I.

JUDICIAL AFFIDAVIT
Republic of the Philippines
REGIONAL TRIAL COURT
National Capital Judicial Region
Branch ________
___________ City

IN THE MATTER OF THE ADOPTION OF _____________________________

Case No. ______________________

ANNE LORRAINE CO y PONGOS,

Petitioner.
x------------------------------------------x

JUDICIAL AFFIDAVIT OF ANNE LORRAINE CO y PONGOS

I, ___________________, of legal age, married, and living at ___________________, petitioner in this case, state under
oath as follows:

PRELIMINARY STATEMENT

The person examining me is Atty. __________________________________________ with address at

________________________________________________. The examination is being held at the same address. I am answering
his questions fully conscious that I do so under oath and may face criminal liability for false testimony and perjury.

The judicial affidavit of petitioner Anne Lorraine Co y Pongos is executed to serve as her direct testimony in the instant
case. This judicial affidavit is offered to prove the following:

(1) Petitioner Anne Lorraine Co y Pongos has all the qualifications and all the requirements to adopt
___________________________________________, a minor; and
(2) Minor ___________________________________________ may be adopted as provided by law.

It is respectfully prayed that the Honorable Tribunal admit this Judicial Affidavit of Anne Lorraine Co y Pongos as the
Direct Examination of the petitioner in order to expedite the proceedings.

QUESTIONS were propounded by petitioner’s counsel, Atty. __________________________,

in English, which the petitioner fully understands, while ANSWERS were given/made by petitioner Anne Lorraine Co y Pongos in
English/Tagalog and the corresponding translation of her answer is provided after each question.

1) Question (Q) Please state your name and other personal circumstances for the record.
Answer (A) I am Anne Lorraine Co y Pongos, __________ years old, a resident of _____________________________ _,
single and a businesswoman. I am a Filipino citizen.

2) Q What is your business?

I have a plastic factory in Valenzuela City and a dormitory in Sampaloc, Manila.

3) Q Do you have any proof that you really own a factory and a dormitory?

A Yes, ma’am! I have all the pertinent documents (Exhibit “A”).

4) Q Are you the same Anne Lorraine Co y Pongo, the petitioner in this case?
A Yes, ma’am!

5) Q Have you been convicted of any crime?

A No, ma’am!

6) Q Do you have a child?

A None!

1
7) Q Have you undergone pre-adoption services?
A Yes, ma’am!

8) Q Do you have any proof that you really have undergone pre-adoption services?
A Yes, ma’am (Exhibit “B”).

9) Q Do you think you are in a good position to provide for all the needs of the
child you want to adopt, to support, educate and care for the child to be
adopted?
A Yes, ma’am!

10) Q Why or how?

A As a businesswoman, I earn more than three hundred seventy five thousand
pesos (₱375,000.00) a month. That is a net, not gross.

11) Q Why do you want to adopt a child?

A Because I am single and I cannot have a fetus in my womb since I am not in a romantic relationship.
Still, I want to become a mother, a real and genuine mother. I want to love a child and be loved by my
child.

12) Q Who is the child that you want to adopt? State her other personal circumstances for the record.
A Her name is __________________________________, _________ years old and she is currently
under the care of CHILDREN’S SHELTER OF CEBU. Her biological parents are both Filipinos and both
residents of Cebu.

13) Q When, how and when did you meet _________________________________________ ?

A I met her last year, August 29th, 2015, when I and my cousins had vacation in
Cebu from August 18th, 2015 to September 5th, 2015. One of my cousins asked
us to go with her in CHILDREN’S SHELTER OF CEBU. My cousin was at the
fence of deciding to adopt a child. There, I saw
_____________________________________________ and was introduced to her by one
of the staffs of CHILDREN’S SHELTER OF CEBU.
14) Q Why is she in CHILDREN’S SHELTER OF CEBU? Where are her parents?
A. According to one of the staffs of CHILDREN’S SHELTER OF CEBU who introduced me to
__________________________________ whose name I cannot remember.
_________________________________ was brought into CHILDREN’S SHELTER OF CEBU by her biological
parents because her biological parents could not afford to raise her and give or provide her needs as they
only do laundry for the others for their living and her father could not find a good and stable job because
of his serious illness which I do not know. Thus, they decided to bring ______________________ into
CHILDREN’S SHELTER OF CEBU.

15) Q Have you met her biological parents?

A Not yet!
16) Q Do you have any idea if she is available for adoption?
A Yes! She has been declared, judicially, available for adoption (Exhibit “C”).

17) Q What is the age of _______________________________________ again?

A ________ years old.
18) Q How did you know?
A I asked the staff who introduced me to her and I also asked her. The said staff
also showed me the Certificate of Live Birth of__________________________ (Exhibit “D”).

19) Q Do you have documents necessary to adopt a child?

A Yes, ma’am! I have (Exhibits “C”, “C-1” to “C-8”).

IN WITNESS WHEREOF, I have hereunto set my hand this _______ day of _________________ 20______ in the City of
___________________________, Philippines.

2
 ANNE LORRAINE CO y PONGOS
Affiant

SUBSCRIBED and sworn to before me, this _______ day of _________________ 20______ in the City of
___________________________, Philippines. I hereby certify that I have personally examined the affiant and that I am
convinced that she understood and voluntarily executed the Judicial Affidavit.

Copy furnished:
THE CLERK OF COURT
(Address)

ATTESTATION

I, Atty. _______________________, of legal age, single and a resident of ________________________, after having
been duly sworn to in accordance with law, hereby depose and state that:

1) I am the counsel of ANNE LORRAINE CO y PONGOS in Case No. _________________________;

2) I faithfully recorded or caused to be recorded the questions I asked and the corresponding answers that the witness
gave for her Judicial Affidavit; and

3) Neither I nor any other person then present or assisting her coached the affiant regarding the latter’s answers.

IN WITNESS WHEREOF, I have hereunto set my hand this _______ day of _________________ 20______ in the City of
___________________________, Philippines.

ATTY. ______________________________
Affiant

SUBSCRIBE and sworn to before me, this _______ day of _________________ 20______ in the City of _____________
by Atty. _____________________________________ with Passport No.____________, issued on
_______________________ at ______________________.

