COMPLAINT FOR RECOVERY OF PERSONAL PROPERTY (Replevin) (CAPTION AND TITLE) alleges: COMES NOW, the Plaintiff, through

the undersigned counsel in the above entitled case and to this Honorable Court 1. 2. 3. That said plaintiff is the lawful owner of the following described personal property; That on or about the 1st day of March 1988, herein defendant borrowed said property from Plaintiff promising to return the same the next day; That on April 1, 1988, and for 10 days thereafter, the herein Plaintiff demanded for the return of the said property but despite repeated demands, said Defendant refused and still refuses to return the said property claiming that the same belongs to him; That said property has not been taken from the said plaintiff for tax assessment or fine pursuant to law, or seized under an execution, or attachment against the property of the Plaintiff (or if so seized, that it is exempted from such seizure); That the actual value of the said personal property is P10, 000.00; That the herein plaintiff is ready and willing to file a bond, executed to the defendant in double the value of the property stated above, for the return of the property to the Defendant if the return thereof be adjudged, and for the payment to the Defendant of such sum as he may recover from the Plaintiff in the auction.

4.

5. 6.

WHEREFORE, Plaintiff prays for judgment: 1. 2. Ordering the sheriff or other officer of the Court forthwith to take such property into his custody and to dispose of it in accordance with the Rules of Court; After trial of the issues, adjudging that the Plaintiff has the right to the possession of said personal property and rendering judgment in the alternative against the Defendant for the delivery thereof to the Plaintiff of the value thereof in case delivery cannot be made; Ordering the defendant to pay the costs of this suit, and for such other equitable relief in the premises. _________________________ Counsel VERIFICATION/CERTIFICATIONOF NON-FORUM SHOPPING I, NAPOLEON C. GATMAITAN, Filipino, of legal age with address at#11 Bohol St., Barangay Horseshoe, Quezon City after having been duly sworn in accordance with law depose and say: 1.That I am the plaintiff in the above-entitled case; 2.That I caused the preparation of the foregoing Complaint and I have read the allegations therein and certify that the same are true and correct of my own personal knowledge; 3.That I further certify that I have not commenced any other action involving the same issues before the Supreme Court, Court of Appeals or any division thereof or any tribunal or agency; and to the best of my knowledge no such action is pending before The Supreme Court, Court of Appeals or any division thereof or any tribunal oragency;4.That in the event that any action involving the same should be made known, I hereby bind myself to report the same within five (5)days from knowledge thereof to this Honorable Court. WITNESS WHEREOF, I hereunto set my hand this _______ day of ________, ________ at Quezon City, Metro Manila, Philippines. NAPOLEON C. GATMAITAN Plaintiff SUBSCRIBED AND SWORN TO before me this ______ day of ______, ______ at Quezon City, affiant having exhibited to me her CTC No. ___________ issued on __________ at __________.

3.

NOTARY PUBLIC Doc. No._____ Page No. ____ Book No. _____ Series of _____ COMPLAINT FOR EJECTMENT XYZ Plaintiff, -versusABC Defendant. x---------------------------x COMPLAINT COMES NOW the Plaintiff in the above entitled case, through counsel, and to this Honorable Court alleges; I That the plaintiff is of legal age and a resident of the City of Manila; that defendant is likewise of legal age, residing at No. 2 Cruz Street, Manila and may be served with summons at said address; II That defendant on January 7, 2001, leased from the plaintiff the premises located at No. 7 Cruz Street, Manila, agreeing to pay monthly rental of P 1, 000.00 III However, defendant failed to pay the aforesaid monthly rentals on their due dates, such that as of the date hereof, his arrearages have accumulated up to P_____________; IV That on March 7, 2001, demands was made on defendant to pay his rental in arrears and vacate the premises, but despite said demands, written and oral, defendant failed and refused to pay the rentals in arrears and vacate the premises leased by him; V As a result, plaintiff was constrained to institute this case, incurring in the process obligations for litigation expenses and attorneys fess in the amount of _______________ PRAYER WHEREFORE, it is respectfully prayed that judgment be rendered against the defendant ordering him: 1. 2. 3. To vacate the premises leased by him; To pay the monthly sum of P1, 000.00 beginning with the month of __________, 2001, with interest thereon at the legal rate until fully paid until the defendant vacates said premises; To pay the sum of P_________ as litigation expenses and attorneys fees.

