Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch ____
Makati City
-oOo-

JORGE GONZALES,
Plaintiff, CIVIL CASE NO. ____

-versus- For: DAMAGES

EXOR BANK,
Defendant.
x- - - - - - - - - - - - - - - - - - x

MOTION FOR INTERVENTION

COMES NOW, the Intervenor, RENE HISON, through
the undersigned counsels, to this Honorable Court, most
respectfully prays that he be permitted to file a Complaint
for Intervention in the above-entitled case, for the following
reasons:

That the intervenor Rene Hison received a check from

herein Defendant Gonzales for 250, 000 php, and upon
presentment before the Exor Bank for encashment, it was
unfortunately dishonored by the said bank.

That the Intervenor has a legal interest in the matter in

litigation, or in the success of the complainant, or is so situated
as to be adversely affected by a distribution or other disposition
of the parcel of land, subject matter of the above-captioned
case;

That this intervention will not, in the least, unduly delay or

prejudice the adjudication of the rights of the original parties in
the case;

That the Intervenor's rights can be fully protected in this

proceeding rather than by filing a separate proceeding.

Makati City, Philippines, August 5, 2018.

Page 1 of 6
Jorge Gonzales -vs- Exor Bank
For: DAMAGES
Complaint
x- - - - - - - - - - - - - - - - - - - - - - - x

PRAYER

WHEREFORE, it is most respectfully prayed that the said

Intervenor RENE HISON be allowed to intervene in this action
by filing a Complaint in Intervention, a copy of which is attached
to this motion.
Makati City, Philippines, 5 August 2018.

MAGA LAW OFFICE

110 Benavidez Keyland Building
Benavidez St, Legaspi Village, Makati City

By:

RAY JOHN AGREGADO

IBP No. 123466/1-1-2016/Makati City
PTR No. 1239567/1-2-2016/Makati City
Attorney’s Roll No. 12345
MCLE No. NCR-0001234
TIN: 123-456-789

MEL JOHN ACUROS

IBP No. 756012/1-1-2016/Makati City
PTR No. 7890123/1-2-2016/Makati City
Attorney’s Roll No. 67890
MCLE No. NCR-0006789
TIN: 123-456-780

HAZEL GARCIA
IBP No. 590923/1-1-2016/Makati City
PTR No. 7876619/1-2-2016/Makati City
Attorney’s Roll No. 73193
MCLE No. NCR-0001872
TIN: 123-456-786

DIANNE P. MEDIANERO
IBP No. 186261/1-1-2016/Makati City
PTR No. 5176797/1-2-2016/Makati City
Attorney’s Roll No. 17862
MCLE No. NCR-0001810
TIN: 123-456-785
Page 2 of 6
Jorge Gonzales -vs- Exor Bank
For: DAMAGES
Complaint
x- - - - - - - - - - - - - - - - - - - - - - - x

NOTICE OF HEARING

TO: ATTY. ANNE ROSE VALENCIA

Counsel for the Plaintiff

Greetings:

Sir: Please take kind notice that on _______, August 2018 at

___in the morning or as soon thereafter as counsel may be
heard, the undersigned attorney will ask the Regional Trial
Court of Regional Trial Court of National Capital Region
(Branch __) that the foregoing Motion to Intervene with
Complaint- in Intervention be granted.

ATTY. RAY JOHN AGREGADO

Attorney for the Intervenor

Page 3 of 6
Jorge Gonzales -vs- Exor Bank
For: DAMAGES
Complaint
x- - - - - - - - - - - - - - - - - - - - - - - x
INSERT COMPLAINT-IN-INTERVENTION

Page 4 of 6
Jorge Gonzales -vs- Exor Bank
For: DAMAGES
Complaint
x- - - - - - - - - - - - - - - - - - - - - - - x
Republic of the Philippines)
City of Makati ) S.S.

VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING

I, RENE HISON, of legal age, after having been duly

sworn in accordance with law, depose and state that:

1. I am an intervenor in the above-stated case;

2. I caused the preparation of the foregoing motion for

intervention and complaint-in-intervention;

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.

IN WITNESS WHEREOF, I have hereunto set my hand

this August 5, 2018 in the City of Makati, Philippines.

RENE HISON
Affiant

SUBSCRIBED AND SWORN TO before me this 5th day

of August 2018 in Makati City, Philippines, affiant exhibiting to
me competent evidence of his identity being TIN 456-789-123
issued on March 12, 2018 issued at Manila City and swore

Page 5 of 6
Jorge Gonzales -vs- Exor Bank
For: DAMAGES
Complaint
x- - - - - - - - - - - - - - - - - - - - - - - x
under the penalty of law as to the truth of the contents of the
foregoing document or instruments.

ATTY. JOHNNY BRAVO

Notary Public
IBP No. 287261/1-1-2016/Makati City
PTR No. 8176497/1-2-2016/Makati City
Attorney’s Roll No. 17862
MCLE No. NCR-0001810
TIN: 123-456-785

Doc. No. 125;

Page No. 123 ;
Book No. XlVI;
Series of 2018.

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