COMPROMISE AGREEMENT This Agreement executed this 31st day of October, 2013 at Makati, Metro Manila, by and between

PEDRO PENDUKO, !ili"ino, of legal age with address at 222 Montclair #treet, Mer$ille %ark, %ara&a'ue, Metro Manila, re"resented herein by Atty( )uan *ela +ru, -hereinafter referred to as .the "laintiff/0( 1and1 ENTENG KABISOTE, !ili"ino, of legal age with address at 2o( 11 3old 4oo" #treet, Ortigas +enter, %asig, Metro Manila, re"resented herein by Atty( Maria Makiling -hereinafter referred to as .the defendant/0( WITNESSETH: That WHEREAS, the "laintiff %52*67O and defendant 7A89#OT5 ha$e instituted se$eral actions against each other in the "ast( WHEREAS, the "laintiff %52*67O instituted the "resent action for recon$eyance of real "ro"erty, annulment of deed of sale and accounting of income of "ro"erty( WHEREAS, the "arties desire to buy "eace and wish to a$oid a "rotracted litigation in this case( NOW THEREFORE, in consideration of the foregoing and the further co$enants hereinafter set forth, the "arties agree as follows 1( %laintiff shall be "aid the sum of !O6: M9449O2 %5#O# -%;,000,000(000 in accordance with the following schedule a( 9nitial "ayment 1 T<O M9449O2 %5#O# -%2,000,000(000 shall be "aid to the "laintiff by defendant 7A89#OT5 u"on the signing and due execution of this +om"romise Agreement, %ro$ided, howe$er, that the initial "ayment by defendant 7A89#OT5 shall be deli$ered into the custody and "ossession of a third "arty, Atty( Maria Mercedes, who shall act as escrow1trustee of

the "arties and who shall only deli$er the said initial "ayment to the "laintiff through "laintiff=s counsel u"on the filing in +ourt of this +om"romise Agreement( b( The balance of T<O M9449O2 %5#O# -%1,000,000(000 shall be "aid by defendant 7abisote as follows #econd "ayment 1 O25 M9449O2 %5#O# -%1,000,000(000 within sixty ->00 days after the date of the first "ayment( Third "ayment 1 O25 M9449O2 %5#O# -%1,000,000(000 within forty1fi$e -;?0 days after the date of the second "ayment( 2( The initial "ayment by defendant 7A89#OT5 shall be made in cash( The two "ayments on the balance shall be co$ered by "ost1dated checks drawn by defendant 7A89#OT5 as "ayable to ATT@( )6A2 *54A +:6A who shall hold and account for said "ayments in trust for "laintiff%52*67O( 3( This +om"romise Agreement shall not affect nor "reBudice any case or cases between the "arties not s"ecifically referred to herein( ;( 6"on deli$ery of the initial "ayment made by defendant 7A89#OT5 and deli$ered to the escrow1trustee of the "arties, the "arties shall seek +ourt a""ro$al of this +om"romise Agreement and the cancellation or lifting of the notice of lis "endens issued by the +ourt o$er the "ro"erty subBect of the action( ?( The signatories to this Agreement hereby re"resent and warrant that they are duly authori,ed to execute this Agreement( >( The "arties or their assigns hereby wai$e, renounce and fore$er 'uitclaim all their res"ecti$e claims and counterclaims subBect of the instant action as well as those that may arise therefrom, in connection therewith or in relation thereto( C( The foregoing co$enants are not contrary to law, morals, or "ublic "olicy and the "arties bind themsel$es to com"ly strictly with their undertakings( IN WITNESS WHEREOF, "arties herein affixed their signatures on the date and "lace abo$e written(

DDDDDDDDDDDDDDDDDDDDDDDDD DDDDDDDDDDDDDDDDDDDDDDDDD %laintiff *efendant

#igned in the "resence of

DDDDDDDDDDDDDDDDDDDDDDDDDDDDD

DDDDDDDDDDDDDDDDDDDDDDDDDDDDDD