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REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT


BRANCH 1
Baguio City
Kim Kardashan
Plaintiff,
v.

CIVIL CASE No. 8076


FOR: Specific Performance with
Damages

Thalia Marimar
Defendant.
X----------------------X

ANSWER DENYING GENUINENESS and


DUE EXECUTION OF INSTRUMENT
COMES NOW, Defendant, through the undersigned counsel, most
respectfully files her Answer in response to the Complaint of the Plaintiff,
to wit:
1.

Paragraph 1 is admitted; however, the defendant is now


presently residing at 43 Legarda Road, Baguio City;

2.

Paragraphs 2a, 2b, 2c, 2d, and 3 are denied for lack of
information or knowledge sufficient to form a reasonable belief
thereof;

3.

Paragraph 4 is denied insofar as the allegation that both


Plaintiff and Defendant entered into a contract of sale and the
subject of which is the latters Nissan Safari 4x4, 2011 model;

4.

That the alleged signature of the defendant in the said


instrument is forged as the defendant never entered into an
agreement with the Plaintiff; hence, denying the genuineness
and due execution of instrument;

5.

The allegation in paragraph 4 is denied as the same is an


erroneous conclusion made by Plaintiff;

6.

The defendant has no knowledge sufficient to form a belief as to


the allegations made in paragraph 5, 6,7 and 8.
PRAYER

WHEREFORE, in view of the foregoing, Defendant most respectfully


prays for the dismissal of the complaint. Other reliefs are likewise prayed
for.
Baguio City, Philippines. October 4, 2014.

SHEERA LAINE V. MANZANO


Of counsel
248 Session Road, Baguio City
PTR No. 125/Baguio City/12-31-15
Roll of Atty. No. 41118
IBP Lifetime Membership No. 9789
MCLE Compliance No 9789
VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING
I, THALIA MARIMAR, of legal age, do hereby state that: I am the defendant in the case;
in response, I have caused the preparation of this Answer; I have read its contents and affirm
that they are true and correct to the best of my own personal knowledge; I specifically deny
the genuineness and due execution as well as the binding effect of the actionable
documents pleaded by plaintiff, I hereby certify that there is no other case commenced or
pending before any court involving the same parties and the same issue and that, should I learn
of such a case, I shall notify the court within five days from my notice.
IN WITNESS WHEREOF, I have signed this instrument on 4 October 2014 in the City of
Baguio, Philippines.
(Sgd.) MARIMAR THALIA

SUBSCRIBED AND SWORN TO before me in the City of Baguio on this


4th day of October, affiant exhibiting before me his Government Issued ID
No. 08061989 issued on August 6, 2012 at Baguio City.

Doc. No. 21
Page No. 4
Book No. 1
Series of 2014.

HANIFAH GO
Notary Public for Baguio City
Until December 31, 2015
182 Session Road, Baguio City
PTR No. 123/Baguio City/12-31-13
Roll of Atty. No. 45678
IBP Lifetime Membership No. 910
MCLE Compliance No 9876

PROOF OF SERVICE

Copy furnished through personal service:


Atty. ANDREI S. BASABAS
Counsel for Plaintiff
44 Honeymoon Road
Baguio City

REPUBLIC OF THE PHILIPPINES


MUNICIPAL TRIAL COURT
BRANCH 1

Baguio City

Willie Vallejos
Plaintiff,
v.

CASE NO. 8076


FOR: Petition for Insolvency

Ethel Panganiban
Defendant.
X----------------------X
ANSWER OF DEBTOR TO PETITION FOR INSOLVENCY
COMES NOW, the defendant, through the undersigned counsel, in
the above-entitled case and to this Honorable Court most respectfully avers
the following:
1. Paragraph 1 is admitted pertaining to the personal circumstances of
the parties;
2. Paragraphs 2 to 3 is admitted as to the circumstances surrounding
the creditor-debtor relationship between the parties, as well as the
amount involved in the case;
3. Paragraph 4 is admitted; in which case, the Defendant is in fact
solvent as she retains substantial cash deposits and properties, as
evidenced by her Statement of Assets and Liabilities attached as
Annex A, to answer for the debt involved in this case;
4. Also, the said indebtedness has not gain its maturity date yet since the
same was subject to an extension or until May 28, 2012, as agreed
orally by the parties;
5. Paragraph 5 is partially denied in that the proposal of garnishment of
the shares of stock in Corporation A in the name of the Defendant
cannot be garnished since the said personal property is being held in
trust by the respondent in favor of a ward;
6. Hence, this case was only maliciously filed to the effect that the
Plaintiff be able to obtain rights over the said shares of stock, in which
he has no right.

WHEREFORE, the Defendant respectfully prays that the petition be


dismissed for lack of merit.
Baguio City, Philippines. 4 October 2014.

