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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. DRAVER WHEREFORE, 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 Posted at

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