000 PHP FROM THE 130,000 PHP WAS BEEN USED IN
ACQUIRING DOCUMENTARY EVIDENCE TO THE FILING OF LEGAL SUITS AGAINST
RENATO ROBLES AND HIS CONSPIRATORS UPON THE DISCOVERY OF UNLAWFUL
TRANSMUTATION OF RESIDENTIAL LAND TITLE NO. 356634 AND ON THE MALICIOUS
WITHDRAWALS OF RENATO ON THE 645,000 PHP VETERANS BACK PAY BENEFIT OF THE
PLAINTIFF IN DECEMBER 2010.
EXPLANATIONS
IN MAY 2007 RENATO BORROWED 300,000 PHP TO THE PLAINTIFF FROM THE
REMAINING BALANCE OF 700,000 AS RENATO DECLARES TO THE PLAINTIFF, BUT
200,000 PHP OF WHICH WAS DONATED TO RENATO, THEREFORE, THERE WAS AN
EXISTING BALANCE OF 500,000 PHP BUT SINCE THERE WAS A MISSING 500,000 PHP AS
RENATO EXCLUDED DURING DEPOSIT IN AUGUST 1998, RENATO IS ACCOUNTABLE ON
THE REMAINING BALANCE OF 1,000,000 AND SINCE CONRADO DECLARES THAT THE
REMAINING BALANCE OF 1,500,000 PHP HAD HE SURRENDERED TO RENATO AND IN
ADDITION OF THE 645,000 PHP VETERANS BACK PAY BENEFIT A TOTAL OF 1,645,000 IS
THE TOTAL AMOUNT TO BE LIQUIDATED BY RENATO ADDED TO IS THE TOTAL EXACT
AMOUNT PAID BY AVELINA TO RENATO FOR 1 UNIT PUJ VEHICLE.
10. IN DECEMBER 1998 THE THE PLAINTIFF BEFORE LEAVING TO DELANO, CALIFORNIA
IN PURSUIT TO ACQUIRING U.S. NATURALIZATION CERTIFICATE FROM A PETITION OF
A RELATIVE HAD TEMPORARILY APPOINTED RENATO TO ADMINISTRATE ON ALL THE
PROPERTIES OF THE PLAINTIFF INCLUDING PAYMENT OF PROPERTY TAX AND TWO
PUJ VEHICLES. RENATO HAD THE OPPORTUNITY TO MALICIOUSLY FABRICATE
FALSIFIED DEED OF SALE OF TWO PUJ VEHICLE TO AVELINA AND CONRADO ROBLES
AND WHEREIN THE AMOUNT OF PAYMENT AS INCLUDED ON THE COMPLAIN TO BE
RECOVERED.
EXPLANATIONS
11. ON OCTOBER 6, 2010 THE PLAINTIFF EMILIANO ROBLES AND THE ATTORNEY IN
FACT WAS NOT BEEN ABLE TO OPEN A DOLLAR ACCOUNT AT BANK OF THE
PHILIPPINES ISLAND TO DEPOSIT THE $ 15,000 BANK CHECK IN THE ABSENCE OF $
500 INITIAL AMOUNT FOR DEPOSIT.
13. BEYOND PRESUMPTIONS OF THE PLAINTIFF THAT RENATO AND FOUR OTHER
DEFENDANTS ARE SINCERE TO THEIR INTENT ON THE HEALTH AND WELFARE OF
THE PLAINTIFF, AND SINCE THE $ 15, 000 WAS UNDER THE CUSTODY OF THE
ATTORNEY IN FACT, JAIME AN AGREEMENT OF PROCEDURES OF ENTRUSTMENT
AND OPENING OF DOLLAR ACCOUNT BETWEEN THE PLAINTIFF, THE ATTORNEY IN
FACT AND RENATO IN THE PRESENCE OF LOURDES, CONRADO, RODANTE AND
MARITES ROBLES WAS BEEN DONE.
14. THE AGREEMENTS ARE:
15. ON DECEMBER 23, 2010, DURING THE MATURITY DATE OF DEPOSIT RENATO DID
APPEAR TO ASSIST THE PLAINTIFF FOR WITHDRAWAL WHEREIN THE PLAINTIFF ASK
THE HELP OF ATTORNEY IN FACT JAIME AND HAD PRESENTED A COPY OF
CERTIFICATE OF DEPOSIT, IT WAS FOUND OUT THAT RENATO HAD ENTERED INTO A
AGREEMENT IN OCTOBER 2010 WITH A MALICIOUS INTENT TO DECEIT AND
DEFRAUD THE PLAINTIFF AND ATTORNEY IN FACT BECAUSE RENATO SUBDIVIDED
THE $ 16,000 EQUIVALENT TO 645,000 PHP $ 9,800 EQUIVALENT TO 422,000 PHP AND
HAD EXCLUDED $ 5,200 IN EQUIVALENT TO 223,000 PHP, AS APPEARING ON THE
CERTIFICATE OF DEPOSIT OF THE $ 9,800 RENATO USED A JOINT ACCOUNT AND OR
WHICH INDICATES THAT RENATO HAD VIOLATED ALL THE AGREED PROCEDURES
ON OPENING OF BANK ACCOUNT AND THE CAUSE OF ENTRUSTMENT, RENATO AND
HIS CONSPIRATORS MALICIOUSLY DISREGARD.
16. ON DECEMBER 24, 2010 UPON VERIFICATION OF THE PLAINTIFF AND THE ATTORNEY
IN FACT AT METROBANK BRANCH MANAGER MS. LINETH GALANG IT WAS
CONFIRMED THAT THE $ 9,800 WAS BEEN WITHDRAWN BY RENATO ON DECEMBER
23, 2010 AND WHICH THEREFORE THE $ 5,200 WAS BEEN DEPOSITED INTO THE
ACCOUNT OF RENATO EARLIER IN OCTOBER 2010.
EXPLANATIONS
JAIME M. ROBLES
ATTORNEY IN FACT
EMILIANO P. ROBLES
PLAINTIFF