REPUBLIC OF THE PHILIPPINES

Office of the Bar Confidant

SUPREME COURT
Manila

MANUEL N. CAMACHO,
Complainant,

-versus- Admin. Matter No. ______

ATTY. ANTERO M. SISON, ATTY.

ENRIQUE DIMAANO, ATTY.
IBARO B. RELAMIDA,
Respondents.
x----------------------x

COMPLAINT

COMPLAINANT respectfully files this administrative complaint

against respondents and states that:

PREFATORY STATEMENT

Complainant comes before the Honorable Supreme Court to file this

complaint seeking perpetual disbarment against three private lawyers who
connived with judges and public prosecutors in maliciously filing various
harassment cases against herein complainant and in delaying the execution
of a valid, final, and executory order previously issued in complainant’s
favor.

PARTIES

Complainant is a Filipino of legal age, a practicing lawyer with offices

at Suite 1605 Corporate 88 Center, Valero corner Sedeno Streets, Salcedo
1
Village, Makati City, where he may be served with the processes of the
Honorable Supreme Court.

Respondents Attys. Antero M. Sison, Jr., Enrique Dimaano, and

Ibaro B. Relamida are private lawyers and/or officers/members of the board
of Marsman Drysdale Organic Farm, Inc./Marsman Drysdale Agribusiness
Holdings, Inc., with offices at the 45th Floor, 8767 Paseo de Roxas Ave.,
Makati City, Philippines, where they may be served with summons and
other processes of the Honorable Court.

GROUNDS FOR DISBARMENT AND DISMISSAL

Complainant files this administrative complaint for perpetual

disbarment against the respondents for violation of Section 3(e), Republic
Act No. 3019 for connived with judges and public prosecutors in having
caused undue injury to the complainant as the accused in Criminal Case No.
13-1688, now pending before RTC Branch 146, Makati City, and for again
conniving with judges in causing the delay of the execution of valid orders in
Civil Case No. 05-655 which were issued in complainant’s favor.

ATTACHMENTS TO THIS COMPLAINT

The following certified copies and/or duplicate original copies of

pertinent documents are attached in support of this complaint:

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 Description Attached As

ORDER dated 20 September 2013 issued by Annex “A”

JUDGE ENCARNACION JAJA G. MOYA,
Presiding Judge, RTC Branch 146, Makati
City, in Criminal Case No. 13-1688 (4 pages)

INFORMATION filed on 18 July 2013 with the Annex “B”

Makati RTC in Criminal Case No. 13-1688,
prepared by SENIOR ASST. CITY
PROSECUTOR HANNIBAL V. SANTILLAN (2
pages)

MOTION TO QUASH INFORMATION in Crim. Annex “C”

Case No. 13-1688, filed on 12 August 2013 (6
pages)

COMMENT/OPPOSITION TO MOTION TO Annex “D”

QUASH INFORMATION in Crim. Case No. 13-
1688, dated 16 August 2013 (7 pages)

REPLY TO COMMENT / OPPOSITION TO MOTION Annex “E”

TO QUASH INFORMATION in Crim. Case No.
13-1688, filed on 30 August 2013 (4 pages)

ORDER dated 6 July 2012 issued by Judge Annex “F”

Benjamin Pozon of Makati RTC Branch 139 in
Civil Case NO. 05-655 (6 pages)

AGREEMENT dated 30 June 2005, regarding Annex “G”

Atty. Camacho’s attorney’s fees from Marsman
Drysdale in Civil Case No. 05-655

LETTER FROM ATTY. ANTERO SISON dated 24 Annex “H”

August 2011, in connection with Civil Case No.

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 05-655

ORDER dated 12 April 2012, in Civil Case No. 05- Annex “I”
655

CHECKS payable to Atty. Enrique Dimaano, Annex “J” and

submitted as evidence in Civil Case No. 05-655 series

PLUNDER COMPLAINT against Atty. Antero Annex “K”

Sison, Jr., et al. filed before the Office of the
Ombudsman on June 21, 2012

WRITE-UP by Vic Agustin in the Philippine Daily Annex “L”

Inquirer regarding the plunder subject of the
complaint above-mentioned

ORDER dated 5 June 2013 in Civil Case No. 05- Annex “M”
655

BACKGROUND FACTS

1. In June 2005, Marsman Drysdale Agribusiness Holdings, Inc. and

Marsman Drysdale Organic Farms, Inc. filed a complaint for recovery
of sum of money (P14.86 million) against Union Insurance Society of
Canton, Ltd. (now Paramount Life & General Insurance Corp.) on the
ground of breach of contract. Herein complainant was then
Marsman’s legal counsel in that case.