CIVIL CASE NO. _______________

Plaintiff further prays for such other reliefs as this Court may deem just and equitable. Manila, Philippines, May 1, 2001. DEFG Attorney for the Plaintiff _________________________________

Address P.T.R. No._______ Date & Place of Issue_____ IBP O.R. No._____ Date & Place of Issue_____ VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING _______________________ Plaintiff JURAT REPUBLIC OF THE PHILIPPINES LOCAL CIVIL REGISTRY OFFICE Province of Pangasinan CITY OF ALAMINOS Republic of the Philippines ) Province of Pangasinan ) City of Alaminos ) ______________________) SS Petition No. ______________

PETITION FOR CORRECTION OF CLERICAL ERROR IN THE CERTIFICATE OF LIVE BIRTH I, ___________________________________________, of legal age, ____________________, (complete name of petitioner) (nationality/citizenship) and a resident of ____________________________________________________________________ (complete address) after having been duly sworn to in accordance with law, hereby declare that: 1. I am a petitioner seeking correction of the clerical error in: a) my Certificate of Live Birth b) the Certificate of Live Birth of _________________________________________________ (complete name of owner) who is my ___________________________________________________________________ (relation of owner to the petitioner) 2. I/He/She was born on _________________________ at ______________________________ (date of birth) (city/municipality) _______________________________________, ____________________________________. (province) (country) 3. The birth was recorded under registry number __________________________________. 4. The clerical error(s) to be corrected is (are): (Use additional sheets, if necessary.) Item No. Description From To 5. The facts/reasons for filling this petition are the following: (Use additional sheets, if necessary.) ____________________________________________________________________________ ____________________________________________________________________________ ____________________________________________________________________________ ____________________________________________________________________________ ____________________________________________________________________________ 6. I submit the following documents to support this petition: (Use additional sheets, if necessary.) a) ________________________________________________________________________ b) ________________________________________________________________________ c) ________________________________________________________________________ d) ________________________________________________________________________ 7. I have not filed and similar petition and that, to the best of my knowledge, no longer similar petition is pending with any LCRO, Court or Philippine Consulate. 8. I am filing this petition at the LCRO of ______________________, _______________________ (city/municipality) (province) in accordance with RA No. 9048 and its implementing rules and regulations. __________________________________ Signature over printed name of petitioner VERIFICATION I, ____________________________________, the petitioner, hereby certify that the allegations herein are true and correct to the best of my knowledge and belief. ______________________________ Signature over printed name of petitioner SUBSCRIBED AND SWORN to before me this ___________ day of _____________________

in the city / municipality of _____________________________, petitioner exhibiting his Community Tax Certificate No. __________________ issued at __________________ on ______________________. Doc. No. ________________ Page. No. ________________ Book No. ________________ Series of ________________ __________________________ Administering Officer

COMPLAINT COMES NOW, the Plaintiff in the above-entitled case, through counsel, and to this Honorable Court alleges: 1.That plaintiff is of age, married and residing at No. 80 Agno Street, Quezon City, while defendant is likewise of age, married and residing at No. 100 Agno Street, Quezon City, where he may be served with summons; 2.That plaintiff is the owner of a semi-concrete bungalow located at No. 100 Agno Street, Quezon City; 3.That on June 10, 2001, plaintiff leased the said bungalow to the defendant for the next three (3) years at a monthly rental of P1,000.00, payable within the first five days of each month, and that the lease contract thereon is hereto attached as Annex A; 4.That since June 11, 2004, the lease contract had already expired and, despite repeated demands, defendant had refused to vacate the premises and continues to occupy the same. 5.That written demand (Annex B hereof) to vacate and pay rentals in arrears was sent to and received by defendant but despite said demand, he failed to vacate the same or pay said rentals. WHEREFORE, it is respectfully prayed that judgment be rendered against the defendant ordering her: 1.To vacate the premises; 2.To pay the monthly sum of P1,000.00 beginning on June 11, 2004, with interest thereon at the legal rate until fully paid, until the defendant vacates said premises;3.To pay the sum of P2,000.00 as litigation expenses and attorneys fees. Quezon City, July 7, 1983. LAWRENCE VILLEGAS Attorney for the Plaintiff XYZ Building, Quezon City IBP No. 12345; 1/3/1983; Quezon City PTR No.61879; 2/2/1983; Quezon City Roll of Attorneys No. 12344