Doc No. _____ Atty. _________________

Page No. _____ Notary Public
Book No. ______ Commission Serial No. _____________
Series of 2018 ______ Until December 31, 2019
Roll of Attorney No. __________
IBP No. _______________/ Nov. 25, 2014/ Manila
PTR No. _____________/ Jan. 3, 2018/ Manila

3
II. MOTION TO REDUCE BAIL
Republic of the Philippines
REGIONAL TRIAL COURT
National Capital Judicial Region
Branch ________
___________ City

THE PEOPE OF THE PHILIPPINES CRIMINAL CASE NO. ______________________

Complainant, FOR: ESTAFA
-versus-

NAME OF ACCUSED
Accused.
x-------------------------------x
MOTION TO REDUCE BAIL

UNTO THIS HONORABLE COURT, Accused, through counsel, most respectfully aver:

1. That Accused is presently detained at Police Station, ________ City, pending the hearing of this case, and that
this case has been raffled to this sala;

2. That the Resolution of the Honorable Office of the City Prosecutor has fixed the bail of the accused at
P20,000.00;

3. That the recommended bail for the offense of Estafa is P6,000.00, in accordance with the 2000 Bail Bond Guide
of the Department of Justice National Prosecution Service;

4. That accused is not affluent in life, being a mere employee with minimum wage;

5. That the bail recommended is tantamount to the denial of bail. Where the right to bail exists, it should not be
rendered nugatory by requiring a sum that is so excessive.

6. That accused is asking for the reduction of bail to P 10,000, which amount the accused can raise;

7. That accused is a good member of the community, and a resident of Davao City, and the probability of flight is
nil;

8. That accused has not been previously convicted of any crime and have no pending case in any judicial or quasi-
judicial body in the Philippines.

9. That accused will undertake to be present when this case is called in Court.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed that the Honorable Court will allow accused to post
bail in the amount of P 10,000.00 for his provisional liberty during the pendency of this case.

Davao City, Philippines, _____________.

By:

ATTY. ____________________________
Counsel for the accused

4
 NOTICE OF HEARING

THE CITY PROSECUTOR

City Prosecution Office
________________________
________________________

THE CLERK OF COURT

COURT
BRANCH __
CITY

Greetings:

Please submit the foregoing Motion for the consideration and approval of this Honorable Office on ________________
at __________o’clock in the morning or as soon as this may be heard.

ATTY. ______________________

5
III. SPECIAL POWER OF ATTORNEY- TO APPEAR IN COURT
SPECIAL POWER OF ATTORNEY – TO APPEAR IN COURT

KNOW ALL MEN BY THESE PRESENTS:

I, _______________________, of legal age, Canadian National, widow, resident of 3483-156th Street, South Surrey, do
hereby name, constitute and appoint ATTY. MAE ELAINE T. BATHAN and/or BATHAN ASSOCIATES Law firm, to be my true and
lawful attorney-in-fact, for me and in my name, place and stead, to do and perform the following acts and things to wit:

1. To represent me before Regional Trial Court of Balayan Batangas, its agencies and subsidiaries in relation to
the case for Partition and/or Termination of Co-ownership docketed as Civil Case No. 4617-A;

2. To file the necessary Special Proceeding case for the allowance of the Last Will and Testament, executed by my
late husband, __________________ which was Probated and Allowed in the courts of British Columbia, Canada;

3. To file any civil, criminal or administrative case against Modesto Villarivera Rubio for accounting, payment,
specific performance, damages for failure to render accounting and turnover proceeds of the income of the property owned by
my late husband _____________________.;

4. To endorse, sign any and all pleadings where necessary including the Verification and Certification of Non-
Forum Shopping; To appear in my behalf in the above mentioned case pending and cases to be filed during the Pre-trial,
Mediation, Trial and all other proceedings relative to the aforesaid case; To submit evidence both testimonial and documentary,
where necessary; To sign and enter into stipulation of facts, amicable settlement, compromise agreement, submit to alternative
modes of dispute resolution, simplification of issues and to do any and all other acts necessary and advantageous to my case.

5. To receive the amount to be awarded lieu of my claim including damages and to sign receipt of such document
and thereafter turnover such amount to my account;

6. To transact, inquire with, negotiate, withdraw, deposit, request for statement of account, sign any and all
documents with Bank of the Philippine Islands Alabang Branch in my Savings Account No. ______________

7. To do any and all acts necessary so as to give full effect to the foregoing authorities stated.

HEREBY GIVING AND GRANTING unto said attorney-in-fact full power and authority requisite, necessary or proper to be
done in and about the premises as fully to all intents and purposes as I might or could lawfully do if personally present, and
hereby ratifying and confirming all that my said attorney-in-fact or her substitute shall lawfully do or cause to be done under and
by virtue of these presents.

IN WITNESS WHEREOF, I have hereunto set my hand this _____ day of December, 2008.

____________________
Principal

SIGNED IN THE PRESENCE OF:

________________________ ________________________

6
 ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES]

CITY OF CEBU ] S.S.

BEFORE ME, a Notary Public this _______ of December, 2008 at the City of Cebu, personally appeared AURORA SISON
MANZANO with her Passport No. ____________ issued on ________________ at _________; known to me the same person
who executed the foregoing Special Power of Attorney for which she acknowledge to be her personal voluntary act and deed.

WITNESS MY HAND AND SEAL on the and place first above written.

Doc No. _____ Atty. _________________

Page No. _____ Notary Public
Book No. ______ Commission Serial No. _____________
Series of 2018 ______ Until December 31, 2019
Roll of Attorney No. __________
IBP No. _______________/ Nov. 25, 2014/ Manila
PTR No. _____________/ Jan. 3, 2018/ Manila

7
IV. CHATTEL MORTGAGE
CHATTEL MORTGAGE

KNOW ALL MEN BY THESE PRESENTS:

I, (Name of Mortgagor) of legal age, single/married to____________________ with postal address at

_____________________________hereinafter known as the MORTGAGOR, and _________________________________ of
legal age, single/married to ______________________ with postal address at _______________________________ hereinafter
known as the MORTGAGEE, witnesseth:

That the MORTGAGOR is indebted unto the MORTGAGEE in the sum of (Amount in Words) (000,000.00), Philippine
Currency, receipt of which is acknowledged by the MORTGAGOR upon the signing of this instrument, payable within a period of
_____ years, with interest thereon at the rate of (___) % per annum;

That for, and consideration of , this indebtedness, and to assure the performance of said obligation to pay, the
MORTGAGOR hereby conveys by way of CHATTEL MORTGAGE unto the MORTGAGEE, his heirs and assigns, the following
personality now in the possession of said MORTGAGOR

MAKE : MOTOR NO. :

SERIES : SERIAL/CHASSIS NO. :
TYPE OF BODY : PLATE NO. :
YEAR MODEL : FILE NO. :

That the condition of this obligation is that should the MORTGAGOR perform the obligation to pay the hereinabove
cited indebtedness of (Amount in Words) (000,000.00) together with accrued interest thereon, thischattel mortgage shall at
once become null and void and of no effect whatsoever, otherwise, it shall remain in full force and effect.
IN WITNESS WHEREOF, the parties have hereunto set their hands, this ____day of ____________ 20___ at ____ Philippines.