2. After trial, the court (RTC Branch 139, Makati City) rendered a
decision in favor of Marsman and against Union Insurance. In
compliance of said Decision, and upon withdrawal of the appeal filed
by Union, through herein complainant’s efforts Marsman and Union
Insurance agreed to settle the claim in order to avoid further
litigation. Marsman agreed to accept P15 million constituting full

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 satisfaction of the trial court’s judgment, and soon thereafter
received that amount from Union Insurance.

3. It is noteworthy that while negotiations were going on for the

settlement of the P15 million from Union Insurance, herein
respondent Atty. Sison, an executive officer of Marsman, vehemently
opposed settlement and wanted to pursue the case in court because
he wanted to claim a higher amount from Union Insurance.
Complainant, as counsel of record for Marsman in the case, advised
against going to trial because the case in fact had nothing to stand
on, as the complaint for insurance claim had been filed out of time.
But Atty. Sison told complainant, “I can pay everybody…even all the
judges.” He uttered these words in the presence of herein
complainant and respondent Atty. Dimaano.

4. Nevertheless, Marsman accepted the settlement. Between Marsman

and herein complainant as their legal counsel, they had previously
agreed to the payment of attorney’s fees equivalent to twenty
percent (20%) of the judgment award. A written agreement to this
effect was executed on June 30, 2005, a copy of which is attached as
Annex “G.”

5. Subsequently however, respondent Atty. Sison refused to honor the

June 30, 2005 agreement regarding attorney’s fees, and offered
complainant only P200,000, as shown in Atty. Sison’s letter dated
August 24, 2011, a copy of which is attached as Annex “H.”

6. Complainant did not accept the offer and instead filed a motion in
the trial court to determine the correct attorney’s fees.

7. The court, in an Order dated April 12, 2012 (copy attached as Annex
“I), ruled in complainant’s favor. Said Order stated that complainant
was indeed entitled to 20% of the judgment award of P15 million,
and thereupon ordered the payment of said amount, minus P300,000
that complainant had already received as acceptance fee. But the
court, in said Order, also improperly deducted other sums allegedly
received by complainant from Marsman, leaving a balance of only
P1,111,740. Thus, complainant filed a motion for reconsideration,

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 alleging that he was entitled to the full amount of attorney’s fees of
P3 million, deducting only the P300,000 acceptance fee, and denying
receipt of all other sums alleged by Marsman.

8. Marsman likewise filed a motion for reconsideration of the April 12,

2012 Order, falsely alleging that it had already turned over to herein
complainant P1.288 million in payments.

9. Upon review of both motions, the court, on July 6, 2012, issued an

Order (Annex “F”) in complainant’s favor, modifying its April 12, 2012
Order and reinstating P1,888,260 to the judgment award, stating
that it was part of the complainant’s attorney’s fees due him.

10.The court then ordered Marsman to pay herein complainant his P3

million attorney’s fee, deducting only the P300,000 acceptance fee,
for a balance of P2.7 million. In the same July 6, 2012 Order (Annex
“F”), the court stated that Marsman has not shown proof that
complainant received the other amounts alleged by them to have
already been paid to complainant.

11.The July 6, 2013 Order further stated:

“Plaintiff’s claim of irregularity on the part of Atty. Camacho is a bare

and unsubstantiated allegation, which will not justify the denial of
the claim of attorney’s fee of Atty. Camacho. Plaintiff submitted no
proof to substantiate the claim of irregularity on the part of
Atty. Camacho, as such, the Court is not inclined to give credence on
such allegation.”

12.Marsman received the July 6, 2012 Order on July 18, 2012 and did
not file any other motion or manifestation in reference thereto. Thus,
said Order became final and executory.

13.Despite the court’s authoritative ruling on the matter which has

become final, respondent Atty. Sison continued to insist that
Marsman had already paid complainant P1.288 million, and accused

6
 him of using the money to bribe the trial judge in that case (Judge
Benjamin Pozon, RTC Branch 139, Makati), and for paying spurious
docket fees. Thus, on July 11, 2012, complainant filed a libel case
against respondent Atty. Sison and other officers and members of the
board of Marsman.

