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REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT


City of Muntinlupa
Branch 5
ANGELA JILL B. BETIA,
Plaintiff,

-versus- CIVIL CASE NO. 12345

JOSEPH M. REYES,
Defendant.
x--------------------------------------------x

ANSWER

COMES NOW, the defendant, through the undersigned


counsel and unto this Honorable Court, most respectfully
avers:

1. That he ADMITS the contents of paragraph 2 only


insofar as his personal circumstances are
concerned;

2. That he ADMITS his obligation of paying the


monthly installments cited in paragraph 3 of the
complaint, but DENY the rest of the allegations
therein as said defendant’s obligation to plaintiff is
not for the exercise of a right to repurchase but for
the amortization of a loan that he acquired from
the plaintiff at an interest of 12% per annum;

3. That defendant is without knowledge or information


sufficient to form a belief as to the veracity of the
averments in paragraph 4 of the complaint;

4. That defendant does not, at the moment, have all


the records of payments he made to plaintiff, so
that he also does not have information sufficient to
form a belief as the truth of the allegations in
paragraph 5 of the complaint and, therefore, DENY
them.

WHEREFORE, the defendant respectfully prays that


the complaint be dismissed with costs against the plaintiff.

Other relief and remedies as may be deemed just


and equitable under the premises are likewise prayed for.

City of Muntinlupa, October 8, 2004.


SISON-GIMELO LAW OFFICE
Counsel for the Defendant
Unit 205, Quadrillion Mansion, San Juan

By:

MICAH ALVIN S. GIMELO


Roll No. 98765
IBP No, 12345/1-3-2012/Manila
PTR No. 34567/1-3-2012/Manila

Copy furnished:
ATTY. KRIZIA MAE P. REAMICO
Counsel for the Plaintiff
Unit 1234 Forbes Building, Makati

EXPLANATION

Copy of the foregoing ANSWER was served to


plaintiff’s counsel by registered mail due to time and
distance constraints and for lack of the undersigned’s staff
who can serve the same in person.

MICAH ALVIN S. GIMELO


REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
City of Manila
Branch 1

MARIA PATRESE CLAVERIA,


Plaintiff,
Civil Case No. 0453
-versus- For: Sum of Money with Prayer for
Injunction

KRIZIA MAE REAMICO,


Defendant,

x-------------------------------------------------x

COMPLAINT

Plaintiff, through counsel alleges:

1. Plaintiff Maria Patrese Claveria of legal age, single and


a resident of 22 Happy Street, Tondo, Manila ; while
defendant Krizia Mae Reamico is of legal age, single,
and a resident of 122 Pride St., Las Pinas;

2. Plaintiff, engaged in the sale of flower vases, entered


into an exclusive dealership and distribution
agreement with Halimuyak International Corporation
(HALIMUYAK for brevity) whereby plaintiff would
exclusively sell Krizia’s products in the Philippines;

3. Defendant, also engaged in the sale of flower vase


began selling the products without authority to do so;

4. As a result of defendant’s acts, plaintiff suffered


damages and is sale of the products of Lakas has been
diminishing to such an extent that plaintiff has been
losing profits of no less than Php 500,000.00 a month
starting January 2018;

5. Defendant continues to commit the act of illegally and


unlawfully interfering with the agreement executed
between plaintiff and defendant;

6. That the plaintiff is entitled to the relief demanded and


the whole or part of such relief consists in restraining
the commission or continuance of the acts complained
of, either for a limited period or perpetually;

7. That the commission or continuance of some act


complained of during the litigation would probably
work some injustice to the plaintiff;

8. That the plaintiff hereby applies for a writ of


preliminary injunction to restrain the defendant from
the proposed act herein complained of, and for the
purpose hereby offers a bond in such sum as the
Honorable Court may fix.

PRAYER
WHEREFORE, it is respectfully prayed for that after
due notice and hearing a preliminary injunction be issued
forthwith to restrain defendant from doing the act herein
complained of, namely to cease and desist from selling the
products of HALIMUYAK International Corporation.; and
that after trial, said injunction be made permanent, with
costs, and with such further orders that are just and
equitable.