SHEERA LAINE V. MANZANO


Of counsel
248 Session Road, Baguio City
PTR No. 125/Baguio City/12-31-15
Roll of Atty. No. 41118
IBP Lifetime Membership No. 9789
MCLE Compliance No 9789
PROOF OF SERVICE
Copy furnished through personal service:
Atty. ANDREI S. BASABAS
Counsel for Plaintiff
44 Honeymoon Road
Baguio City

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT

FIRST JUDICIAL REGION


BRANCH 1
Baguio City
JUAN DELA CRUZ,
Plaintiff,
v.
PEDRO MENDOZA,
Defendant.
x----------------------------x

Civil Case No. 1234


For: Petition for Cancellation
of Title

ANSWER
RESPONDENT, by undersigned counsel and to this
Honorable Court, answering the petition for cancellation of title,
respectfully alleges:
1)
He admits the allegations in par. 1 of the petition regarding
the personal circumstances and addresses of the parties.
2)
He admits the allegations in pars. 2 to 5 to the petition,
subject to qualifications and affirmative defenses herein alleges;
By way of SPECIAL AND AFFIRMATIVE DEFENSES,
respondent alleges:
1)
That the parcel of land in question is a conjugal property of
respondent and his wife, Betty Diyosa;
2)
That the court in Civil Case NO. 123 has not acquired
jurisdiction over the person of his wife because she was not a party
litigant therein:
3)
That the money judgment in Civil Case No 123 arose from
the personal transaction of petitioner in connection with the
accommodation surety he executed to secure payment of the loan
extended by respondent to the corporation, X, which loan did not
benefit the conjugal property, and accordingly said conjugal property
is exempt from execution to satisfy said personal judgment of
respondent.
4)
That the execution sale is invalid because there was no valid
levy made by the sheriff, as at the time the court in Civil Case No. 123
has not acquired jurisdiction over the person of respondents wife,
who was not a party litigant in said case.

5)
The value of the land in question has market value far
exceeding the amount of money judgment rendered in favor of
petitioner, as to unfairly and unjustly enrich petitioner.
6)

As the Supreme Court ruled in Padilla, Jr. v. Phil. Producers


Cooperative Marketing Assn., G.R. No. 141256, July 15, 2005:
It is clear that PD 1529 provides the solution to respondents
quandary. The reasons behind the law make a lot of sense; it provides
due process to a registered landowner (in this case the petitioner) and
prevents the fraudulent or mistaken conveyance of land, the value of
which may exceed the judgment obligation. Petitioner contends that
only his interest in the subject lots, and not that of his wife who was
not a party to the suit, should have been subjected to execution, and
he should have had the opportunity to prove as much.
PRAYER

WHEREFORE, respondent respectfully prays that the petition be


dismissed for lack of merit.
Baguio City, Philippines, October 4, 2014.

SHEERA LAINE V. MANZANO


Counsel for Respondent
248 Session Road, Baguio City
PTR No. 125/Baguio City/12-31-15
Roll of Atty. No. 41118
IBP Lifetime Membership No. 9789
MCLE Compliance No 9789
PROOF OF SERVICE
Copy furnished through personal service:
Atty. ANDREI S. BASABAS
Counsel for Plaintiff
44 Honeymoon Road
Baguio City
Republic of the Philippines
FIRST JUDICIAL REGION

REGIONAL TRIAL COURT


BRANCH 6
Baguio City
In the Matter of the Petition of
LIBERTY REYES,
Plaintiff,
v.

S.P. No. 1234


For: Habeas Corpus

The Chief Of Police Of Baguio City


Defendant.
x -------------------------------- x
ANSWER
The undersigned respondent in the above-entitled case hereby makes
due return of the writ of Habeas Corpus issued by this Court on April 18,
2013, and by way of answer, most respectfully states:
1)

That the herein respondent has LIBERA T. REYES under


restraint in the police detention cell at the Baguio Police Department
headquarters, pending completion of and transfer to the city jail now under
reconstruction;

2)

That the herein respondent caused the apprehension of the said


LIBERA T. REYES on April 9, 2013, and the authority, the true, and the
whole story and cause of the said restraint of the said person are the
following, to wit:

a)

That said party, LIBERA T. REYES, was apprehended and placed under
police custody on suspicion of having smuggled unlicensed firearm found
abandoned in an army bag at the corner of Kayang and Abano Streets, of
this city, to have been carried by said LIBERA T. REYES as reported by a
witness;

b)

That in the evening of April 8, 2013, while investigation of the detainee was
being conducted, the Warrant Section of the Baguio City Police Department
discovered among its files a warrant for the arrest of said LIBERA T.
REYES issued by the Regional Trial Court of this city, Branch II, in
Criminal Case No. 1234 entitled People of the Philippines vs. LIBERA T.
REYES for the crime of Assault upon a person in Authority;
c) That in the above-mentioned criminal case, the detainee has
not posted a bond for her provisional liberty up to the present time;

d) That said detainee has been detained temporarily in the police


detention cell of the Baguio City Police Department in view of the
destruction through fire of the Baguio City Jail;
e) That a copy of the warrant of arrest issued against LIBERA T.
REYES is Criminal Case No. 1234 entitled People of the Philippines vs.
Libera T. Reyes commanding her apprehension, is hereto attached as
Annex A made an integral part of this return and answer.
WHEREFORE, all the foregoing premises considered, it is
respectfully prayed that the petition for Habeas Corpus be dismissed, and
that the said LIBERA T. REYES be ordered to remain in the custody of
the Baguio City Police Department.
Baguio City, Philippines, 4 October 2014.