14.In a ploy to have complainant withdraw the libel case, Marsman,

through its in-house legal counsel, herein respondent Atty. Dimaano,
offered complainant a compromise wherein they would pay
complainant P1.5 million. They paired the monetary offer with the
assurance that complainant would continue to act as counsel for
respondent corporations. This, in exchange for complainant’s
withdrawal of the libel complaint against them. Complainant agreed
to withdraw the libel complaint, except as to respondent Atty. Sison.
Complainant then signed a quitclaim to that effect, but still retaining
Atty. Sison as respondent in the libel case.

15.Thus, Marsman and complainant filed an Urgent Joint Motion with

the trial court for the issuance of an order approving their
compromise agreement. Said motion was thereafter granted by the
court, and complainant duly withdrew the libel case that he had filed
against Marsman’s executives and board members, except as to
respondent Atty. Sison.

16.Shortly thereafter, on September 10, 2012, Atty. Sison, with the full
approval and authority of the other officers and board members of
Marsman, filed an estafa case against complainant, insisting that they
had already previously paid over to the latter the total sum of P1.288
million, which was allegedly used as bribe money for Judge Pozon in
Civil Case No. 05-655 and for spurious docket fees. The Information in
the estafa case Criminal Case No. 13-1688), which was prepared and
filed by herein respondent public prosecutor Hannibal Santillan, is
attached as Annex “B.”

17.The allegations of estafa however are utterly baseless, as complainant

had already shown evidence proving that the P1.228 million
disbursed by Marsman was not received by the complainant but by
Marsman’s own in-house legal counsel, herein respondent Atty.

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 Dimaano. This evidence was accepted by the court in Civil Case No.
05-655 and was in fact the basis for its July 6, 2013 Order.

18.In the documentary evidence submitted by respondent Atty. Sison

himself before the prosecutor’s office during the filing of the estafa
case against herein complainant, the subject checks were clearly
payable to respondent Atty. Enrique Dimaano (copies of the checks
are hereto attached as Annexes “J” and series). Yet Atty. Dimaano, in
utter bad faith, executed an affidavit in the estafa case pinning the
blame on herein complainant.

19.To understand Atty. Sison’s vindictive actuations toward complainant,

it is necessary to explain that sometime in late 2012, complainant
filed a plunder complaint before the Office of the Ombudsman
against herein respondent Atty. Antero M. Sison, Jr. along with some
government officials. That case involved the improper payment of
U.S. $4.8 million by the Philippine government to a foreign claimant
(Fidelity Partners) through the machinations of respondent Atty.
Sison who had connections with high officials of the government of
then president Gloria Macapagal-Arroyo and her husband Atty. Mike
Arroyo. Respondent Atty. Sison pocketed more than $3 million of that
amount and paid only $1.5 million to Fidelity Partners. Herein
complainant was then the principal counsel in the case filed by
Fidelity Partners against the Philippine government (then pending
before the Supreme Court) but herein respondent Atty. Sison
manipulated matters to get complainant out of the way. A copy of the
plunder complaint against Atty. Sison, et al. with its attachments is
hereto attached as Annex “K.”

20.The case involving the dirty work that Atty. Sison did for Fidelity
Partners in bilking millions of dollars from the Philippine Government
is well-known and has been widely publicized. An informative write-
up written by columnist Vic Agustin for the Philippine Daily Inquirer
tells of these machinations that led to the loss of U.S. $4.8 million in
public funds. A copy of the write-up is attached as Annex “L.”

21.With the malicious filing of the estafa case, complainant moved for
the recall of the Order dated September 14, 2012 in Civil Case No. 05-
655, which approved his compromise agreement with Marsman

8
 regarding his attorney’s fees. Instead, complainant asked for the
immediate issuance of a writ of execution of the Order dated July 6,
2012 which ordered Marsman to pay complainant P2.7 million in
attorney’s fees.

22.In asking for the nullification of the compromise agreement,

complainant cited Article 2041 of the Civil Code and argued that the
filing of the estafa case against him has voided the compromise
agreement because the filing of the estafa case was an act which
constituted an open repudiation of the compromise agreement by
the reneging party.

