Republic of the Philippines Regional Trial Court Branch 89 Quezon City

LIBERTY AGUILAR, Plaintiff, -versus MARTIN ANONUEVO, Defendant. Civil Case No. Q-10-14344


MEMORANDUM DEFENDANT, Memorandum. by counsel, respectfully submit this

Preliminary Statement Defendant denies the allegations of the plaintiff, the truth of the matter that his indebtness to the plaintiff has already been paid fully on January 6, 2011 and that the plaintiff was tainted with ill motive in filing the complaint. Defendant now prays that the complaint be dismissed by the Honorable Court.

Statement of Facts 1. Martin Anonuevo borrowed money from Liberty Aguilar amounting to P500,000 for the hospitalization and medical expenses his his father. 2. Defendant executed a promissory note, in full confidence that he would be able to pay his indebtness to the plaintiff.

INC. INC. INC. On 11 April 2010. took the risk of such condition. (iii)Sleeping during working hours specifically on 22. administrative committee and state why he should not be subject to disciplinary action and / or termination of his employment with the same. YYY’s two week notice of resignation letter and replied that the same must comply with the thirty (30) day notice rule for resignation as stipulated under their contract. with due notice.000. and 2 to 3 p. to find a replacement for the said position when needed. 8.SSS. 9. defendant pleaded the plaintiff if he may be allowed to pay his balance in two other installments and plaintiff gave defendant up to January 6.000. YYY confirmed. specifically paragraph 11. Because of his non-participation. YYY. YYY services for the following reasons: (i) Absence Without Leave (AWOL) – from 2 march 2010 to onwards. plaintiff would just write down his payment on her notebook. In response. resolved the same based on the complaint and evidence at hand. the administrative committee of XXX. 5.00 thus reducing the balance of his indebtness to P300. Despite this agreement. . INC. He instead. that he will comply with the stipulated thirty (30) day notice of rule for resignation. for MR. On the same day. The said provision was specifically necessary and indispensable for XXX. 11. MR. 12. XXX. 25. YYY had no intention of complying with the agreed thirty (30) day notice rule for resignation.m. Thus. administrative hearings were set on 9 March 2010 at 9:00 a. Defendant paid the plaintiff on December 3.3. fully aware of the said provision in the contract.m. 13. through Ms. MR. 4. 7. YYY. (ii) Tardiness from 22 to 27 of February 2010. YYY to respond and appear before XXX. tendered his two week resignation letter dated 17 February 2010 with XXX. left his employer after receiving his latest salary in full. since 2 March 2010. XXX. That defendant. after due notice and hearing. out of respect and trust to the plaintiff.m. because of the nature of the work specifically required to be performed by an engineer and to also give ample opportunity for XXX. denied MR. MR. INC. and 27 of February 2010 at 11:00 a. 6. INC. no longer reported for work. INC. 10. upon condition that she would issue a consolidated receipt after he paid in full and for the meantime. 2011 to pay such amount. MR. 2010 the amount of P200. terminated MR.

INC.00) Pesos as previously agreed by him and the company. 15. MR. 16. XXX. YYY to pay liquidated damages in the amount of One Hundred Thousand (Php 100. INC.000. As of even date and after due demand. suffered delay and damages in its operations in finishing its scheduled projects with its long term clients since it was only MR. the said amount due. Because of this. YYY has not paid XXX. YYY who had the technical know-how in finishing the same which he originally started. .14. Formal demand was made upon MR.

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