BRYAN DY
Chief of Police, Baguio City

REPUBLIC OF THE PHILIPPINES


FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 10

Baguio City
AIKO MELENDEZ,
Petitioner,

CIVIL CASE NO. 1234


For: Legal Separation

v.
JOMARI YLLANA,
Respondent.
x------------------------------x

ANSWER TO PETITION FOR LEGAL SEPARATION


COMES NOW, the Defendant, by counsel and to this Honorable Court, by way of
answer, most respectfully avers the following:

1. Paragraph 1 is admitted as to the personal circumstances of the parties;


2. Paragraphs 2 , 4, 5, and 7 are also admitted by the defendant;
3. Paragraph 3 is hereby partially admitted in that he and the petitioner have only three
sons and one daughter; such that the allegation of having six children entitled to
support is denied;

4. Furthermore, the two children, namely Cesar and Beth, having been successfully
adjudged in Case No. 9876 to have been impossibly the children of the herein
respondent, it is but just to exclude them from the persons rightful to support from
the respondent;

5. Paragraph 6 is partially denied in that he is presently holding a managerial position


in a private company but such company is at the verge of closing business due to
insolvency and that as of present time, there is delay in the reception of his monthly
salary; hence, the amount of support being demanded by the Petitioner cannot be
afforded by the Respondent;

6. Paragraph 8 is likewise partially denied by the Respondent since the lot located at
Malolos, Bulacan is the Respondents exclusive property having been donated by his
parents to him during the marriage, as evidenced by the Deed of Donation executed
on February 11, 2013; having been so, it cannot form a part of the conjugal properties
subject to the proposed dissolution of properties by the Petitioner.
WHEREFORE, after due hearing, judgment be rendered declaring a decree of legal
separation between petitioner and respondent, ordering the liquidation of the conjugal property
with the exception of the Bulacan property, and reducing the amount of support to the lawful
children of the respondent only, excluding the illegitimate children of the petitioner, until they
reached majority age or until they finished their college education, in such amount as the
Honorable Court may reasonably fix.

Baguio City, Philippines. 19 April 2013.


SHEERA LAINE V. MANZANO
Of counsel
248 Session Road, Baguio City
PTR No. 125/Baguio City/12-31-15

Roll of Atty. No. 41118


IBP Lifetime Membership No. 9789
MCLE Compliance No 9789
VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING
I, THALIA MARIMAR, of legal age, do hereby state that: I am the defendant in the case;
in response, I have caused the preparation of this Answer; I have read its contents and affirm
that they are true and correct to the best of my own personal knowledge; I specifically deny
the genuineness and due execution as well as the binding effect of the actionable
documents pleaded by plaintiff, I hereby certify that there is no other case commenced or
pending before any court involving the same parties and the same issue and that, should I learn
of such a case, I shall notify the court within five days from my notice.
IN WITNESS WHEREOF, I have signed this instrument on 4 October 2014 in the City of
Baguio, Philippines.
(Sgd.) MARIMAR THALIA
SUBSCRIBED AND SWORN TO before me in the City of Baguio on this 4 th day of October,
affiant exhibiting before me his Government Issued ID No. 08061989 issued on August 6, 2012
at Baguio City.

Doc. No. 21
Page No. 4
Book No. 1
Series of 2014.

HANIFAH GO
Notary Public for Baguio City
Until December 31, 2015
182 Session Road, Baguio City
PTR No. 123/Baguio City/12-31-13
Roll of Atty. No. 45678
IBP Lifetime Membership No. 910
MCLE Compliance No 9876
PROOF OF SERVICE

Copy furnished through personal service:


Atty. ANDREI S. BASABAS
Counsel for Plaintiff
44 Honeymoon Road
Baguio City

REPUBLIC OF THE PHILIPPINES


MUNICIPAL TRIAL COURT
BRANCH 1
Baguio City

A-Z COMPANY,
Plaintiff,
Civil Case No. 2222
For : Ejectment

v.
PETRONICIA AGTALBOG,
Defendant.
x ----------------------------------- x

ANSWER WITH NEGATIVE AND AFFIRMATIVE DEFENSE


COMES NOW, DEFENDANT, by counsel, respectfully states that:

Admissions/Denials
1.

He admits the contents of paragraph 1 only insofar as his personal circumstances


but specifically denies the contents insofar as plaintiffs personal circumstances for
the reason stated in the Affirmative Defenses below;

2.

He admits the contents of paragraph 2 only where it states that a Contract of Lease
was entered into but specifically denies that the Contract reflects the true intent of
the parties as explained in the Affirmative Defenses below;

3.

He admits the contents of paragraph 3 only as to the fact that demand to vacate was
made but specifically denies its contents as to the truth of the reasons for the letter
for lack of knowledge sufficient to form a reasonable belief as to its truth or
falsehood;

4.

He specifically denies the contents of paragraphs 4 to 6 for the reasons stated in the
Affirmative Defenses below.

Affirmative Defenses
5.

Defendant reiterates, repleads and incorporates by reference all the foregoing


insofar as they are material and additionally submit that the Complaint should be
dismissed because:

5.1.

Plaintiff has no capacity to sue as it is a foreign corporation doing


business in the Philippines without a license.

5.2.

The Complaint fails to state a cause of action as the Contract of


Lease (ANNEX A) was, before its expiration, superseded by a Deed
of Absolute Sale whereby plaintiff sold to defendant the parcel of
land in question, a copy of which is attached as ANNEX 1.