_______________________________ _______________________________
MORTGAGOR MORTGAGEE

IN THE PRESENCE OF:

_______________________________ _______________________________

ACKNOWLEDGEMENT
Republic of the Philippines)
________________________ ) S.S

BEFORE ME, personally appeared:

Name Valid Identifying Instrument Date/Place Issued

(Name of Mortgagor) 10000000 Jan 01, __ / Quezon City

(Name of Mortgagee) 10000000 Jan 11, __ / Las Pinas City

Known to me and to me known to be the same persons who executed the foregoing instrument and acknowledged to me that
the same is their free and voluntary act and deed.

WITNESS MY HAND AND SEAL, on the date and place first above written.

Doc No. _____ Atty. _________________

Page No. _____ Notary Public
Book No. ______ Commission Serial No. _____________
Series of 2018 ______ Until December 31, 2019
Roll of Attorney No. __________
IBP No. _______________/ Nov. 25, 2014/ Manila
PTR No. _____________/ Jan. 3, 2018/ Manila

8
 AFFIDAVIT OF GOOD FAITH

We, the undersigned MORTGAGOR AND MORTGAGEE hereby jointly and severally swear that we executed the
foregoing Chattel Mortgage in order to secure the indebtedness therein and for no other purpose or purposes contrary to law.

____________________________ _____________________________
MORTGAGOR MORTGAGEE

9
V. AFFIDAVIT-COMPLAINT
REPUBLIC OF THE PHILIPPINES )
QUEZON CITY, METRO MANILA ) S.S.
x---------------------------------------x

AFFIDAVIT-COMPLAINT

I, BRYAN VALDERAMA EGUIA, of legal age, Filipino and a resident of B168 L48 PII Mabuhay City, Mamatid Cabuyao
Laguna, after having been sworn to in accordance with law hereby depose and state:

1. That am accusing MR. KEVIN RABAGO a resident of ______________ of THEFT.

2. That on January 23, 2017, I was resting at our office’s lounge and eventually slept;

3. That on that same date, when I woke up, I realized that I had lost my Xperia X-Performance Black 64g, (herein
after referred to as “Cellular Phone”) phone which I had placed at the end-side portion of the double deck bed where I
rested and slept;

4. As standard procedure, I verbally reported the incident to my team manager, and Operations Manager and
they promised to look into it;

5. February 7, 2017, a friend of mine, MARY GRACE JOYA noticed that our co-worker, KEVIN RABAGO had a new
phone which was very similar to the one I lost;

6. That on February 10, 2017 early in the morning, I confronted MRS. “JEN” RABAGO, the mother of respondent
KEVIN RABAGO, who was also a fellow co-worker about KEVIN RABAGO having possession of a stolen phone;

7. That on February 10, 2017 around 5:30am in the morning, KEVIN RABAGO went to our station and brought the
phone in his possession;

8. At this juncture, myself, MR. EDGARSON DELA CRUZ, my team leader and KEVIN RABAGO examined the IMEI
of the cellular phone to check its identity and verify if its IMEIs matches my lost phone’s IMEIs which are all indicated in
the (1) Warranty Receipt and (2) Product Box in my possession;

9. Upon checking the phone’s IMEIs, we found out that it was a complete match;

IMEI1: 358096072063585
IMEI2: 358096072063593

10. When we asked KEVIN RABAGO why he stole my cellular phone, he denied stealing the same, and argued that
he won the said phone in a computer tournament, furthermore he refused to return the cellular phone to me;

11. Respondent KEVIN RABAGO, despite my objection, asked us to allow to him to get the box and show proof that
he indeed won the said cellular phone in a contest, however he never returned nor did he show proof of his rightful
possession of my cellular phone;

12. Later on, he informed me that he had lost the cellular phone;

THEFT
Art. 308. Who are liable for theft. — Theft is committed by any person who, with intent to gain but without
violence against or intimidation of persons nor force upon things, shall take personal property of another
without the latter’s consent.

Theft is likewise committed by:

Any person who, having found lost property, shall fail to deliver the same to the local authorities or to its
owner;

13. That attached hereto as Annexes to prove the elements of the crime of theft:

10
 “A” – Warranty Receipt of the stolen phone indicating the name of the buyer and its respective IMEIs
(International Mobile Equipment Identity);

“B” – Sworn Affidavit of Team Leader EDGARSON DELA CRUZ, to prove and attest that the IMEI of cellular
phone in possession of KEVIN RABAGO matches the IMEI of the cellular phone I bought;

“C” - Signed statement of EDGARSON DELA CRUZ dated March 29, 2017;

“D” – Incident Report dated February 6, 2017 which I sent to our operations manager to report that a fellow
co-worker saw KEVIN RABAGO in possession of a cellular phone which was very similar to the one stolen from
me;

“E”- Photographs of the stolen phone;

“F” – Photographs of the Product Box, indicating the IMEIs of my cellular phone, to prove the phones unique
identity.

That I am executing this Complaint-Affidavit for the purpose of filing the complaint for THEFT against MR. KEVIN
RABAGO.

IN WITNESS WHEREOF, I have hereunto set my hand this ____day of April 2017, in Quezon City, Philippines.

