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REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION REGIONAL TRIAL COURT Manila, Branch 1 COMPLAINT FOR EXPROPRIATION

PLAINTIFF, thru counsel, unto this Honorable Court respectfully avers that: 1. Plaintiff is a __________; 2. Several defendants are all of age and are all residents of ____________________________; 3. Plaintiff, by virtue of ____________________ has the power to exercise of the right of eminent domain and to take private property for public use; 4. The following described property, with all the improvements thereon, are private property, severally owned by defendants, to with: 5. (Here describe the property to be condemned, showing, as far as practicable, the interests of such defendant separately, if the title is obscure of doubtful so that the real owners cannot be stated with certainty, averment of this effect must be made.); 6. That the said property are sought to be condemned in order to convert them into _____________, which is avowedly a public purpose; 7. Plaintiff tenders and offers to deposit the amount of ________________ which is equivalent to the assessed value of the property, so that pending these proceedings, the plaintiff may immediately be placed in possession of the property involved. WHEREFORE, it is respectfully prayed: 1. That, after due notice and hearing, an order of condemnation be entered, declaring that the plaintiff has a lawful right to take the several properties herein sought to be condemned for public use, upon payment of just compensation to be determined as of the filing of this complaint; 2. That, upon entry of order of condemnation, three competent and disinterested persons be appointed as commissioners to ascertain and report to the court the just compensation for the property to be condemned; 3. That, pending these proceedings, the plaintiff be placed in possession of the property upon deposit with the National Treasurer of such sum as may provisionally be ascertained and fixed by this court, subject to the orders and final disposition of the same. Other reliefs just and equitable are likewise prayed for. Manila, Philippines, May 16, 2012.

Maria Santos Counsel for the Plaintiff Roll of Attorney No. ________ PTR No. ____, _______ (date and place of issue) IBP No. ____, _______ (date and place of issue) MCLE Compliance or Exemption No. ____________ Office Address ______________________________ Contact Number _____________________________

NOTICE OF HEARING Atty. Stephanie Del Castillo Counsel for the Defendant GREETINGS: Please take notice that the above motion shall be submitted for the consideration of the honorable court on Friday, (month, date and year) at 8:30 AM, or as soon thereafter as the counsel may be heard. Maria Santos Counsel for the Plaintiff Roll of Attorney No. ________ PTR No. ____, _______ (date and place of issue) IBP No. ____, _______ (date and place of issue) MCLE Compliance or Exemption No. ____________ Office Address ______________________________ Contact Number _____________________________

PROOF OF SERVICE Copy furnished Through registered mail: Atty. Stephanie Del Castillo Counsel for the Defendant Address _______________ Reg. receipt no. _________ Date___________________ Post Office at ___________ EXPLANATION Service of the above pleading was effected through registered mail because of the impracticablitiy of personal service. The office of the undersigned counsel is located at the city of Manila while that of the adverse counsel is located in Baguio City, and there are no messengerial personnel in the employ of the undersigned counsel who could effect personal service. (Name and Signature of the Counsel for the Plaintiff)

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING VERIFICATION JUAN DELA CRUZ, subscribing under oath, hereby deposes and states that: I am the petitioner in the instant case. I have read the foregoing Petition and the allegations therein are true and correct of my own knowledge and/or based on the records on hand. I attest to the authenticity of the annexes thereof. CERTIFICATION I certify that: a. I have not commenced any other action or proceeding involving the same issues in the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency. b. No such action or proceeding is pending in the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency. c. If I should learn that a similar action or proceeding has been filed or is pending before the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency, I hereby undertake to notify this Honorable Court within five (5) days from such notice. _______________________ JUAN DELA CRUZ

REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION REGIONAL TRIAL COURT Manila, Branch 1 COMPLAINT FOR FORECLOSURE OF REAL ESTATE MORTGAGE Plaintiff, thru the undersigned counsel, and unto this Honorable Court, respectfully sates that: 1. (State the names and residences of the mortgagor and mortgagee); 2. On (specific date), defendant obtained a loan in the sum of ___________, evidenced by a promissory note on the same date, promising to pay the plaintiff the amount with legal interest, on or before ______________. Copy of the promissory note is here attached as Annex A of this complaint; 3. The loan was secured by a real estate mortgage executed by the defendant in favour of the plaintiff, on a (state description of the real property) located in _____________________; 4. The real estate mortgage was duly registered with the Registry of Deeds of ___________ on _____________. Copy of the said mortgage is attached as Annex B and made an integral part of this complaint; 5. Defendant has not paid the mortgage debt of ______________, in spite the lapse of the stipulated period; 6. Defendant failed to pay the plaintiff any amount despite repeated oral and written demands to satisfy the same. A copy of the final written demand letter personally received by the defendant is here attached as Annex C, and 7. There are no other persons having or claiming and interest in the mortgaged property. WHEREFORE, it is respectfully prayed that judgement be rendered against the defendant. 1. To pay within a period of not less than ninety (90) days but not more than one hundred twenty days (120) from entry of judgment the sum of ___________ together with the stipulated interest, plus cost of suit and attorneys fees, and 2. In default of such payment, the abovementioned property be ordered sold at public auction to pay off the mortgage debt and its accumulated interest, plus attorneys fees and cost of suit. Other reliefs just and equitable are likewise prayed for. Manila, Philippines, May 16, 2012.