WHEREFORE, Defendant respectfully prays that judgment be rendered in his favor by


dismissing the Complaint.
Other just and equitable reliefs are prayed for.
Baguio City for Quezon City. 19 April 2013.
SHEERA LAINE V. MANZANO
Of counsel
248 Session Road, Baguio City
PTR No. 125/Baguio City/12-31-15
Roll of Atty. No. 41118

IBP Lifetime Membership No. 9789


MCLE Compliance No 9789
VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING
I, THALIA MARIMAR, of legal age, do hereby state that: I am the defendant in the case;
in response, I have caused the preparation of this Answer; I have read its contents and affirm
that they are true and correct to the best of my own personal knowledge; I specifically deny
the genuineness and due execution as well as the binding effect of the actionable
documents pleaded by plaintiff, I hereby certify that there is no other case commenced or
pending before any court involving the same parties and the same issue and that, should I learn
of such a case, I shall notify the court within five days from my notice.
IN WITNESS WHEREOF, I have signed this instrument on 4 October 2014 in the City of
Baguio, Philippines.
(Sgd.) MARIMAR THALIA
SUBSCRIBED AND SWORN TO before me in the City of Baguio on this 4 th day of October,
affiant exhibiting before me his Government Issued ID No. 08061989 issued on August 6, 2012
at Baguio City.

Doc. No. 21
Page No. 4
Book No. 1
Series of 2014.

HANIFAH GO
Notary Public for Baguio City
Until December 31, 2015
182 Session Road, Baguio City
PTR No. 123/Baguio City/12-31-13
Roll of Atty. No. 45678
IBP Lifetime Membership No. 910
MCLE Compliance No 9876
PROOF OF SERVICE

Copy furnished through personal service:


Atty. ANDREI S. BASABAS
Counsel for Plaintiff
44 Honeymoon Road
Baguio City

REPUBLIC OF THE PHILIPPINES


MUNICIPAL TRIAL COURT
City of Baguio
Branch 1

GAVIN REYES,
Plaintiff
v.

CIVIL CASE NO. 12345


FOR: Action For Specific Performance

ARTHUR SANTOS,
Defendant.
x--------------------------------------------x

ANSWER WITH PERMISSIVE COUNTERCLAIM

COMES NOW, the defendant, through the undersigned counsel and unto this Honorable
Court, most respectfully avers:
That the subject matter of the complaint is specific performance of contract, and the
permissive counterclaim has no relation to such subject matter of the complaint, as follows:
Plaintiff and defendant entered into a contract of sale of clothing
materials on or about December 18, 2012, whereby defendant would
deliver to plaintiff such materials worth P300,000.00 and the
plaintiff would in turn pay the same, upon such delivery on March 2,
2013.
Defendant having delivered said clothing materials on March 2, 2013 to plaintiff, but the
latter, notwithstanding repeated demands, both oral and written, failed and refused to pay the
same and still fails and continues to refuse to pay the purchase thereof, in breach of his
obligation.
WHEREOF, defendant prays that the complaint be dismissed for lack of merit.
Under his counterclaim, judgment be rendered ordering plaintiff to pay the amount of
THREE HUNDRED THOUSAND PESOS (P300, 000.00 ) with legal interests thereon until the
principal amount and interest are fully paid.
Such other relief and remedies as may be deemed just and equitable under the premises
are likewise prayed for.
City of Baguio, Philippines. 19 April 2013.

ATTY. JUAN LUNA


Counsel for the Defendant

182 Gayaba Bldg., Session Road, Baguio City


PTR No. 123/Baguio City/12-31-13
Roll of Arty No. 45678
IBP Lifetime Membership No. 910
MCLE Compliance No 9876

REPUBLIC OF THE PHILIPPINES


MUNICIPAL TRIAL COURT
City of Baguio
Branch 1

JUAN DELA CRUZ,


Plaintiff,
CIVIL CASE NO. 12368
For: Collection of Sum of Money

v.
PEDRO REYES,
Defendant,
x------------------------------------------x

ANSWER with SPECIAL AND AFFIRMATIVE DEFENSES


WITH COUNTERCLAIM
NOW COMES the defendant, by the undersigned counsel, in the above-entitled case
and to this Honorable Court most respectfully alleges:
1) Defendant admits the averment in paragraph 1, 2, and 3 of the complaint;
2) Defendant specifically denies the allegation in paragraph 4 of the complaint for lack of
information and sufficient knowledge to form a belief as to the truth thereof;
3) Defendant does not admit the allegations contained in paragraph 5 and 6 of the
complaint as it lacks in form and substance to support any cause of action against the defendant;
4) Defendant does not admit the allegation in paragraph 7 as it has no basis in law and in
facts.

Special and Affirmative Defense


Defendants adopt and replead the foregoing allegations, and raise by way of special and
affirmative defenses the following:
The complaint states no cause of action. The rule requires that every action must be
prosecuted or defended in the name of the real party in interest. (Sec. 2, Rule 3 of 1997 Rules of
Civil Procedure). Only parties to a contract may sue or be sued upon that contract.
In the instant case, it is plain in the verification / certification appeared to the complaint
that A is suing in his own name by stating, under oath, that he is the plaintiff in the case, not A &
Z Corporation. A is not a party to the contract, she has no cause of action against herein
defendant.

Counterclaim
Defendant reiterates, repleads and incorporates by reference all the foregoing insofar as
they are material and additionally submit that he is entitled to relief arising from the filing of
this malicious and baseless suit, as follows:
1. Moral Damages amounting to Fifty Thousand Pesos (PHP50,000.00) because
his name and reputation were besmirched by this malicious and baseless suit.
2. Attorneys Fees amounting to Ten Thousand Pesos (P10,000.00) because he
was compelled to secure services of counsel to vindicate his legal rights.