Verification Jurat Republic of the Philippines METROPOLITAN TRIAL COURT National Capital Judicial Region Branch ____, Quezon City NAPOLEON C. GATMAITAN Plaintiff, -versus-

CIVIL CASE NO. _____ For: Collection of a Sum of Money

EDGARDO S. SANTOS Defendant . X - - - - - - - - - - - - - - - - - - - - - - - - - - -X

COMPLAINT

PLAINTIFF, thru the undersigned Counsel, unto this Honorable Court, respectfully alleges:

1.That Plaintiff is of legal age, Filipino, married to Nancy A. Gatmaitan, and with residence at # 11 Bohol St., Barangay Horseshoe, Quezon City; 2.That Defendant is likewise of legal age, Filipino, married and with residence at # 15 Bohol St., Barangay Horseshoe, Quezon City, where he could be served with summons and other processes of the Court; 3.That the above-named spouse of Plaintiff is the erstwhile business partner of the defendant from year 2007 to 2009;4.That in the course of their business, the plaintiffs spouse made financial contributions through the request and assurances of the defendant that such amount will be repaid. That however, afterseveral months and upon inquiry, plaintiffs spouse found out that defendant misappropriated the financial investments made for his own personal use. That despite demands, defendant failed to remit toand/or settle with the plaintiffs spouse the aggregate amount of Ninety Eight Thousand Seven Hundred Pesos (P98,700.00); 5.That in recognition of defendants obligation in favor of plaintiffs spouse, the former executed an Acknowledgement of Debt in favor of the plaintiff on January 26, 2008, a photocopy of which is attached hereto as Annex A; 6.That by reason of the kindness and generosity of plaintiffs spouse, defendants obligation through the Acknowledgement wasreduced to the sum of Sixty Thousand Pesos (P60,000.0),and transferred in favor of the plaintiff as formalized n a duly-notarized Loan Agreement entered by and between the plaintiff and the defendant on January 29 2008, a photocopy of which is hereto attached as Annex B; 7.That part of said Loan Agreement is the obligation of thedefendant-debtor to pay the plaintiffcreditor the amount of Two Thousand Five Hundred Pesos (P2,500.00) in monthly installments for thirty six (36) months, in the form of cash from February 2008 to March 2011, and in the form of post-dated checks from February 2008onwards up to the full satisfaction of said loan, including interest, set at two percent (2%) per month; 8.That after paying Two Thousand Five Hundred Pesos(P2,500.00) in February 2008 and One Thousand Five Hundred Pesos(P1,500.00) only in March 2008 the defendant-debtor has starteddefaulting in the payment of his due accounts; 9.That plaintiff-creditor sent separate letters (dated April 7,2008 and May 21, 2008) to the defendant-debtor containing a demand for the payment of his outstanding payable, photocopies of which are hereto attached as Annexes C and C-1; 10.That the continued refusal of defendant to settle his account prompted the plaintiff-creditor to lodge a complaint with the barangay officials of Barangay Horseshoe, Quezon City. A Certificate to File Action, copy of which is hereto attached as Annex D, was subsequently issued for failure of the parties to come to an Agreement. 11.That on June 1, 2008 a final demand letter was sent to the defendant-debtor for the payment of his outstanding payable up to July2008, which however, was left unheeded, a photocopy of which ishereto attached as Annex E; 12.That the demand letter was duly received by defendant thru his wife Mrs. Veronica A. Santos on June 3, 2008, as shown by a Certification dated June 25, 2008 issued by the Quezon City Central Post Office, copy of which is hereto attached as Annex F; 13.That defendant-creditor has, as of this date, defaulted in the payment of an aggregate amount of Twenty-six Thousand Pesos(P26,000.00); 14.That notwithstanding plaintiff-creditors repeated oral andwritten demands, defendantdebtor failed and refused and still failsand refuses to heed to the formers just and valid demands, leaving the plaintiff no other recourse but to litigate and file this action. 15.That by reason of defendants unjustified acts as well as bad faith and intentional refusal to pay his overdue obligation, Plaintiff is entitled to the award of moral damages in the amount of P5,000.00; 16.That by reason of defendants violation and disregard of Plaintiffs rights, the award of exemplary damages in the amount of P5,000.00 is likewise warrant to serve as a deterrent to thecommission by the defendant and to others similarly-minded of similar acts in the future. PRAYERWHEREFORE, PREMISES CONSIDERED, it is most respectfully prayed of this Honorable Court that, after due hearing, judgment be rendered against the defendant ordering the latter to pay the plaintiff as follows: 1. 2. 3. 4. The amount of TWENTY SIX THOUSAND PESOS representing the unpaid monthly installments due under the Loan Agreement dated August 6, 2005; The amount of P5,000.00 as and by way of moral damages; The amount of P5,000.00 as and by way of exemplary damages; Cost of suit. Other reliefs just and equitable under the premises are likewise prayed for.