23.On June 5, 2013, the court in Civil Case No. 05-655 issued an Order
(copy attached as Annex “M”) granting complainant’s motion to
nullify the compromise agreement, stating the following:

“…the court is inclined to rule that the plaintiff (herein

private respondents) reneged on its obligation under the
compromise agreement that was approved by the
court…

xxx

As correctly pointed out by Atty. Camacho, the plaintiff

has openly repudiated the compromise agreement when
Atty. Antero Sison, Jr. filed a complaint for estafa against
Atty. Camacho in order to collect the said amount of
P1,288,260…

xxx

Therefore, as correctly invoked by Att. Camacho in his

memorandum, the quitclaim signed by Atty. Camacho
became inoperative and without any legal effect,
pursuant to Article 2041 of the New Civil Code and the
ruling of the Supreme Court in the case of Miguel vs.
Montanez citing Leonor vs. Sycip…

xxx

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 Accordingly, the Order dated 14 September 2012
treating the plaintiff’s urgent motion for approval of the
compromise agreement as a motion to dismiss is hereby
recalled and reconsidered, and let a writ of execution be
instead issued directing the plaintiff to pay Atty.
Camacho the sum of P1.2 million representing the
balance of his attorney’s fees.”

(Emphases supplied)

24.Thus, on 12 August 2013, complainant filed a motion to quash the

Information in Crim. Case No. 13-1688, arguing that the controversy
over the amount subject of the estafa case had already been
threshed out in Civil Case No. 05-655, which findings have become
final and executory. Complainant argued that res judicata has set in,
which precludes the re-litigation of a particular fact or issues in
another action between the same parties on a different claim or
cause of action.1 A copy of the Motion to Quash is attached as Annex
“C” of this complaint.

25.Public prosecutor Leilia Llanes in Crim. Case No. 13-1688 filed a

comment/opposition to the motion to quash, arguing that not all of
the requisites of red judicata are present and that the estafa case has
no relation to Civil Case No. 05-655. A copy of the
Comment/Opposition is attached as Annex “D” of this complaint.

26.Complainant then filed a reply to the opposition, and argued that

Civil Case No. 05-655 is pivotal to the estafa case because the two
Orders in Civil Case No. 05-655 dated July 6, 2012 and June 5, 2013
settled with finality the matter of the amount subject of the estafa
case, in that it is the very same amount that has been adjudicated to
be part of herein complainant’s attorney’s fees and therefore due and
demandable by him.

27.Complainant in his reply further stated that: “If in the civil case,
which requires only a preponderance of evidence, the accused was
favored by not just one but two Orders adjudging him to be
1
Lopez vs, Reyes, G.R. No. L-29498, 31 march 1977, 76 SCRA 179.

10
 blameless and in fact entitled to the amount involved, what
foundation then is the prosecution building this criminal case on,
which requires the heavier burden of proof beyond reasonable
doubt?”

28.Nonetheless, despite the obvious lack of basis of the criminal

complaint and the Information for estafa, Judge Moya, in the Order
dated 20 September 2013 (Annex “A” of this complaint), denied the
motion to quash information reasoning out that res judicata is not a
ground to quash Information and that the termination of a civil case
will not bar a criminal case.

DISCUSSION

As complainant has repeatedly stressed in his pleadings and various

motions filed before the courts concerned, res judicata is a doctrine that
encompasses all cases where there is identity of the parties and the facts.

Res judicata is defined as "a matter adjudged; a thing judicially acted

upon or decided; a thing or matter settled by judgment. It also refers to the
rule that a final judgment or decree on the merits by a court of competent
jurisdiction is conclusive of the rights of the parties or their privies in all
later suits on points and matters determined in the former suit."2
(Emphasis supplied)

According to case law, this doctrine is a rule which pervades every

well-regulated system of jurisprudence and is founded upon the following
precepts of common law, namely: (1) public policy and necessity, which
makes it to the interest of the State that there should be an end to
litigation, and (2) the hardship on the individual that he should be vexed
twice for the same cause. A contrary doctrine would subject the public
peace and quiet to the will and neglect of individuals and prefer the
gratification of the litigious disposition on the part of suitors to the
preservation of the public tranquility and happiness.3

2
Gutierrez v. CA, G.R. No. 82475, January 28, 1991, 193 SCRA 437.
3
Cruz v. CA, G.R. No. 164797, February 13, 2006, 482 SCRA 379, quoting Heirs of the Late Faustina
Adalid v. Court of Appeals, G.R. No. 122202, May 26, 2005, 459 SCRA 27.