City of Manila, Philippines, July 17, 2018.

ATTY. MICAH ALVIN S. GIMELO


Counsel for the Plaintiff
Room 205, Quadrillion Mansion,
Las Pinas
IBP NO. 097709; 1/10/10
PTR NO. 0977097; 1/10/10
ROLL NO. 051694; 05/05/05
MCLE NO. I 123456; 09/09/09
REPUBLIC OF THE PHILIPPINES)
CITY OF MANILA ) S.S.

VERIFICATION AND CERTIFICATION

VERIFICATION AND CERTIFICATION OF NON-


FORUM SHOPPING

I, MARIA PATRESE CLAVERIA, of legal age and


resident of 22 Happy Street, Tondo, Manila, under oath
declare that:

1. I am the Plaintiff in the above-entitled case;

2. That I have caused the preparation of the foregoing


compalint and have read the allegations contained
therein;

3. The allegations in said answer are true and correct of


my own knowledge and based on authentic records;

4. I hereby certify that I have not commenced any other


action or proceeding involving the same issues in any
court, tribunal or quasi-judicial agency and, to the
best of my knowledge, no such other action or claim
is pending therein;

5. If I should thereafter learn that a similar action or


proceeding has been filed or is pending, I hereby
undertake to report that fact within five (5) days
therefrom to the court or agency where the original
pleading and sworn certification contemplated herein
have been filed;
6. I executed this verification/certification to attest to the
truth of the foregoing facts and to comply with the
provisions of Adm. Circular No. 04-94 of the Honorable
Supreme Court.

IN WITNESS WHEREOF, I have hereunto affixed my


signature this 17th day of July 2018, in the City of Manila.

(sgd) MARIA PATRESE CLAVERIA

JURAT

SUBSCRIBED AND SWORN TO before me this 17th day


of July 2018, in the City of Manila, affiant exhibiting to me
his SSS ID No. 123456 issued on January 5, 2012.

ATTY. MICAH ALVIN S. GIMELO


Notary Public for Las Pinas
Suite 258 Tower B, Las Pinas
Appointment no. 123, Until December 31, 2018
IBP NO. 097709; 1/10/10
PTR NO. 0977097; 1/10/10
ROLL NO. 051694; 05/05/05
MCLE NO. I 123456; 09/09/09
MCLE NO. II 123456; 09/09/10
Serial No. of Commission M123Doc No. 38

Page No. 58
Book No. VII
Series of 2018
REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
QUEZON CITY
Branch 1

Darian Kaye S. Aquino,


Petitioner

- versus - G.R. No. 1234566


For: Writ of Habeas Corpus

Angela Jill G. Betia,


Respondent.

x -----------------------------x

PETITION

NOW COMES, Darian Kaye S. Aquino, the Petitioner,


by the undersigned counsel, to this Honorable Court and
respectfully represents:

1. That she is the mother of Krizia Mae P. Reamico,


who is presently in the custody of Angela Jill G. Betia,
the maternal grandmother of Krizia Mae P. Reamico,
who forcibly abducted Krizia and until now actually
restraints her of her liberty;

2. That despite demands, Angela, the respondent,


refuses to turn over the custody of Krizia to the
petitioner;
PRAYER

WHEREFORE, it is respectfully prayed that an order be


issued to Darian Kaye S. Aqui to bring the minor Krizia Mae
P. Reamico to this Honorable Court at the hour and date to
be set by this Honorable court, and thereafter that the
custody of the minor X be turned over to the petitioner.

Quezon City, Philippines, this 20th day of March 2013.


REPUBLIC OF THE PHILIPPINES)
CITY OF MANILA ) S.S.