BRYAN VALDERAMA EGUIA

Complainant/Affiant

SUBSCRIBED AND SWORN TO before me this _____ day of April, 2017, in Pasig City, Philippines, and hereby certify that I
have personally examined the Affiant and I am satisfied that he voluntarily executed and understood his complaint affidavit

Assistant City Prosecutor

11
VI. OTHER FORMS

Petition for Adoption

Republic of the Philippines

REGIONAL TRIAL COURT
Ninth Judicial Region
Branch 15
Zamboanga City

IN RE: IN THE MATTER OF ADOPTION OF MINOR MARLOU ROJAS AND CHANGE OF NAME TO CLIFFORD SANTIAGO

SPECIAL PROCEEDING
NO. 8977
SPS. ABRAHAM D. SANTIAGO and ESTER A. SANTIAGO,
Petitioners.
x--------------------------------------------------------------x

PETITION

COMES, NOW, THE PETITIONERS, thru their counsel, and unto this Honorable Court, most respectfully allege the
following, to wit:

1. That petitioners are both of legal age, Filipinos, married to each other, and residents of #54 Lacandalo Drive, Sta.
Maria, Zamboanga City;

2. That they desire to adopt the minor child named MARLOU ROJAS, who is male, three years of age, Filipino, and
likewise residing at #54 Lacandalo Drive, Sta. Maria, Zamboanga City;

3. That herein subject minor, was born at Zamboanga City Medical Center on December 5, 2012 to MARILOU ROJAS,
unmarried, which proof of birth was duly registered in the Register of Births of the Office of the Civil Registrar of
Zamboanga City, for which a Certificate of Live Birth was issued. A machine copy of it is herewith attached as Annex
“A”;

4. That the minor child was admitted to the proper care and custody of the Department of Social Welfare and
Development (DSWD for brevity) by his biological mother together with referring social worker, SARAH LIM of DWSD-
Crisis Intervention Unit located in Sta. Barbara, Zamboanga City on December 8, 2012. Subject child was referred to
their office by the Medical Social Worker of Zamboanga City Medical Center (ZCMC for brevity) after being initially
assessed that the mother cannot support the child with all his needs due to economic and health reasons;

5. That MARLOU was only 2 days old when he was brought for admission at the center. He was born through normal
delivery and assisted by DR. PIA CENTENO, Medical Officer III of Zamboanga City Medical Center;

6. That during the interview of the child’s mother, it was found that the subject child’s mother worked as a Guest
Relation Officer (GRO) in Fantacy KTV bar along MCLL Highway, Guiwan, this city, and his father could not be identified.
No further details regarding his family background was established due to the mother’s inconsistent answers to the
questions. Moreover, the referring social worker, MS. SARAH LIM worked out to submit child’s mother for assessment
by psychiatrist but the mother refused as she insisted to be mentally stable and healthy. Per collateral review on the
given address, it was found that the mother has several men whom she does not want to identify. She has no relative
living in the city.

7. That during the child’s admission in the center, the mother, was informed of the placement status of the child and
the center’s programs and services. She was also advised to come and visit her son to determine her readiness to
assume the role of parenting. Unfortunately, the mother failed to fulfill such agreement. In fact, it was her first and last
visit to her child has been deprived of the love, care and attention from his biological mother since he was two (2) days
old up to the present;

8. That as per Child Study report, the DSWD has evaluated and recommended that the minor child can be legally
adopted to spouses ABRAHAM D. SANTIAGO and ESTER A. SANTIAGO for the child’s best interest and welfare. A copy of
said DSWD Child Study Report is herein attached as Annex “B”;

12
 9. THAT, MOREOVER, Petitioner is qualified to adopt the minor child above-named under Articles 183-186 of the Family
Code of the Philippines, as amended by the provisions of Republic Act No. 9552, the Domestic Adoption of 1998;

10. That, in addition, the adoptive applicants have been married since June 16, 2007 but they remain childless. The
spouses decided to foster a child to whom they can give their love, care and affection. On January 10, 2014, Marlou
Rojas from the Child Reception and Study Center for Children at Talon-Talon, this city, was placed under their custody
as foster child. Attached herewith is a copy of the spouses’ Marriage Contract as Annex “C”;

11. That the DSWD in fact made a Child Study Report on the case of the subject minor child and in that study report i.e.
social diagnosis the minor deprived of parental love and care. They maintained that it was the present custodian, who
unselfishly provided them love and the best opportunities to make the child fully accepted and loved by the family
resulting to a positive parent-child relationship;

12. That, on September 30, 2015, the subject minor was formally matched to Spouses ABRAHAM and ESTER SANTIAGO.
Last October 15, 2015, the corresponding AFFIDAVIT OF CONSENT TO ADOPTION by DSWD was issued and herein
attached and form part of the petition as Annex “D”;

13. That herein petitioners has the capability and ability to extend to said minor the kind of financial support that a
parent can give to his child. ABRAHAM SANTIAGO is an Accounts Officer in the Land Bank of the Philippines while the
wife ESTER is a pre-school teacher at Ateneo de Zamboanga University Grade School. Attached hereto are the
employment identification cards of petitioners as Annex “E” and “E-1”;

9. That it is for the best interest of said minor if they would be considered as child of herein petitioners because his
financial, spiritual, and emotional needs would be taken care of and his future would be safeguarded. In fact, the
couple owns a house located a safe neighborhood in Sta. Maria. They also hired a nanny to take care of the subject
minor while they are at work. Moreover, the mother of Abraham lives with the spouses who loves the child as much as
the spouses. With that, the DSWD, in its Home Study Report, has strongly evaluated and recommended that the
Honorable Court approve the adoption of minor Marlou Rojas to Spouse Abraham Santiago and Ester A. Santiago. A
copy of the Home Study Report is herein attached as Annex “F”;

10. That the spouses are of good character, has no derogatory record whatsoever can be attributed to them, are
emotionally and psychologically capable of caring for the child, are more than sixteen (16) years older that the subject
minor sought to be adopted, are in position to support and care said child in keeping with the means of the family.
Attached herewith are copies of their Police clearances as statements as Annexes “G” and “G-1”;

11. That, at present, the subject minor is now three (3) years old and has been with the petitioners for two (2) years
now. He has adjusted well in the atmosphere and environment of his foster family. He is observed to be an active,
healthy, sociable and affectionate child. Generally speaking, his total growth and development is within the normal
level which could be attributed to the positive, alternative, and stimulating activities given by the foster family.