11
 In this jurisdiction, the concept of res judicata is embodied in Section
47 (b) and (c) of Rule 39 of the Rules of Court, thus:

SEC. 47. Effect of judgments or final orders. — The effect of a

judgment or final order rendered by a court of the Philippines,
having jurisdiction to pronounce the judgment or final order,
may be as follows:

(a) In case of a judgment or final order against a specific thing

or in respect to the probate of a will, or the administration of
the estate of a deceased person, or in respect to the personal,
political, or legal condition or status of a particular person or
his relationship to another, the judgment or final order is
conclusive upon the title to the thing, the will or
administration, or the condition, status or relationship of the
person; however, the probate of a will or granting of letters of
administration shall only be prima facie evidence of the death
of the testator or intestate;

(b) In other cases, the judgment or final order is, with respect
to the matter directly adjudged or as to any other matter that
could have been raised in relation thereto, conclusive between
the parties and their successors in interest by title subsequent
to the commencement of the action or special proceeding,
litigating for the same thing and under the same title and in
the same capacity; and,

(c) In any other litigation between the same parties or their

successors in interest, that only is deemed to have been
adjudged in a former judgment or final order which appears
upon its face to have been so adjudged, or which was
actually and necessarily included therein or necessary
thereto.
(Emphasis supplied)

The above provision outlines the dual aspect of res judicata.4 Section
47 (b) pertains to it in its concept as "bar by prior judgment" or "estoppel
by verdict," which is the effect of a judgment as a bar to the prosecution of
a second action upon the same claim, demand or cause of action.
4
NHA v. Baello, G.R. No. 143230, August 30, 2004, 437 SCRA 86.

12
 On the other hand, Section 47 (c) pertains to res judicata in its
concept as "conclusiveness of judgment" or otherwise known as the rule of
auter action pendant which ordains that issues actually and directly
resolved in a former suit cannot again be raised in any future case between
the same parties involving a different cause of action.5

The background of this case clearly and effectively precludes a charge

of estafa.

The Information reads in its pertinent portion:

“On March 4, 2011 and subsequent thereto, in the city of

Makati, Philippines, accused, with intent to gain and
with abuse of confidence, did and there wilfully,
unlawfully and feloniously defraud complainant
Marsman Drysdale Agribusiness Holdings, Inc.,
Marsman Drysdale Organic Farm, Inc., represented by
Atty. Enrique Dimaano in the following manner, to wit:
the said accused who was then counsel of complainant
fees (sic) for Civil Case No. 05-655, pending before RTC
Branch 139,Makati in the amount of Php 1,288,260,
entitled ‘Marsman Drysdale Agribusiness Holdings, Inc.
Marsman Drysdale Organic Farm, Inc., Plaintiff vs. Union
Insurance Society of Canton, Ltd. (now Paramount Life &
General Insurance Corporation), Defendant,’ but accused
once in possession of the said amount misappropriated,
misapplied, and converted the same, to the damage and
prejudice of the complainant in the amount of
P1,288,260.”

Note however that, in the Order dated July 6, 2012 in Civil Case No.
05-655 (Annex “F”), the trial Court there ruled that herein complainant
(therein counsel for the respondents) is entitled to receive from Marsman
the amount of P3 million as his rightful attorney’s fees, deducting only the
P300,000 that the accused had already received as acceptance fee. In said
Order, the Court said herein respondents have not shown proof that herein
5
Spouses Rasdas v. Estenor, G.R. No. 157605, December 13, 2005, 477 SCRA 538.

13
complainant had received the other amounts alleged by them to have
already been paid to the latter, and that includes the P1,288,260 subject of
the estafa case. In said Order, the Court said:

“As correctly stated by Atty. Camacho, the deduction of

P1,888,260.00, as allegedly for amounts already
received by him, have not been proven by plaintiff to
have been actually received by the said counsel, except
for the P300,000.00 by way of acceptance fee. Aside
from the bare allegation of plaintiff that Atty. Camacho
had received the amounts deducted by the Court, it
presented no proof to substantiate the same. The burden
to prove that the said amounts were received by Atty.
Camacho lies on the plaintiff, and its failure to prove its
allegation leaves this Court without recourse but to
reinstate the amount deducted, except the acceptance
fee of P300,000.00 which is reflected on the retainer
agreement.”

