Republic of the Philippines
Department of Finance
INSURANCE COMMISSION
Insurance Commission Bldg.
Teigonm
JAN 24 2019
1071 U.N. Avenue cor. Romualdez St. has Wa Bw
Manila =
Republic of the Philippines
INSURANCE COMMISSION
Manila
CLAIMS ADJUDICATION DIVISION
NARSON LEELIN FRANCISCO,
Complainant,
- versus - IC CAD Case No. 4210
PEOPLE’S GENERAL INSURANCE CORP.,
Respondent.
ynplainant’s Motion issic if Position
COMES NOW, the Respondent People’s General Insurance Corporation
(hereinafter, “PGIC"}, by the undersigned counsel, unto this Honorable Office,
respectfully submits this Conment/ Opposition to Complainant’s Motion for Submission of
Pasition Paper in Lien of Clarifeatory Hearing | Conference, and thus states, That
1.0. _In his Motion jor Submission of Pasition Paper in Lieu of Clarificatory Hearing /
Conference, Complainant secks to forego with the conduct of heasing/conference in
order to expedite the proceedings to further the interest of justice.
2.0. In view of its peculiarity, however, Respondent PGIC respectfully
submits that the conduct of a full blown tral shall be essential to obtain an accurate
and comprehensive understanding of the facts surrounding the instant case.
DRAVERWHEREFORE, PREMISES CONSIDERED, it is respectfully prayed of this
Honorable Office that Complainant’s Motion for Submission of Position Paper in Lica of
Clarificatory Hearing / Conference be DENIED for UTTER LACK OF MERIT.
Such other reliefs and remedies which are just and equitable in the premises are
likewise prayed for.
Pasig City for Manila, 16 January 2019.
JABLA BAGAS SAMPIOR & LIBARDO
LAW OFFICES
Counsel for People’s General Tnsterance Corporation
Unit 906 Richmonde Plaza, San Miguel Avenue
Corner Lourdes Street, Ortigas Center,
Pasig City, Metro Manila 1605
(02) 633-6832 / (02) 687-0306
oe
Roll of Attorneys No. 55635
TBP No. 064400/01-08-19/RSM
PTR No. 5238666/01-09-19/Pasig, City
MCLE COMPLIANCE No. V-0014824/March 01, 2016
Mobile No. 09176780808; lenkibardo@gmail.com
Oo
EMMANUEL R. JABLA
Roll of Attorneys No. 36523
IBP No. 064399 / 1-08-19 / Manila IV
PTR No. 5238667 / 109-19 / Pasig City
MCLE Compliance No. V-0022864/July 07, 2016
Mobile No. (0917)8121626
COPY FURNISHED by Registered Mail with Return Card and private courier
(LBC) due to lack of manpower of the above-mentioned law firm to effect the
preferred mode of service by personal delivery pursuant to Sec. 11, Rule of the
1997 Rules of Civil Procedure:3
THE LAW FIRM OF BALBIN/LUCMAN & PARTNERS
Counsel for the Complainant
Seabome Bldg., 4203 R. Magsaysay Blvd.
cor. Sociego St, Sta. Mesa, Manila
As Per Registry Receipt No. 5
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