VERIFICATION AND CERTIFICATION OF NON-


FORUM SHOPPING

I, Darian Kaye S. Aquino, of legal age, after having been


duly sworn in accordance with law, depose and state that:

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing


complaint;

3. I have read the contents thereof and the facts


stated therein are true and correct of my personal
knowledge and/or on the basis of copies of documents
and records in my possession;

4. I have not commenced any other action or


proceeding involving the same issues in the Supreme
Court, the Court of Appeals, or any other tribunal or
agency;

5. To the best of my knowledge and belief, no such


action or proceeding is pending in the Supreme Court,
the Court of Appeals, or any other tribunal or agency;

6. If I should thereafter learn that a similar action or


proceeding has been filed or is pending before the
Supreme Court, the Court of Appeals, or any other
tribunal or agency, I undertake to report that fact
within five (5) days therefrom to this Honorable
Court.
(sgd) DARIAN KAYE S. AQUINO

AFFIANT
JURAT

SUBSCRIBED AND SWORN to before me this 20TH


day of March 2003 at Sison-Gimelo Law Office affiant
exhibitin to me his Community Tax Certificate No.
123445 issued on April 2000 at Quezon City.

ATTY. MICAH ALVIN S. GIMELO


Notary Public for Quezon City
Room 23 Luxe Condominium, Quezon City
Appointment no. 123, Until December 31, 2018
IBP NO. 097709; 1/10/10
PTR NO. 0977097; 1/10/10
ROLL NO. 051694; 05/05/05
MCLE NO. I 123456; 09/09/09
MCLE NO. II 123456; 09/09/10
Serial No. of Commission M123Doc No. 38
REAL ESTATE MORTGAGE AGREEMENT

KNOW ALL MEN BY THESE PRESENTS:

I, Micah Alvin S. Gimelo, Filipino, of legal age, married


and with address at B3, L3, Capitoline Hills, Italia 500, Las
Pinas City, for and in consideration of a loan in the sum of
One Million and Five Hundred Thousand Pesos (P
1,500,000.00), Philippine Currency, to me in hand paid
Krizia Mae P. Reamico, Filipino, of legal age, single, and
with residence and post office address of 34 Relay Street,
Moonwalk Village, Las Pinas, her heirs and assigns, that
certain parcel of land, together with all the buildings and
improvements thereon, situated in, Morong, Rizal. Bounded
in the north by property of Venancio Ablay y Simeon Ablay;
in the east by the property of Veronica Tulak y Dionisio
Ablay; and in the west by the property of Dionisio y Ablay
with an area of 9,856 square meters evidenced by
Original/Transfer Certificate of Title No. 1234567 of the
land registry of the Province of Rizal; The loan shall be
payable on or before 15 December 2019. Failure and/or
refusal or the Debtor/Mortgagor to pay shall automatically
make the principal loan of P 1,500,000.00 due and
demandable, together with the unpaid interest, if any.

In consideration of the loan stated hereof and by way


of a security there For and in consideration of the loan
stated in paragraph 2 hereof and by way of a security
therefor, the Debtor/Mortgagor hereby constitutes a real
estate mortgage on the Property in favor
of Creditor/Mortgagee, under the following terms and
conditions:
1. The mortgage shall secure the payment of the
loan, together with the unpaid interest, if any.
2. In case the maturity of the loan is extended,
upon mutual agreement in writing of the Parties, this
mortgage shall be a continuing security for the
obligation/s of the Debtor/Mortgagor to
the Creditor/Mortgagee without the necessity of
executing a new contract of real estate mortgage.
3. If the Debtor/Mortgagor shall well pay and/or
comply with his all and every obligation under
this Deed, then this mortgage shall cease to have any
force and effect. However, if
the Debtor/Mortgagor shall fail and/or refuse, for any
reason whatsoever, to fully pay and/or comply with all
or any of his said obligations, then
the Creditor/Mortgagee may judicially or
extrajudicially, at his option, foreclose the mortgage
on the property in accordance with law.
4. In case collection of any amount due under this
mortgage agreement is referred to a lawyer by
the Creditor/Mortgagor, the Debtor/Mortgagor is
under obligation to pay the former twenty percent
(20%) of the amount due.