As complainant has repeatedly stressed before the courts, the above

ruling has never been reversed, modified, nullified, or set aside, and it has
never been challenged on appeal. Thus, it has become the law of the case
as between the accused and the private complainants in Crim. Case No. 13-
1688 with respect to the controversy at issue.

Judge Moya must surely know these legal principles because she is a
judge of the Regional Trial Court. But even though herein complainant
keeps belaboring the point that, since the amount of P1,288,260 subject of
the estafa case has already been ruled by a court of competent jurisdiction
to be due him as his attorney’s fees, and that there can be no estafa
because he is entitled to that money on his own right, Judge Moya, with
manifest partiality and evident bad faith, denied the motion to quash on
shaky reasoning. For this, complainant charged Judge Moya in another case
with:

1. Gross ignorance of the law;

14
 2. Violation of Article 206, Revised Penal Code for knowingly
6

rendering unjust and interlocutory orders;

3. Violation of Section 3(e) of Republic Act No. 3019 (The Anti-Graft

and Corrupt Practices Act) for having caused undue injury to
7

herein complainant and giving unwarranted benefits to the

adverse parties in Criminal Case No. 13-1688 and Civil Case No.
05-655; and

4. Rule 1.02 , Canon I, Code of Judicial Conduct for failure to

8

administer justice impartially.

Herein respondents Atty. Sison, Atty. Dimaano, and Atty. Relamida,

having connived with one another and with Judge Moya and the public
prosecutors in pressing the unfounded estafa case against complainant,
must therefore also be investigated for violation of Section 3 (e) of RA 3019.

PRAYER

6
Article 206. Unjust Interlocutory Order. - Any judge who shall knowingly
render an unjust interlocutory order or decree shall suffer the penalty of
arresto mayor in its minimum period and suspension; but if he shall have
acted by reason of inexcusable negligence or ignorance and the
interlocutory order or decree be manifestly unjust, the penalty shall be
suspension. (Article 206, Revised Penal Code, Article 206)
7
Section 3. Corrupt practices of public officers. — In addition to acts or
omissions of public officers already penalized by existing law, the following
shall constitute corrupt practices of any public officer and are hereby
declared to be unlawful:
xxx
(e) Causing any undue injury to any party, including the
Government, or giving any private party any unwarranted benefits,
advantage or preference in the discharge of his official
administrative or judicial functions through manifest partiality,
evident bad faith or gross inexcusable negligence. This provision
shall apply to officers and employees of offices or government
corporations charged with the grant of licenses or permits or other
concessions. (Anti-Graft and Corrupt Practices Act, Republic Act No.
3019, Section 3(e))
8
“A judge should administer justice impartially and without delay.”

15
 WHEREFORE, premise considered, complainant most
respectfully prays of the Honorable Supreme Court that after due
proceedings, judgment be rendered finding respondents guilty of the
charges and ordered PERPETUALLY DISBARRED.

COMPLAINANT further prays for such other just reliefs.

Makati City for Manila, 9 December 2013.

MANUEL N. CAMACHO
Complainant
Suite 1605 Corporate 88 Centre
Valero corner Sedeno Streets
Salcedo Village, Makati City

VERIFICATION and CERTIFICATION OF

NON-FORUM SHOPPING

REPUBLIC OF THE PHILIPPINES )

MAKATI CITY ) S.S.

I, MANUEL N. CAMACHO, a Filipino of legal age with offices at Suite

1605 Corporate 88 Centre, Valero corner Sedeno Streets, Salcedo Village,
Makati City, Philippines, under oath state that:

1. I am the complainant the above-entitled case;

2. I have caused the filing of the foregoing COMPLAINT, and I verify that
its contents are true and correct of my own personal knowledge and
based on authentic records;

16
 3. I hereby certify that I have not commenced any similar action or filed
any claim involving the same respondents in relation to the same in
any court, tribunal or quasi-judicial agency, and to the best of my
knowledge, no such other action or claim is pending; and

4. I hereby undertake that should I hereafter learn of any other such

action or proceeding, whether pending or terminated, with any
court, tribunal or agency, I shall notify this Honorable Court of its
status within five (5) days from notice.

MANUEL N. CAMACHO
Affiant

SUBSCRIBED AND SWORN to before me in Makati City this

________________, affiant exhibiting to me his IBP ID Card bearing
Attorney’s Roll No. 14108, which ID is competent evidence of his identity,
and on which his picture and signature both appear.

Page No. _______

Doc. No. _______
Book No. _______
Series of 2013.

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