PRAYER

WHEREFORE, it is respectfully prayed that the complaint be dismissed for lack of


cause of action and defendant be awarded the amount of fifty thousand pesos (Php 50,000.00)
and ten thousand pesos (Php 10,000.00) for moral damages and attorneys fees respectively.

Other relief and remedy just and equitable under the premises are likewise prayed for.
Baguio City, Philippines. April 19, 2013.

ATTY. GREGORIO DEL PILAR


Counsel for the Defendant

182 Gayaba Bldg., Session Road, Baguio City


PTR No. 123/Baguio City/12-31-13
Roll of Arty No. 45678
IBP Lifetime Membership No. 910
MCLE Compliance No 9876

REGIONAL TRIAL COURT


MUNICIPAL TRIAL COURT
BRANCH 3

Baguio City
JUAN DELA CRUZ,
Plaintiff,
Civil Case No. 2222
For : Damages with Specific
Performance

v.
PEDRO REYES,
Defendant.
x ----------------------------------- x

ANSWER with SPECIFIC DENIAL UNDER OATH


DEFENDANT, by counsel, respectfully states that:
1. He admits the contents of paragraph 1 only insofar as his personal circumstances but
specifically denies the contents insofar as plaintiffs personal circumstances for the reason stated
in the Affirmative Defenses below.
2. He denies Paragraphs 2, 3 and 4 for the lack of knowledge and reasonable belief as to
the truthfulness of the allegations thereon.
3. He specifically denies under oath the genuineness and due execution of the
instrument, a copy of which is attached to Plaintiffs complaint as Annex A, the truth being
that his signature thereon is forged and that he did in fact sign the said instrument.
4. He admits the contents of paragraph 3 only as to the fact that demand to deliver
goods but specifically denies its contents as to the truth of the reasons for the letter for lack of
knowledge sufficient to form a reasonable belief as to its truth or falseness.

PRAYER
WHEREFORE, Defendant respectfully prays that judgment be rendered in his favor by
dismissing the Complaint.
Other just and equitable reliefs are prayed for.
Baguio City, Philippines. 19 April 2013.

ATTY. GREGORIO DEL PILAR


Counsel for the Defendant

182 Gayaba Bldg., Session Road, Baguio City


PTR No. 123/Baguio City/12-31-13
Roll of Arty No. 45678
IBP Lifetime Membership No. 910
MCLE Compliance No 9876

Republic of the Philippines


FIRST JUDICIAL REGION
REGIONAL TRIAL COURT

BRANCH 6
Baguio City

JUAN DELA CRUZ,


Plaintiff,
Civil Case No.1237
For: EJECTMENT

v.
PEDRO REYES, Respondent
ANDRES BONIFACIO, Intervenor-Respondent.
X-------------------------------------------X

ANSWER-IN-INTERVENTION
COMES NOW, the intervenor-respondent, though the undersigned counsel, by way of
Answer, avers the following:

1. Paragraph 1 is admitted as to the personal circumstances of the parties, but denies


before the filing of the Complaint the knowledge on the person and identity of the
Petitioner;

2. Paragraphs 2 to 5 are denied for lack of information or knowledge sufficient to form a


reasonable belief thereof;

3. Paragraph 6 is denied insofar as the allegation that the owner of the entire lot subject
in the case is Juan Dela Cruz alone;

4. Furthermore, the 300 square meters of the subject lot is sold to the intervenor on
January 12, 2003; as a result of which a Tax Declaration is awarded to the
intervenor;

5. That by virtue of such sale, there was an absolute transfer of ownership from the
Respondent to the Intervenor; hence, the claim of the Plaintiff on the entire 1000 sq.
m., including the 300 sq. m. lot sold to the Intervenor, of the subject lot, is not
tenable;

6. Besides, the Plaintiff herein claims her right to the land by virtue of tenancy for a
period of 9 years; being such, she has no right as to the ownership of the subject lot;

7. The claim on paragraph 7 therefore that the Plaintiff is the absolute owner of the
subject property is denied for being erroneous.
WHEREFORE, it is prayed that the Complaint be dismissed for lack of merit.
Baguio City, Philippines. April 19, 2013.

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
FIRST JUDICIAL REGION
BRANCH 16
Baguio City

PEOPLE OF THE PHILIPPINES


Plaintiff,
CRIM. CASE NO.1234-D
For: Acts Of Lasciviousness

v.
JUAN DELA CRUZ,
Accused.
x-------------------------------------------x

INFORMATION
The undersigned accuses JUAN DELA CRUZ of the crime of ACTS OF
LASCIVIOUSNESS, committed as follows:
That on or about April 9, 2013 at about 4:00 p.m., in the City of Baguio and within the
jurisdiction of this Honourable Court, the said accused went to the house of the offended party,
MARIA CLARA, on the pretext of asking for a glass of water, stealthily approached her and,
without giving her an opportunity to defend herself, embraced and kissed her and caught hold of
her breasts, against her will and by means of force.
Contrary to law.
Baguio City, Philippines, 19 April 2013.

MISS PROSECUTOR
Assistant City Prosecutor

CERTIFICATION OF PRELIMINARY INVESTIGATION


I hereby certify that a preliminary investigation in this case was conducted by me in
accordance with law; that I examined the Complainant and his witnesses; that there is
reasonable ground to believe that the offense charged had been committed and that the accused
is probably guilty thereof; that the accused was informed of the Complaint and of the evidence
submitted against him and was given the opportunity to submit controverting evidence; and
that the filing of this Information is with the prior authority and approval of the City Prosecutor.