for, the Debtor/Mortgagor hereby constitutes a real


estate mortgage on the Property in favor
of Creditor/Mortgagee, under the following terms and
conditions:
1. The mortgage shall secure the payment of the loan,
together with the unpaid interest, if any.
2. In case the maturity of the loan is extended,
upon mutual agreement in writing of the Parties, this
mortgage shall be a continuing security for the
obligation/s of the Debtor/Mortgagor to
the Creditor/Mortgagee without the necessity of
executing a new contract of real estate mortgage.
3. If the Debtor/Mortgagor shall well pay and/or
comply with his all and every obligation under
this Deed, then this mortgage shall cease to have any
force and effect. However, if
the Debtor/Mortgagor shall fail and/or refuse, for any
reason whatsoever, to fully pay and/or comply with all
or any of his said obligations, then
the Creditor/Mortgagee may judicially or
extrajudicially, at his option, foreclose the mortgage
on the property in accordance with law.
4. In case collection of any amount due under this
mortgage agreement is referred to a lawyer by
the Creditor/Mortgagor, the Debtor/Mortgagor is
under obligation to pay the former twenty percent
(20%) of the amount due.

IN WITNESS whereof, the Parties affixed their


signatures this 20th day of February 2017 in Las Pinas
City.
Signed:
MICAH ALVIN S. GIMELO
(Mortgagor)

KRIZIA MAE P. REAMICO


(Mortgagee)

Signed in the presence of:


ANGELA JILL G. BETIA
Witness
ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES)


) S.S.
x––––––––––––––––––––––x

BEFORE ME personally appeared:

PERSONS ID
KRIZIA MAE P. REAMICO Driver’s License No. 123455
MICAH ALVIN S. GIMELO Driver’s License No. 234455

presenting their competent evidence of identity, known to


me and to me known to be the same persons who executed
the foregoing Real Estate Mortgage Agreement and
they acknowledged to me that the same is their knowing,
free and voluntary act and deed.
This document relates to the mortgage of a parcel of land
registered under TCT No. 2344566of the Registry of
Deeds for RIZAL City and consists of Ten (10) pages,
including this page, each of which had been signed by
the Parties and their instrumental witnesses.
WITNESS my signature and notarial seal this 11th day of
May 2017.

Doc. No. 123;


Page No. 4;
Book No.56
Series of 2017.
DEED OF ABSOLUTE SALE WITH PACTO DE RETRO

KNOW ALL MEN BY THESE PRESENTS:

This Deed of Absolute Sale with Pacto de


Retro made and executed by and between:

MICAH ALVIN S. GIMELO, of legal age, Filipino,


single, and with postal address at No. Relay Street, Las
Pinas City, hereinafter referred to as the SELLER;

and

ANGELA JILL G. BETIA, of legal age, Filipino, single


with residence address at 555 Kamagong Street, Ayala
Alabang Village, Muntinlupa City, Metro Manilahereinafter
referred to as the BUYER.

WITNESSETH:

That the SELLER is the absolute owner of a certain


parcel of land situated in San Pablo City, Province of
Laguna, and more particularly described and bounded as
follows:

TCT No. T-123456


A PARCEL OF LAND (Lot 32 of the consolidation-subdivision
plan (LRC) Pcs-5141, being a portion of the consolidation of
Lots 1 and 2, Psu-112287 Amd., LRC (GLRO) Rec. No. N-
17511), situated in the Dist. Of Concepcion, City of San
Pablo, Laguna, Island of Luzon. Bounded on the NE., points
3 to 6, by Lot 85; on the S., points 6 to 1 by Lot 30; on the
SW., points 1 to 2, by Lot 31; and on the N., points 2 to 3
by Lot 35, all of the consolidation-subdivision plan.
Beginning at a point marked "1" on plan, being N. 51 deg.
36' E., 1321.76 m. from B.L.L.M. No.1, San Pablo, Laguna
(a copy of which title is hereto attached as Annex "A")