12. That the minor sought to be adopted does not own any real, personal, tangible and intangible property; and

13. That this adoption is for the best interest and security of the said minor if he would be considered as true and legal
child of herein petitioners and it will make his life normal, productive, and good persons in the community;

PRAYER
WHEREFORE, premises considered, it is respectfully prayed of this Honorable Court to grant this petition of Spouses
Abraham and Ester Santiago for the adoption of Marlou Rojas and for the change of the child’s name to Clifford A. Santiago.

Such other reliefs which the Honorable Court may deem just and equitable under the premises are likewise prayed for.

RESPECTFULLY SUBMITTED.

City of Zamboanga, Philippines, January 7, 2016.

FATIMA SARPINA P. HINAY

Counsel for the Petitioners
MP Tower, Buenavista St.
Zamboanga City
ROLL NO. 87221 5-16-10
IBP NO. 896989 1-04-16
PTR No. 0927798 1-04-

13
(Republic of the Philippines)
(City of Zamboanga ) S.S.
X- - - - - - - - - - - - - - - - - - - - - - - )

VERIFICATION AND CERTIFICATION

We, Spouses ABRAHAM D. SANTIAGO and ESTER A. SANTIAGO, both of legal age, Filipino citizens, and residents of #54
Lacandalo Drive, Sta. Maria, Zamboanga City, under oath, depose and state:

1. That we are the Petitioners in the above-mentioned case;

2. That we have caused the preparation of this Petition;
3. That we have read and understood its contents and affirm that they are true and correct to our personal knowledge
and based on authentic records; and,
4. That we hereby certify that there is no other case or special proceeding commenced or pending before any court
involving the same parties and the same issue and that should we learn of such a case or special proceeding, we shall
notify the court within five (5) days from our notice.

IN WITNESS WHEREOF, we have signed this instrument on the 7th day of January 2016, in the City of Zamboanga,
Philippines.
ABRAHAM D. SANTIAGO ESTER A. SANTIAGO
Affiant Affiant

SUBSCRIBED AND SWORN to before me this 7th day of January 2016, in the City of Zamboanga, Philippines.

Doc No. _____ Atty. _________________

Page No. _____ Notary Public
Book No. ______ Commission Serial No. _____________
Series of 2018 ______ Until December 31, 2019
Roll of Attorney No. __________
IBP No. _______________/ Nov. 25, 2014/ Manila
PTR No. _____________/ Jan. 3, 2018/ Manila

14
 Urgent Petition for Bail

Republic of the Philippines

6th Judicial Region
REGIONAL TRIAL COURT
Branch 57-San Carlos City

PETITION FOR BAIL OF: SP Proc. No. __________

REYNATO BULFA y Caburnay,

JESSICA PARCON y Magno,
JEROME PARCON y Magno,
JUDITH GENON y Sortigosa,
JOSEPH MAGNO y Carbaquel,
RAYMUNDA SALINAS y Mancao,
RONEL LOQUE y Razon,
JECTOPHER MADERAZO y Cataluña,
YOLANDO ESOGAN y Librando,
GEGIE ESOGAN y Paran,
JOEL JUNSAY y Balasoto,
CHRICEMAR GENON Y Sortigosa,
Petitioners
x------------------------------------------x

URGENT PETITION FOR BAIL

COMES NOW, the Petitioners, through the undersigned counsel, unto this Honorable Court, most respectfully states
that:

1. Records of the San Carlos City Police Station shows that in December 4, 2014, on or about 3:30 o’clock in the
morning, by virtue of a search warrant issued by Presiding Judge of RTC Branch 49 of Bacolod City, herein Petitioners
were apprehended by the elements of SOG NOPPO and NOPSC, ANNEX “A”;

2. That herein Petitioners were immediately placed under the custody of the San Carlos City PNP where they
continued to be detained as of this filing;

3. That as of the moment, no criminal complaint for alleged violation of PD 1602 was filed before the Office of
the City Prosecutor neither an Inquest Proceedings was ever conducted. In short, there is no case that is filed yet before
the Office of the City Prosecutor and or the proper court in connection with the case;

4. The Petitioners are pleading the indulgence of this Honorable Court for the allowance of BAIL pending the
inquest proceedings and filing of the proper information against the Petitioners in court by the San Carlos City
Prosecutor’s Office pursuant to Paragraph (c), Section 17 of the Revised Rules on Criminal Procedure which provides:

“(c) Any person in custody who is not yet charged in court may apply for bail with any court in the province,
city or municipality where he is held”

5. The Petitioners are heads of their respective families and on account of the impending landfall of another
super typhoon “Ruby”, they need to be released immediately to secure their respective families against the apparent
natural calamity;

6. That Petitioners faithfully undertake to submit themselves to the court or any government authorities
whenever their presence is required or necessary in connection with the instant case;

7. That the instant case is “BAILABLE” in nature thus Petitioners are qualified to apply for bail considering that
the main purpose for bail is to guarantee the appearance of the accused at the trial, or whenever so required by the
court (Yap, Jr. vs. CA, 358 SCRA 564);

8. That considering that no information was yet filed by the City Prosecutor’s Office of San Carlos City, there is a
need for this Honorable Court to fix the amount of bail bond for each of the Petitioner on account of the crime by
which they were apprehended;

15
 9. That this instant Petition is not intended to delay proceedings of this case but for reasons above stated
particularly for humanitarian reasons;

PRAYER

WHEREFORE, PREMISES CONSIDERED, it is most respectfully prayed the following:

1. That the instant Petition be GRANTED and an Order be issued fixing the bail of the herein Petitioners in
accordance with the bail bond guide pending the filing of the proper Information in Court;

2. Issue an Order directing the Station Commander of San Carlos City Police Station, San Carlos City, Negros
Occidental and/or any authorities concerned, who are in ACTUAL CUSTODY of the Petitioners to IMMEDIATELY RELEASE
them upon posting of the bond fixed by this Honorable Court, unless they are detained for some other legal charge or
charges.

Other relief and remedies that are just and proper under the circumstances are likewise prayed for.

RESPECTFULLY SUBMITTED.

Bacolod City, Philippines, December 4, 2014.