MISS PROSECUTOR
Assistant City Prosecutor

SUBSCRIBED AND SWORN TO BEFORE ME this 19th day of April 2013 in Baguio City.
MISTER FISCAL
City Prosecutor

Bail Recommended: P 10,000.00

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
FIRST JUDICIAL REGION
BRANCH 2
Baguio City

PEOPLE OF THE PHILIPPINES,


Plaintiff,
CRIM. CASE NO.1234-D
For: Adultery

v.
JUANA REYES
and JUAN DELA CRUZ
(Both of No. 28 Tacay Rd, Baguio City),
Accused.
x--------------------------------------------------x

INFORMATION
The undersigned hereby accuses JUANA REYES and JUAN DELA CRUZ of the
crime of ADULTERY, committed as follows:
That on or about April 9, 2013, prior to and subsequent thereto, and continuously up to
the present time, in the City of Baguio, Philippines, and within the jurisdiction of this Honorable
Court, the said accused JUANA REYES, being then united in lawful wedlock with JUAN REYES,
willfully, unlawfully and feloniously lay with and have carnal knowledge with her co-accused
JUAN DELA CRUZ, who in turn, knowing that said JUANA REYES was a married woman,
willfully, unlawfully and feloniously lay with and have carnal knowledge of her.
CONTRARY TO LAW.
Baguio City, Philippines, this 3rd day of March 2013.
MISS PROSECUTOR
City Prosecutor

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
FIRST JUDICIAL REGION
BRANCH 5
Baguio City

PEOPLE OF THE PHILIPPINES


Plaintiff,
v.

CRIM. CASE NO.1234-D


For: Concubinage

JUAN DELA CRUZ, and


JUANITA DELA ROSA
(Both of No 28, Queen of Peace,
Baguio City)
Accused.
x-------------------------------------------x

INFORMATION
The undersigned, Provincial Prosecutor, accuses JUAN DELA CRUZ of the crime of
CONCUBINAGE, committed as follows, to wit:
That on or about April 9, 2012 and continuously up to the present time, in the City of
Baguio, Philippines, and within the jurisdiction of this Honorable Court, the said JUAN DELA
CRUZ, willfully, unlawfully and feloniously at the said time and place, being then legally married
to complainant PEDRITA DELA CRUZ, cohabit with JUANITA DELA ROSA, a woman not his
wife, living with her as husband and wife at No.28 Queen of Peace, Baguio City, and the said
JUANITA DELA ROSA, knowing JUAN DELA CRUZ to be married, unlawfully and feloniously
cohabit with JUAN DELA CRUZ, living with him as husband and wife at No. 28 Queen of Peace,
Baguio City, begetting out of such cohabitation, a child named BASHA DELA CRUZ.
Contrary to law.
Baguio City, Philippines. 19 April 2013.

MISS PROSECUTOR
Assistant City Prosecutor

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
First Judicial Region
Branch 16, Baguio City
PEOPLE OF THE PHILIPPINES
Plaintiff,

CRIM. CASE NO.1234-D

v.

For: Damages to Property


Through Reckless

Imprudence
JUAN DELA CRUZ,
Accused.
x-----------------------------------------x
INFORMATION

The undersigned, City Prosecutor, accuses JUAN DELA CRUZ of the crime of
DAMAGE TO PROPERTY THROUGH RECKLESS IMPRUDENCE, committed as
follows, to wit:
That on or about April 9, 2013 at about 2 a.m., in the City of Baguio, and within the
jurisdiction of this Honourable Court, the said accused did then and there, while driving her
SUV with Plate No. XYZ123 under the influence of liquor and in a reckless and imprudent
manner, bumped his said vehicle into the residential house of PEDRO REYES situated at No. 12
Magsaysay Avenue, Baguio City, thereby causing damage to the front wall of the said residential
house to the damage and prejudice of its owner, PEDRO REYES in the amount of P500,00.00.
Contrary to law.
Baguio City, Philippines, 19 April 2013.

MISS PROSECUTOR
City Prosecutor

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
FIRST JUDICIAL REGION
BRANCH 2
Baguio City
PEOPLE OF THE PHILIPPINES

Plaintiff,

CRIM. CASE NO.1234-D


For: Estafa

v.
JUANA DELA CRUZ,
Accused.
x-------------------------------------------x

INFORMATION
The undersigned, City Prosecutor, accuses JUANA DELA CRUZ of the crime of
ESTAFA committed as follows, to wit:
That on or about March 7, 2013 at about 5: 00 p.m., in the City of Baguio, and within the
jurisdiction of this Honourable Court, the said accused having received from PEDRO REYES a
variety of jewelry valued at ONE MILLION (P1,000,000.00) for the purpose of selling the same
on commission, under the express obligation of holding the same in trust for PEDRO REYES
and to remit the proceeds of the sale of the said goods, if sold, or to return the same in case of
non-sale, within ten (10) days from receipt thereof, the said accused did then and there, wilfully,
unlawfully, and feloniously, misappropriate and convert the said goods or their proceeds to her
own personal use and benefit to the damage and prejudice of PEDRO REYES in the amount of
ONE MILLION FIVE HUNDRED THOUSAND (P1,500,000.00).
Contrary to law.
Baguio City, Philippines. 19 April 2013.
MISS PROSECUTOR
City Prosecutor