THAT the SELLER, for and in consideration of the


amount of FIVE HUNDRED THOUSAND PESOS
(P500,000.00), Philippine Currency, receipt in full is hereby
acknowledged by her to her satisfaction, hereby
SELL, TRANSFER and CONVEY under PACTO DE RETRO
unto said BUYER, his heirs and assigns, the above described
property with all the buildings and improvement thereon,
free from liens and encumbrances whatsoever;

THAT the SELLER, in executing this conveyance,


hereby reserves the right to REPURCHASE, and the BUYER,
in accepting the same, hereby obligates himself to RESELL
the property herein conveyed within a period of five (5)
years from and after the date of this instrument for the
same price of FIVE HUNDRED THOUSAND PESOS
(P500,000.00), Philippine Currency: Provided however,
that if the SELLER fails to exercise her right to repurchase
as herein granted within the period stipulated, then
this conveyance shall become absolute and irrevocable,
without the necessity of drawing up a new deed of absolute
sale, subject to the requirements of the law
regarding consolidation f ownership of real property.
IN WITNESS WHEREOF, the parties have hereunto
set their hands this 16th day of June 2013 in Manila,
Philippines.

MICAH ALVIN S. GIMELO ANGELA JILL G. BETIA


Seller Buyer

Signed in the presence of:


KRIZIA MAE P. REAMICO
Witness
DEED OF SALE OF REAL PROPERTY

KNOW ALL MEN BY THESE PRESENTS:

I, MICAH ALVIN S. GIMELO Filipino citizen, single, of


legal age with residence and post-office address at 27 Relay
Street Manila, for and in consideration of the sum of Two
Hundred Million Pesos, paid to me today by KRIZIA MAE P.
REAMICO, Filipino citizen, of legal age, with residence and
post office address at 23 Happy Street, Las Pinas City, do
hereby SELL, TRANSFER, AND CONVEY absolutely and
unconditionally, unto said KRIZIA MAE P. REAMICO her
heirs and assigns, that certain parcel of land, together with
the buildings and improvements thereon, situated in the
City/Municipality of Rizal), and more particularly described
as follows:

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
(LRC) Psd-50533, Lot 3, Psd-100703, Lot 1, Psd-150980,
LRC Rec. Nos. Nos. N-27024, 51768, 89632, N-11782, N-
13466, and 21071 situated in the Bo. of San Donisio, Mun
of Paranaque, Prov of Rizal, Is. of Luzon. Bounded on NE.,
point 4 to 1 by Road Lot 22, on...to the point of beginning;
containing an area of (280) square meters more or less..."

of which I am the registered owner in fee simple, my title


thereto being evidenced by Transfer (or Original) Certificate
of Title No. 1234556, issued by the Register of Deeds of
Rizal.

It is hereby mutually agreed that the vendee shall


bear all the expenses for the execution and registration of
this deed of sale.
IN WITNESSS WHEREOF, I have hereunto signed
this deed of sale, this 21st day of November, 2013 at
Municipality of Rizal, Philippines.

MICAH ALVIN S. GIMELO KRIZIA MAE P. REAMICO


Vendor Vendee

SIGNED IN THE PRESENCE OF:

ANGELA JILL G. BETIA


Witness

ACKNOWLEDGMENT

Republic of the Philippines)


City/Mun. of Rizal ) S.S.

PERSONS ID

KRIZIA MAE P. REAMICO Driver’s License No. 123455

MICAH ALVIN S. GIMELO Driver’s License No. 234455

presenting their competent evidence of identity, known to


me and to me known to be the same persons who executed
the foregoing Real Estate Mortgage Agreement and
they acknowledged to me that the same is their knowing,
free and voluntary act and deed.
This document relates to the mortgage of a parcel of land
registered under TCT No. 1234556 of the Registry of
Deeds for Municipality of Rizal and consists of three (3)
pages, including this page, each of which had been signed
by the Parties and their instrumental witnesses.
WITNESS my signature and notarial seal this 11th day of
December 2013.