Quezon City,______________ Atty. ANGELICO ZENON M. DELOS REYES

Counsel for the Plaintiff Phoenix Sun Business Park E. Rodriguez Jr. Ave., Libis, Quezon City Roll No. 76430 IBP No. 352980 dated 1-2-08 MCLE Compliance No. 11-00043527 VERIFICATION/CERTIFICATIONOF NON-FORUM SHOPPING I, NAPOLEON C. GATMAITAN, Filipino, of legal age with address at#11 Bohol St., Barangay Horseshoe, Quezon City after having been duly sworn in accordance with law depose and say: 1.That I am the plaintiff in the above-entitled case; 2.That I caused the preparation of the foregoing Complaint and I have read the allegations therein and certify that the same are true and correct of my own personal knowledge; 3.That I further certify that I have not commenced any other action involving the same issues before the Supreme Court, Court of Appeals or any division thereof or any tribunal or agency; and to the best of my knowledge no such action is pending before The Supreme Court, Court of Appeals or any division thereof or any tribunal oragency;4.That in the event that any action involving the same should be made known, I hereby bind myself to report the same within five (5)days from knowledge thereof to this Honorable Court. WITNESS WHEREOF, I hereunto set my hand this _______ day of ________, ________ at Quezon City, Metro Manila, Philippines. NAPOLEON C. GATMAITAN Plaintiff SUBSCRIBED AND SWORN TO before me this ______ day of ______, ______ at Quezon City, affiant having exhibited to me her CTC No. ___________ issued on __________ at __________.

NOTARY PUBLIC Doc. No._____ Page No. ____ Book No. _____ Series of _____ REPUBLIC OF THE PHILIPPINES FIRST JUDICIAL REGION MUNICIPAL TRIAL COURT Lingayen, Pangasinan REKLAMADOR Plaintiff, Versus Civil Case No. _______ For: Forcible Entry

NIREREKLAMO Defendant. X - - - - - - - - - - - - -x COMPLAINT COMES NOW the Plaintiff in the above entitled case, through counsel, and to this Honorable Court alleges: I. That the plaintiff is of legal age and a resident of # 350 Reyes St. Quezon City; that the defendant is likewise of legal age, residing at # 25 Sct. Albano St. Quezon City and may be served with summons at said address; II. That the plaintiff had been in the lawful and peaceful possession of a house and lot situated at # 544 Gumamela St. Quezon City being the owner thereof, since October 21, 1988 until the day and incident in the following paragraph hereof;

III. That on or about June 1, 2001, by means of force, strategy and stealth, unlawfully entered said house ejecting BANTAY who, for and in behalf of plaintiff, was staying in and looking after the house, thereby illegally depriving plaintiff of the possession of the premises; IV. That since the day mentioned in the preceding paragraph, defendants have remained in illegal possession of the said premises and, up to the present, still retain such possession thereof; V. That the reasonable rental value of said premises is EIGHTEEN THOUSAND PESOS (Php 18,000.00) a month; VI. As a result, plaintiff was constrained to institute this case, including in the process obligations for litigation expenses and attorneys fees in the amount of _______. PRAYER WHEREFORE, it is most respectfully prayed that judgment be rendered in favor of plaintiff and against defendants: 1. Ordering the latter to vacate premises in question and to restore the possession thereof to plaintiff; 1. Ordering the defendants to pay plaintiff P80.00 a month, from the time of forcible entry to the time possession is returned to plaintiff; 2. Other just and equitable relief are also prayed for.