MALUNES, MAMPANG & MONTORO

LAW OFFICE
Counsel for the Petitioners
Room 202, Park Lane Building,
Hilado-Tindalo Ave., Bacolod City

BY:
ARIEL I. MALUNES
IBP Roll No. 51729
IBP No. 929358 - 01/6/14, Bacolod City
PTR No. 625612, 1/15/14- E.B. Magalona, Neg. Occ.
MCLE Compliance No. IV- 0022885

cc. San Carlos City

PNP

NOTICE OF HEARING

The Clerk of Court

RTC Branch 57, San Carlos City

San Carlos City PNP

Negros Occidental

Greetings!

Due to urgency, kindly set the foregoing petition for bail for the consideration and approval of this Honorable Court
immediately upon receipt hereof, without oral argument.

Thank you.

ARIEL I. MALUNES

16
 Affidavit of Desistance

Republic of the Philippines

Department of Justice
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
________________ City

AFFIDAVIT OF DESISTANCE

I, Anne Lorraine Pongos Co, of legal age, Filipino, single and a resident of __________________________
_________________________________________________, after having been duly sworn to in accordance with law, depose
and state THAT:

1. I am the private complainant in a criminal case for Reckless Imprudence Resulting to Damage to Property
against ______________________________________________________ docketed as IS No.
_________________________________ before the Office of the City Prosecutor, (City/Municipality and Province);

2. In this regard, the accused has already paid the damage to our vehicle;

3. In view of the payment by the accused and considering that I was not injured, I would like to manifest that I
now completely and absolutely exonerate the accused from any liability in connection with the above-mentioned
criminal case and that I am no longer interested, and I hereby desist, in prosecuting the said criminal case;

4. As such, I respectfully pray that the aforementioned case against ___________________ be

withdrawn and/or dismissed.

IN WITNESS WHEREOF, I have hereunto set my hand this _______ day of _________________ 20______ in the City of
___________________________, Philippines.

ANNE LORRAINE PONGOS

Affiant

SUBSCRIBE and sworn to before me, this _______ day of _________________ 20______ in the City of _____________
by Atty. _____________________________________ with Passport No.____________, issued on
_______________________ at ______________________.

Doc No. _____ Atty. _________________

Page No. _____ Notary Public
Book No. ______ Commission Serial No. _____________
Series of 2018 ______ Until December 31, 2019
Roll of Attorney No. __________
IBP No. _______________/ Nov. 25, 2014/ Manila
PTR No. _____________/ Jan. 3, 2018/ Manila

17
 Information

REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
6th JUDICIAL REGION
BRANCH______, ILOILO CITY

PEOPLE OF THE PHILIPPINES,

-versus – IMINAL CASE NO. 10-1236

MELISSA L. DATUYON, For: QUALIFIED THEFT

Accused
X ------------------------------------------------ X

INFORMATION

The undersigned accuses MELISSA L. DATUYON of the crime of the THEFT, committed as follows:

That on or about September 21, 2013 in the City of Iloilo, within the jurisdiction of this court, the accused did, then and
there, willfully, unlawfully, feloniously, with intent of gain and without the consent of the owner thereof, take, steal, and carry
away the following personal property belonging to one, GARLIT O. PEREZ to wit: MITZUBISHI LANCER 2011 MODEL, of the total
value of 600,000, Philippine currency:

CONTRARY TO LAW.

MARVIN H. TALEON II
Assistant City Prosecutor

CERTIFICATION AS TO CONDUCT OF INQUEST

I hereby certify that the accused was lawfully arrested without a warrant and that, upon being informed of his rights,
refused to waive the provisions of Article 125 of the Revised penal Code and, for this reason, an Inquest was conducted; that
based on the complaint and the evidence presented before me without any countervailing evidence submitted by the accused,
despite opportunity to do so, there is reasonable ground to believe that the accused has committed the crime of theft and
should thus, be held for said crime; that this Information was with prior authority of the City Prosecutor.

MARVIN H. TALEON II
Assistant City Prosecutor

SUBSCRIBED AND SWORN TO BEFORE ME this 22nd day of September 2013 in Iloilo City.

JOMMEL Q. ALERTA
City Prosecutor

No Bail recommended

18
 Special Power of Attorney

SPECIAL POWER OF ATTORNEY

KNOW ALL MEN BY THESE PRESENTS:

WE, _________, of legal age, Filipino, married, a resident of_______________, Philippines, do by this presents hereby
name, constitute and appoint_______________, likewise of legal age, Filipino, married, a resident of, _____________City to be
my true and lawful Attorney-in-fact, for me and in my name, place and stead, and for my own use and benefit, to do and
perform all or any of the following acts and things, to wit:

1. To purchase a parcel of land located in Brgy. Pasil with TCT. No 1234;

2. To sign the Deed of Absolute Sale and other pertinent document relative to the purchase of the
abovementioned property;

3. To perform all other acts necessary to carry out the above purpose and to administer my property in my
behalf.

HEREBY GIVING AND GRANTING unto my said Attorney-in-fact full power and authority to do and perform all and every
act and thing whatsoever requisite and necessary to be done in and about the premises, hereby ratifying and confirming all that
my said Attorney-in-fact shall lawfully do and cause to be done by virtue of these presents.

IN WITNESS WHEREOF, I have hereunto affixed my signature this ______ of ____________, 200_ at Cebu City,
Philippines.

__________________
Grantor/Principal

With my conformity:

___________________
Grantee/Agent

SIGNED IN THE PRESENCE OF:

____________________________ ____________________________

REPUBLIC OF THE PHILIPPINES)

CITY OF CEBU) S.S.

ACKNOWLEDGMENT

BEFORE ME, Notary Public in and for the City aforesaid this ___ of _______, 200__personally appeared
_____________with Passport No. ___________ issued on _________________ at _____________________, evidencing
competent identity of the person executing this instrument and which she is known to me and to me known to be the same
person who signed and executed the foregoing instrument and acknowledged to me that the same is his own free and voluntary
act and deed.

WITNESS MY HAND AND NOTARIAL SEAL on the date and place first above-written.