Doc. No. 4;
Page No. 2;
Book No. 21;
Series of 2017.
CONTRACT OF SALE OF MOTOR VEHICLE

KNOW ALL MEN BY THESE PRESENTS:

That I, MICAH ALVIN S. GIMELO. , of legal age, Filipino,


single and a resident of 27 Relay Street, Moonwalk Village,
Las Pinas City, for and in consideration of the amount of
FIVE HUNDRED THOUSAND (5000, 000.00) PESOS,
Philippine Currency, receipt of which is hereby
acknowledged from ANGELA JILL G. BETIA, of legal age,
Filipino, single and a resident of 23 Gold Street, Don
Antonio, Quezon City, do hereby SELL, CEDE, TRANSFER
and CONVEY unto ANGELA JILL G. BETIA and in favor of
his heirs, successors and assigns a motor vehicle
particularly described as follows:

Make and Type: MITSUBISHI LANCER EX


Motor Number: 900-87654-PP8765
Serial/Chassis No. : YT98-009754-9
Plate No. : PRO 984
MV FILE NO. : 09978-9977
COLOR: Black

Free from liens and encumbrances.

IN WITNESS WHEREOF, I have hereunto set my hand this


20th day of January 2018 at Echague, Isabela,
Philippines.

MICAH ALVIN S. GIMELO

SIGNED IN THE PRESENCE OF:

KRIZIA MAE P. REAMICO MA. PATRESE CLAVERIA


Witness Witness
REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
Manila, Branch 1

PEOPLE OF THE PHILIPPINES,


Plaintiff,
Criminal Case No. 2251
-versus-

KIERK C. RET,
Accused,
x-------------------------------------------------x

MOTION TO QUASH

Accused, through the undersigned counsel,


respectfully moves to quash the information filed against
him on the ground that the court has no jurisdiction to try
the present case.

ARGUMENTS:

1. The accused KIERK C. RET is a minor;


2. The proper court to try the present case would be a
Family Court;
3. The Crime was committed in Mandaluyong CIty,
hence, the venue lies therein
WHEREFORE, it is respectfully prayed that the
information against the accused be dismissed.
City of Manila, Philippines, July 17, 2018.

ATTY. MICAH ALVIN S. GIMELO


Counsel for the Defendant
Suite 258 Tower B,
Las Pinas
IBP NO. 097709; 1/10/10
PTR NO. 0977097; 1/10/10
ROLL NO. 051694; 05/05/05
MCLE NO.I 123456; 09/09/09
REPUBLIC OF THE PHILIPPINES
METROPOLITAN TRIAL COURT
City of Las Pinas
Branch 3

KIERK C. RET,
Plaintiff,

-
versus- Civil Case No. 12345

KRIZIA P. REAMICO,
Defendant.
x--------------------------------------------x

MOTION FOR EXECUTION OF JUDGMENT

COMES NOW, the Plaintiff through undersigned


counsel and to this Honorable Court respectfully alleged:

1. That judgment was rendered by this Honorable


Court in favor of the plaintiff on June 1, 2017.

2. That said judgment was duly received by the


defendant on July 5, 2017 as shown in the registry
return card;

3. That up to the present, the defendant had not filed


any motion for reconsideration or had appealed
from said decision, hence the decision has become
final and executory.
WHEREFORE, it is respectfully prayed that an order be
issued by this Honorable Court for a writ of execution of
said judgment.

Las Pinas, Philippines, July 17, 2018.

ATTY. MICAH ALVIN S. GIMELO


Counsel for the Plaintiff
Suite 258 Tower B,
Las Pinas
IBP NO. 097709; 1/10/10
PTR NO. 0977097; 1/10/10
ROLL NO. 051694; 05/05/05
MCLE NO. I 123456; 09/09/09
LEGAL FORMS
ATTY. MELANIE TRINIDAD
Submitted by: Micah Alvin S. Gimelo
2014400175