Maria Santos Counsel for the Plaintiff Roll of Attorney No. ________ PTR No. ____, _______ (date and place of issue) IBP No. ____, _______ (date and place of issue) MCLE Compliance or Exemption No. ____________ Office Address ______________________________ Contact Number _____________________________

NOTICE OF HEARING Atty. Stephanie Del Castillo Counsel for the Defendant GREETINGS: Please take notice that the above motion shall be submitted for the consideration of the honorable court on Friday, (month, date and year) at 8:30 AM, or as soon thereafter as the counsel may be heard. Maria Santos Counsel for the Plaintiff Roll of Attorney No. ________ PTR No. ____, _______ (date and place of issue) IBP No. ____, _______ (date and place of issue) MCLE Compliance or Exemption No. ____________ Office Address ______________________________ Contact Number _____________________________

PROOF OF SERVICE Copy furnished Through registered mail: Atty. Stephanie Del Castillo Counsel for the Defendant Address _______________ Reg. receipt no. _________ Date___________________ Post Office at ___________ EXPLANATION Service of the above pleading was effected through registered mail because of the impracticablitiy of personal service. The office of the undersigned counsel is located at the city of Manila while that of the adverse counsel is located in Baguio City, and there are no messengerial personnel in the employ of the undersigned counsel who could effect personal service. (Name and Signature of the Counsel for the Plaintiff)

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING VERIFICATION JUAN DELA CRUZ, subscribing under oath, hereby deposes and states that: I am the petitioner in the instant case. I have read the foregoing Petition and the allegations therein are true and correct of my own knowledge and/or based on the records on hand. I attest to the authenticity of the annexes thereof. CERTIFICATION I certify that: d. I have not commenced any other action or proceeding involving the same issues in the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency. e. No such action or proceeding is pending in the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency. f. If I should learn that a similar action or proceeding has been filed or is pending before the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency, I hereby undertake to notify this Honorable Court within five (5) days from such notice. _______________________ JUAN DELA CRUZ

REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION REGIONAL TRIAL COURT Manila, Branch 1 PETITION PLAINTIFF, thru counsel, unto this Honorable Court respectfully avers that: 1. Petitioner and the respondent are both of age, and residents of _________________. 2. Petitioner, in whose behalf this application is being made, is actually restrained of his liberty by the respondent at the latters residence at ________________. 3. This restraint of liberty of the petitioner consist of the following: (State facts constituting the illegal confinement) 4. Such restraint of the petitioner by the respondent is without any legal authority. 5. Petitioner, thru counsel, has exhausted all efforts available at law, and that he has no other plain, speedy and adequate remedy to protect his personal rights except by his application of a Writ of Habeas Corpus. WHEREFORE, petitioner prays that a Writ of Habeas Corpus be issued by this Honorable Court directed to _________________ commanding the latter to produce the body of __________ before this court at the time and place therein specified, and to summon the respondent ______________ then and there to appear and show cause the detention of said ___________; and that after due proceedings, _______________ be restored to his liberty and forthwith discharged from confinement.

Manila, Philippines, May 16, 2012.

Maria Santos Counsel for the Plaintiff Roll of Attorney No. ________ PTR No. ____, _______ (date and place of issue) IBP No. ____, _______ (date and place of issue) MCLE Compliance or Exemption No. ____________ Office Address ______________________________ Contact Number _____________________________

VERIFICATION

JUAN DELA CRUZ, subscribing under oath, hereby deposes and states that: I am the petitioner in the instant case. I have read the foregoing Petition and the allegations therein are true and correct of my own knowledge and/or based on the records on hand.

REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION REGIONAL TRIAL COURT Manila, Branch 1 In the Matter of Probate of the Will of __________, deceased.

JUAN DELA CRUZ, Petitioner. x_________________________x

SP. PROC. NO. _______

PETITION

PETITIONER, by counsel and to this Honorable Court, alleges: 1. On, ___________, John Doe, an American citizen, died in New York City, New York, U.S.A., leaving a will which was duly executed in accordance with the laws of New York, U.S.A., and named executor in the said will is herein petitioner. True copy of the said will is attached hereto as Annex A. 2. This said will was presented for probate in the Court of ________, New York and was duly allowed by the court per its order of ________. Certified true copy of said order, as certified by the clerk of the said Court, and duly authenticated by the Philippine consular representative in New York, is attached hereto as Annex B. 3. The deceased John Doe left real properties and shares of stock in the City of Manila, Philippines, which are disposed as provided for in the said will and which have a total value of ____________. 4. The persons in whose favour said properties have been disposed of are the following: Names ______________ ______________ ______________ Addresses ______________ ______________ ______________

5. Petitioner as named executor, moves and prays that letters testamentary, be issued to him; that he is competent to serve as executor and is ready to give a bond as required by the Rules of Court. WHEREFORE, petitioner prays that after due notice, publication and hearing the aforementioned will of deceased ______________ be allowed in the Philippines, and that letters testamentary be issued to herein petitioner.

Manila, Philippines, May 16, 2012.

Maria Santos Counsel for the Plaintiff Roll of Attorney No. ________ PTR No. ____, _______ (date and place of issue) IBP No. ____, _______ (date and place of issue) MCLE Compliance or Exemption No. ____________ Office Address ______________________________ Contact Number _____________________________

VERIFICATION

JUAN DELA CRUZ, subscribing under oath, hereby deposes and states that: I am the petitioner in the instant case. I have read the foregoing Petition and the allegations therein are true and correct of my own knowledge and/or based on the records on hand.

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Submitted by:
Maris Angelica C. Ayuyao

Submitted to:
Justice Elpidio Vega

Date Submitted:
May 16, 2012