Doc No. _____ Atty. _________________

Page No. _____ Notary Public
Book No. ______ Commission Serial No. _____________
Series of 2018 ______ Until December 31, 2019
Roll of Attorney No. __________
IBP No. _______________/ Nov. 25, 2014/ Manila
PTR No. _____________/ Jan. 3, 2018/ Manila

19
 Motion for Bill of Particulars

Republic of the Philippines

National Capital Judicial Region
METROPOLITAN TRIAL COURT
Quezon City, Branch 32

Alabaster Graves,
Plaintiff-Appellant, Criminal Case No. 01-975413
- versus -

Richter Belmont,
Defendant-Appellee,
x-----------------x

MOTION FOR BILL OF PARTICULARS

Defendant, through the undersigned counsel and unto this Honorable Court, respectfully avers:

1. That the plaintiff's complaint in paragraph 5 alleges:

"From August 3 to December 2013, defendant never paid anything to herein plaintiff. The check that
he issued as partial payment for the first month also bounced. x x x"; (underscoring supplied)

2. The said allegation is not averred with sufficient definiteness and particularity, specifically it does not mention
the amount of the check therein mentioned, its check number, date, and the drawee bank;

3. That a more definite statement on the matters as above-indicated is necessary in order to enable the
defendant to prepare its responsive pleading because from the very onset of this controversy, the main dispute was on
what was actually and exactly agreed upon by the parties as the amount of monthly rentals on the lease of plaintiff's
property;

4. However, due to the fact that defendant corporation had to transfer its liaison offices depending on its project
sites, the check stub where the above-mentioned check came from was probably misplaced and could no longer be
found;

5. That a bill of particulars or a more definite statement as to particulars of the said check which was allegedly
issued by the defendants as partial payment for the first month would definitely simplify the issues in this case, and
hopefully simplify the negotiations between the parties for an amicable settlement.

PRAYER

WHEREFORE, defendant most respectfully prays that an order be issued by this Honorable Court requiring the plaintiff
to make more definite statement as to the particulars of the check mentioned in paragraph 5 of his complaint, particularly
stating its amount, check number, date, and the name of the drawee bank.

Quezon City, Philippines, January 23, 2014

ATTY. ROMMELITO FRANCISCO MACARAYO

counsel for the defendant
13-69 Barracks Building, Marikina
IBP NO. 87123-7/19/12-AC
PTR NO. 669913/21/12-AC
Roll No. 99998
MCLE Exempt
(Admitted to the bar: April 6, 2012)

20
 NOTICE OF HEARING

Atty. Ezekiel Razon

Counsel for the Plaintiff
12-26 Marina Arcade, Mabalacat City

Greetings! Please take notice that the foregoing Motion for Bill of Particulars shall be submitted for the consideration
and approval of the Honorable Court on Friday, January 24, at 10:00 AM or as soon as counsel and matter may be heard.

Atty. Rommelito Francisco Macarayo

EXPLANATION

The foregoing Motion for a Bill of Particulars is being filed with this Honorable Court and served on the opposing
counsel by registered mail in view of the impracticability of personal filing and service due to distance considering that the office
of this Honorable Court is at Quezon City and that of the opposing counsel is at Mabalacat City, while undersigned counsel holds
office in Marikina.

Atty. Rommelito Francisco Macarayo

COPY FURNISHED:

Atty. Ezekiel Razon

Counsel for the Plaintiff
12-26 Marina Arcade, Mabalacat City

21
 Motion for New Trial

Republic of the Philippines

National Capital Judicial Region
METROPOLITAN TRIAL COURT
Quezon City, Branch 32

Juan Dela Cruz,

Plaintiff,
-versus – Civil Case No. ______
For: Collection of Sum of Money
Juana Dela Cruz,
Defendant,
x------------------------------------------x

MOTION FOR NEW TRIAL

COMES NOW, the defendant, through counsel, respectfully that:

1. The judgment of this court in the above-entitled case was served on him on May 10, 2012, which was obtained by
plaintiff through FRAUD;

2. Since then, defendant, discovered new evidence, which he could not, with reasonable diligence have discovered and
produced at the trial and if considered would alter the outcome of the case;

3. The above-mentioned discovered evidence consists in the following, to wit two letters stating that the said obligation
has been paid including the interest set forth in the first promissory note signed;

4. That the affidavits of X and Y(and/or, the following documents) are attached hereto as Annexes “A”, “B”, etc., to
substantiate the aforementioned newly-discovered evidence;

5. That said newly-discovered evidence, if presented this case, would alter the result of the decision of the Honorable
Court.

WHEREFORE, defendant prays that the judgment in this case be set aside and a new trial be ordered for the reception
of the newly-discovered evidence mentioned above.

Other relief and remedies as may be deemed just and equitable under the premises are likewise prayed for.

Manila, May 16, 2012.

Atty. ABC
Counsel for the Defendant
36 P. Campa, Sta. Cruz, Manila
IBP No.: 12345/020506/Manila
PTR No.: 12345/020508/Manila
Roll No.: 12345
MCLE No. III – 0019263-01-10-10

NOTICE OF HEARING

To: ATTY. CDE

Counsel for the Plaintiff

GREETINGS!

Please submit the foregoing MOTION FOR NEW TRIAL for the consideration and approval of the Honorable Court on
May 20, 2012 at 9:00 in the morning.

ABC

22
 VERIFICATION

REPUBLIC OF THE PHILIPPINES )

CITY OF MANILA ) S. S.

I, Juana dela Cruz, of legal age, Filipino citizen, married, and resident of 12-B Marcelino St. Sta. Cruz, Manila, after
having been duly sworn to in accordance with law do hereby depose and say:

1. That I am the defendant in the above- entitled case;

2. That I have caused the preparation of the foregoing Motion for New Trial and have read the allegations contained
therein;
3. The allegations in the said complaint are true and correct of my own knowledge and authentic records.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 13th day of May, 2012, in the City of Manila.

Juana dela Cruz

SUBSCRIBED AND SWORN to before me this 13th day of May 2012, in the City of Manila, affiant exhibiting to me her
Driver’s License No.: 12345 issued at LTO, Manila on December 16, 2011.

Doc No. _____ Atty. _________________

Page No. _____ Notary Public
Book No. ______ Commission Serial No. _____________
Series of 2018 ______ Until December 31, 2019
Roll of Attorney No. __________
IBP No. _______________/ Nov. 25, 2014/ Manila
PTR No. _____________/ Jan. 3, 2018/ Manila

CC: Atty. CDE

Counsel of the Plaintiff
23 Hidalgo St. Sta. Cruz, Manila

EXPLANATION OF SERVICE

Copy of the MOTION FOR NEW TRIAL 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.