Quezon City, Philippines, August, 24, 2001. Atty. WALANG KWENTA Attorney for Plaintiff ____________________ Address IBP #_________1/2/2001; Pasig City PTR#_______2/2/2001;Pasig City 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. c.

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. 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 _______________ Plaintiff JURAT

SUBSCRIBED AND SWORN to before me, in the City/Municipality of _____________, this ________________day of ____________, 20____, by ______________ with Community Tax Certificate No. _________ issued at __________ on _______________, 20______.

Doc. No. Page Book Series of 2001

; ; ; .

NOTARY PUBLIC Until Dec. 31, 20______ IBP#________1/2/2001;Pasig City PTR#_______2/2/2001;Pasig City

XYZ Plaintiff, -versusABC Defendant. x---------------------------x

REPUBLIC OF THE PHILIPPINES FIRST JUDICIAL REGION MUNICIPAL TRIAL COURT Lingayen, Pangasinan CIVIL CASE NO. _______________ For: Unlawful Detainer

COMPLAINT COMES NOW the Plaintiff in the above entitled case, through counsel, and to this Honorable Court alleges; I That the plaintiff is of legal age and a resident of the City of Manila; that defendant is likewise of legal age, residing at No. 2 Cruz Street, Manila and may be served with summons at said address; II That defendant on January 7, 2001, leased from the plaintiff the premises located at No. 7 Cruz Street, Manila, agreeing to pay monthly rental of P 1, 000.00 III However, defendant failed to pay the aforesaid monthly rentals on their due dates, such that as of the date hereof, his arrearages have accumulated up to P_____________; IV That on March 7, 2001, demands was made on defendant to pay his rental in arrears and vacate the premises, but despite said demands, written and oral, defendant failed and refused to pay the rentals in arrears and vacate the premises leased by him;

V As a result, plaintiff was constrained to institute this case, incurring in the process obligations for litigation expenses and attorneys fees in the amount of _______________ PRAYER WHEREFORE, it is respectfully prayed that judgment be rendered against the defendant ordering him: 4. 5. 6. To vacate the premises leased by him; To pay the monthly sum of P1, 000.00 beginning with the month of __________, 2001, with interest thereon at the legal rate until fully paid until the defendant vacates said premises; To pay the sum of P_________ as litigation expenses and attorneys fees.

Plaintiff further prays for such other relief as this Court may deem just and equitable. Manila, Philippines, May 1, 2001. DEFG Attorney for the Plaintiff _________________________________ Address P.T.R. No._______ Date & Place of Issue_____ IBP O.R. No._____ Date & Place of Issue_____ 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. b. c. 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. 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. 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 _______________________ Plaintiff

JURAT SUBSCRIBED AND SWORN to before me, in the City/Municipality of _____________, this ________________day of ____________, 20____, by ______________ with Community Tax Certificate No. _________ issued at __________ on _______________, 20______.

Doc. No. Page Book Series of 2001

; ; ; .

NOTARY PUBLIC Until Dec. 31, 20______ IBP#________1/2/2001;Pasig City PTR#_______2/2/2001;Pasig City

COMPLAINT NOW COMES plaintiff to this Honorable Court and for cause of action against the defendant, respectfully alleges: That on March 6, 1988, defendant executed a promissory note (Annex A hereof) in favor of the plaintiff in terms and conditions as follows: (COPY) That to secure the payment of the said promissory note, defendant executed on March 1, 1988 a Deed of Mortgage in favor of plaintiff over a parcel of land whose technical description is as follows: (COPY DESCRIPTION) Copy of said Deed of Mortgage is attached hereto, marked annex B and made as integral part of this complaint; That said mortgage was registered with the Office of the Registrar of Deeds of Quezon City on March 2, 1988; mands; That payment of said promissory note is long overdue and defendant has failed to pay the same despite repeated deWHEREFORE, it is respectfully prayed that judgment be issued in favor of the plaintiff, ordering the defendant to pay: 1. 2. The principal sum of P50,000.00 until fully paid; That the aforementioned parcel of land be sold at a public auction should the defendant fail to pay the sums set forth in this complaint and apply the proceeds thereof in accordance with the dispositions of law.

DEFG Attorney for the Plaintiff ________________________________________ Address P.T.R. No._______ Date & Place of Issue_____ IBP O.R. No._____ Date & Place of Issue_____ VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING _______________________ Plaintiff JURAT