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
FIRST JUDICIAL REGION
BRANCH 16
Baguio City
PEOPLE OF THE PHILIPPINES
Plaintiff,

CRIM. CASE NO.1234-D


For: Attempted Homicide

v.
JUAN DELA CRUZ,
Accused.
x-------------------------------------------x

INFORMATION
The undersigned, City Prosecutor, accuses JUAN DELA CRUZ of the crime of
ATTEMPTED HOMICIDE, committed as follows, to wit:
That on or about March 7, 2013, at about 3 p.m., in the City of Baguio, and within the
jurisdiction of this Honourable Court, the said accused, armed with a jungle knife, and with
evident intent to kill, did then and there wilfully, unlawfully, and feloniously assault, attack and
wound one Severino Co with his said weapon, missing said arm by only a fraction of an inch, and
would have continued his criminal act had not the said victim successfully resisted him with the
help of some bystanders who responded to his cry for help.
Contrary to law.
Baguio City, Philippines. 19 April 2013.

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
FIRST JUDICIAL REGION
BRANCH 16
Baguio City
PEOPLE OF THE PHILIPPINES,
Plaintiff,
v.

CRIM. CASE NO.1234-D


For: Frustrated Homicide

JUAN DELA CRUZ,


Accused.
x-------------------------------------------x

INFORMATION
The undersigned, City Prosecutor, accuses JUAN DELA CRUZ of the crime of
FRUSTRATED HOMICIDE, committed as follows, to wit:
That on or about April 9, 2013, at about 3 p.m., in the City of Baguio, and within the
jurisdiction of this Honourable Court, JUAN DELA CRUZ, armed with a jungle knife, and with
evident intent to kill, did then and there wilfully, unlawfully, and feloniously assault, attack and
wound one Severino Magbanua inflicting mortal wounds in different parts of his body, which
would have directly caused the death of said Severino Magbanua, thus performing all acts of
execution which would have produced the crime of homicide as a consequence, but nevertheless
did not produce the same by reason of cause independent of his will, that is, because of the
timely medical assistance rendered on the said wounds.
Contrary to law.
Baguio City, Philippines. 19 April 2013.

MISS PROSECUTOR
City Prosecutor

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
FIRST JUDICIAL REGION
BRANCH 16
Baguio City
PEOPLE OF THE PHILIPPINES
Plaintiff,
CRIM. CASE NO.1234-D

v.

For: Less Serious Physical


Injuries

JUAN DELA CRUZ,


Accused.
x-------------------------------------------x

INFORMATION
The undersigned, City Prosecutor, accuses JUAN DELA CRUZ of the crime of
SLIGHT PHYSICAL INJURIES, committed as follows, to wit:
That on or about April 9,2013, at about 10 a.m., in the City of Baguio , Province of
Benguet and within the jurisdiction of this Honourable Court, the said accused did there and
then wilfully, unlawfully and feloniously, and without justifiable cause therefor, attack, assault,
and beat one Lindo Naban, punching him on the face, thereby inflicting on the latter physical
injuries, which have required and will require medical attention for a period of one to nine days,
and have incapacitated and will incapacitate him from labor for the same period of time.
Contrary to law.
Baguio City Philippines. 9 April 2013.

MISS PROSECUTOR
City Prosecutor

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
FIRST JUDICIAL REGION
BRANCH 16
Baguio City
PEOPLE OF THE PHILIPPINES,
Plaintiff,

CRIM. CASE NO.1234-D

v.

For: Illegal Detention

MANNY Y. JONES,
LANNY V. JONES,
JOHN DOE,
Accused.
x-------------------------------------------x

INFORMATION
The undersigned, City Prosecutor, accuses Spouses Manny Y. Jones and Lanny Y.
Jones of the crime of ILLEGAL DETENTION, committed as follows, to wit:
That within the period of April 9, 2013 to April 10, 2013, in the City of Baguio,
Philippines, and within the jurisdiction of this Honourable Court, the above-named accused who
are private individuals, conspiring, confederating and mutually helping one another for a
common purpose, did then and there, wilfully, unlawfully and feloniously detain Rosario B.
Amorsolo, a female, in the following manner: When Rosario B. Amorsolo was in the house of
accused Manny V. Jones, accused 'John Doe' tied her hands with wire on her back while accused
Manny V. Jones covered her head with a knapsack and told her that accused 'John Doe' was a
policeman and accused Lanny V. Jones asked Rosario B. Amorsolo to sign a document for the
withdrawal of a civil case; and as a consequence thereof said Rosario B. Amorsolo was deprived
of her liberty against her will for a period aforestated.
Contrary to law.
Baguio City Philippines. 19 April 2013.

MISS PROSECUTOR
City Prosecutor

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
First Judicial Region
Branch 16, Baguio City
PEOPLE OF THE PHILIPPINES,
Plaintiff,
v.

CRIM. CASE NO.1234-D


For: Malversation

JUAN DELA CRUZ,


Accused.
x---------------------------------------------x

INFORMATION
The undersigned, Assistant City Prosecutor, accuses JUAN DELA CRUZ of the crime
of MALVERSATION, committed as follows, to wit:
That on or about April 9, 2013 , at about 5 p.m., in the City of Baguio and within the
jurisdiction of this Honourable Court, the said accused, then being the Treasurer of the City of
Baguio, did then and there wilfully, unlawfully, and feloniously, and with grave abuse of
confidence, misappropriate, take, withdraw, and convert for his own personal use and benefit,
the total amount of P1,500,000.00 which are public funds belonging to the City of Baguio, to the
damage and prejudice of the public interest.
Contrary to law.
Baguio City, Philippines. 19 April 2013.