ABC

23
 Extra-Judicial Foreclosue of Real Mortgage

Republic of the Philippines

National Capital Judicial Region
METROPOLITAN TRIAL COURT
Office of the Clerk Sheriff & Ex-Officio Sheriff
Quezon City, Branch 32

Jan Kriezl M. Catipay FILE NO. 1234

Petitioner-Mortgagee, Extra-Judicial Foreclosure of Real Estate
Mortgage under Act No. 3135

(Petition for Extra Judicial Foreclosure of Real Estate Mortgage under Act 3135 as amended)

The City/Provincial Sheriff

City/Province of
_____________, Philippines

S I R:
GREETINGS:

Mortgagee _____________, of legal age, Filipino, (single / married / widow), and a resident of _____________,
Philippines, most respectfully alleges:

1. That on _____________, __Name of Mortgagor-Debtor__, of legal age, Filipino, (single / married / widow), and a
resident of _____________, Philippines, executed a Real Estate Mortgage in my favor mortgaging said property described in the
Real Estate Mortgage Contract hereto attached as Annex "A" and forming an integral part hereof; to secure the payment of loan
in the amount which is shown in the promissory note executed by said Mortgagor-Debtor dated _____________, a copy of
which is hereto attached as Annex "B"

2. That to the best of my knowledge, the mortgaged property is subject to no prior mortgage or any lien whatsoever
and is now in the possession and full control of the above-named Mortgagor-Debtor;

3.That the Mortgagor-Debtor defaulted in its obligation under the aforementioned Real Estate Mortgage Contract and
Promissory Note;

4.That under the terms and conditions of the Real Estate Mortgage Contract, the Mortgagee is entitled to foreclose
extra-judicially the mortgaged property, which is more particularly described as follows:

(Technical Description of Property)

5.That by the terms and conditions of the Real Estate Mortgage Contract herein-above referred to, the principal
obligation of the Mortgagor which has become overdue as of _____________ is in the amount of ________________________
(P___________), excluding penalties, liquidated damages, past due interest, attorney's fee representing ______% of the total
obligation due, other charges and expenses of foreclosure.

WHEREFORE, I respectfully request you to take possession of the property described in the aforementioned Real Estate
Mortgage and sell the same at Public Auction in accordance with the provisions of Act 3135 as amended. Please furnish the
undersigned and the Mortgagor-Debtor with copies of your notice of Sale at least ten (10) days before the sale.

_____________, Philippines, __Date__.

MORTGAGEE
(VERIFICATION)

24
 Republic of the Philippines
National Capital Judicial Region
METROPOLITAN TRIAL COURT
Quezon City, Branch 32

Juan Dela Cruz,

Plaintiff,
-versus – Civil Case No. ______
For: Collection of Sum of Money
Juana Dela Cruz,
Defendant,
x------------------------------------------x

25
NOTES:

Motion
What is a motion?
- Application of relief other than a petition
- Oral/written

1. Caption
2. Rule 15 Sections 4, 5, 6

SECTION 4. Hearing of motion. — Except for motions which the court may act upon without prejudicing the rights of the adverse
party, every written motion shall be set for hearing by the applicant. Every written motion required to be heard and the notice
of the hearing thereof shall be served in such a manner as to ensure its receipt by the other party at least three (3) days before
the date of hearing, unless the court for good cause sets the hearing on shorter notice. (4a) wmeLme

SECTION 5. Notice of hearing. — The notice of hearing shall be addressed to all parties concerned, and shall specify the time and
date of the hearing which must not be later than ten (10) days after the filing of the motion. (5a)

SECTION 6. Proof of service necessary. — No written motion set for hearing shall be acted upon by the court without proof of
service thereof.

3. Scheduled within 10 days

4. Adverse party to receive within 3 days before hearing

Two kinds of motion:

1. Litigated
2. Ex parte

Bill of Particulars
- Petition is vague and to clearly state the information

Motion for New Trial

- FAME with affidavit of meritorious defense

SPA
- Name, Appoint, Constituting
- Acknowledgment

SPA to appear in court

1. Rule 18 Section 4

SECTION 4. Appearance of parties. — It shall be the duty of the parties and their counsel to appear at the pre-trial. The non-
appearance of a party may be excused only if a valid cause is shown therefor or if a representative shall appear in his behalf fully
authorized in writing to enter into an amicable settlement, to submit to alternative modes of dispute resolution, and to enter
into stipulations or admissions of facts and of documents.
a. Amicable settlement
b. ADR
c. Stipulation / Admission of Facts / Docs
2. Acknowledgment

Chattel Mortgage
1. Conveys/Mortgages
2. Affidavit of Good Faith
3. Acknowledgment

Information
- Courts jurisdiction
- Always willfully, unlawfully and feloniously
- Always contrary to law
- Number of witnesses to be presented
- Recommended bail
- Depends on value of property (property, surety, cash bond)

26
Petition for Bail
- No bail fixed

Motion to reduce bail

- There is a fixed amount of bail
- State the good grounds:
o Financial capacity
o Health, age, sex of the accused
o Penalty less than 6 years
o Probability of flee and not attending trial

Affidavit of Desistance
- Same format as affidavit
- Affiant is client of the prosecution
- Not forced
- To whom: judge, prosecutor

Foreclosure of mortgage
- Material dates
- Documentary evidence (contracts of mortgage)

Rule 68. Section 1. Complaint in action for foreclosure.

In an action for the foreclosure of a mortgage or other encumbrance upon real estate, the complaint shall set forth
1. the date and due execution of the mortgage;
2. its assignments, if any;
3. the names and residences of the mortgagor and the mortgagee;
4. a description of the mortgaged property;
5. a statement of
a. the date of the note or other documentary evidence of the obligation secured by the mortgage,
b. the amount claimed to be unpaid thereon; and
c. the names and residences of all persons having or claiming an interest in the property subordinate in right to that of
the holder of the mortgage, all of whom shall be made defendants in the action.

Complaint for Theft

- Elements of theft under Article 308 of the RPC
(1) that there be taking of personal property;
(2) that said property belongs to another;
(3) that the taking be done with intent to gain;
(4) that the taking be done without the consent of the owner; and
(5) that the taking be accomplished without the use of violence against or intimidation of persons or force upon things.

- Affidavit format
- Jurat – notary public allowed but better if subscribed by the prosecutor

27