MISS PROSECUTOR
Assistant City Prosecutor

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
First Judicial Region
Branch 16, Baguio City

PEOPLE OF THE PHILIPPINES,


Plaintiff,
v.

CRIM. CASE NO.1234-D


For: Parricide

JUAN DELA CRUZ,


Accused.
x--------------------------------------x

INFORMATION
The undersigned, Assistant City Prosecutor, accuses JUAN DELA CRUZ of the crime
of PARRICIDE, committed as follows, to wit:
That on or about April 9, 2013, at about 10:00 a.m., in the City of Baguio and within the
jurisdiction of this Honourable Court, the said accused, motivated by extreme jealously, and
while armed with a .38 caliber pistol, did then wilfully, unlawfully, and feloniously, suddenly,
unexpectedly, and treacherously fired several shots at JUANITA DELA CRUZ, his lawfully
wedded wife, which caused the instantaneous death of his said wife while she is walking along
Session Road with her friend, Pedro Masangkay.
Contrary to law.
Baguio City, Philippines. 19 April 2013.

JACK R. GO
City Prosecutor

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
FIRST JUDICIAL REGION
BRANCH 16
Baguio City

PEOPLE OF THE PHILIPPINES,


Plaintiff,
v.

CRIM. CASE NO.1234-D


For: Rape

JUAN DELA CRUZ,


Accused.
x--------------------------------------x

INFORMATION
The undersigned, City Prosecutor, accuses JUAN DELA CRUZ of the crime of RAPE,
committed as follows, to wit:
That on or about April 9, 2013, at about 11 p.m., in the City of Baguio and within the
jurisdiction of this Honourable Court, the said accused entered the house of Lisa Laya who was
then and there alone, and did there and then, wilfully, unlawfully, and feloniously, had carnal
knowledge of the said minor against her will and by means of force, violence, intimidation and
threats.
Contrary to law.
Baguio City, Philippines. 19 April 2013.

JACK I. ENRILE
City Prosecutor

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
First Judicial Region
Branch 16, Baguio City
PEOPLE OF THE PHILIPPINES
Plaintiff,
v.
JUAN DELA CRUZ,

CRIM. CASE NO.1234-D


For: Robbery

Accused.
x-------------------------------------------x

INFORMATION
The undersigned, Assistant City Prosecutor, accuses JUAN DELA CRUZ of the crime
of ROBBERY, committed as follows, to wit:
That on or about April 9,2013, at about 10 p.m., in the City of Baguio and within the
jurisdiction of this Honourable Court, the said accused did then and there, wilfully, unlawfully,
feloniously, with intent to gain and with intimidation upon the person of Louie Campo by
threatening him with a .38 caliber pistol, took and carry away the latters O2 XDA II mobile
phone valued at P35,000.00, Philippine Currency, to the damage and prejudice of the said
victim in the said amount.
Contrary to law.
Baguio City, Philippines, 19 April 2013.

JACKI P. RODRIGUEZ
Assistant City Prosecutor

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
FIRST JUDICIAL REGION
BRANCH 16
Baguio City
PEOPLE OF THE PHILIPPINES
Plaintiff,
v.
JUAN DELA CRUZ,

CRIM. CASE NO.1234-D


For: Seduction

Accused.
x-------------------------------------------x

INFORMATION
The undersigned upon sworn complaint filed by the offended party, JUANITA GANDA,
copy of which is attached hereto, accuses JUAN DELA CRUZ, of the crime of SIMPLE
SEDUCTION, committed as follows:
That on or about and during the month of February and March, 2013, in the City of
Baguio, within the jurisdiction of this Honourable Court, the above-named accused by means of
deceit by promising to marry the offended party, did then and there wilfully, unlawfully and
feloniously have sexual intercourses with one Juanita Ganda, a 17 year old unmarried woman of
good repetition, thereby resulting to the pregnancy of the said offended party.
CONTRARY TO LAW.
Baguio City, Philippines. 19 April 2013.

JACK O. UY
City Prosecutor

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
FIRST JUDICIAL REGION
BRANCH 2
Baguio City
PEOPLE OF THE PHILIPPINES,
Plaintiff,
v.
JUAN DELA CRUZ,

CRIM. CASE NO.1234-D


For: Violation of R.A. 9262

Accused.
x-------------------------------------------x

INFORMATION
The undersigned hereby accuses JUAN DELA CRUZ of VIOLATION OF R.A. 9262
(ANTI-WOMENS VIOLENCE ACT) committed as follows:
That sometime on April 9, 2013 in the City of Baguio, Philippines and within the
jurisdiction of this Honorable Court, the above-named accused did there and then, willfully,
unlawfully and criminally and with intent to manipulate the conduct of his wife and children to
beg money from him, commit acts of economic abuse against his wife, JUANA DELA CRUZ and
their minor children, by refusing to give them any financial support, which is legally due them
under the law, to their damage and prejudice.
CONTRARY to Section 5 par.e (2) in relation to Sec 3 sub. Par.d, of RA 9262 (economic
abuse).
Baguio City, Philippines, this 19th day of April 2013.

PEDRO LIWANAG
City Prosecutor