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REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT


REGION IV-A
BACOOR CITY, CAVITE

JONES PAUL VARGAS,


Plaintiff,

-versus- Civil Case No. 6969


For: Small Claims

ROMMARIE ANGELI DELA


ROSA
Defendant.

x-------------------------------------------------x

COMMENT
(To Notice of Appeal)

Defendant, ROMMARRIE ANGELI DELA ROSA, by


counsel, unto to this Honorable Court, respectfully
interposes:

1. In the Order dated 12th of May 2019, the


Honorable Court required herein defendant to
file a Comment to the Notice of Appeal filed
by the plaintiff;

2. The Notice of Appeal filed by herein


plaintiff should not be given consideration
on the ground that the Order dated 25 April
2019 is already final, executory and
unappealable as provided under Section 24 of
the 2016 Revised Rules of Procedure for
Small Claims Cases;

PRAYER/RELIEF

WHEREFORE, defendant respectfully asks that the


appeal be DENIED and the 25 April 2019 Decision
dismissing the claim AFFIRMED.

Other just and equitable reliefs are likewise


prayed for.
City of Manila, 13 May 2019.

ELEAD GADDIEL S. ALBUERO


Counsel for Defendant
Saliendra Law Office
66th floor, Targaryen Tower
2119 Recto Ave., Sampaloc
1015 Manila
Roll No. 20394/IBP
LRN 75498/09-07-12
PTR No. 2873463D/02-03-17
MCLE Exemption No. IV-765498/12 May 2014
Telefax: 563558/ Mobile No. 0927-6786083
E-mail: gaddielsaliendra7@gmail.com

COPY FURNISHED:

ATTY. HODOR SAMMY S. ENRIQUEZ


ERQZ Law Offices
425 Rizal Street
Kawit, Cavite

THE CLERK OF COURT


MTC
Bacoor City, Cavite

EXPLANATION

Considering the non-litigious nature of the


motion, please take notice that the same will be
submitted for the consideration and approval of the
Honorable Court immediately upon receipt hereof,
without further oral arguments and without
appearance.

The filing and service of the foregoing is served


via registered mail due to the absence of manpower
to effect personal filing and service and due to the
distance involved and time constraints.

ELEAD GADDIEL S. ALBUERO


REPUBLIC OF THE PHILIPPINES)
Bacoor City, Cavite )S.S.
x------------------------------x

AFFIDAVIT OF SERVICE

I, John K. Wick, of legal age, single, and a


resident of The Continental Condominium, Buck
Estate, Bacoor City, Cavite Philippines, after
having been duly sworn in accordance with law, hereby
depose and say:

1. That I am a Legal Aide of the Saliendra Law


Office with office address at 66th floor,
Targaryen Tower, 2119 Recto Ave., Sampaloc
1015 Manila, Philippines;

2. That in my aforementioned capacity, I had


personally served a copy of the Comment in the
case entitled "Jones Paul Vargas vs. Rommarie
Angeli Dela Rosa docketed as Civil Case No.
6969 to the office of plaintiff’s Counsel of
Record, Atty. Hodor Sammy S. Enriquez, with
address at ERQZ Law Offices 425 Rizal Street
Kawit, Cavite by registered mail with return
card under Registry Receipt No. 9303759307811.

IN WITNESS WHEREOF, I have hereunto set my hand


this 15th day of May 2019 in Bacoor City, Cavite,
Philippines.

John K. Wick
Affiant

SUBSCRIBED AND SWORN TO before me this 15th day


of May 2019 in Bacoor City, Cavite, after the affiant
appeared before me whom I personally know and who
exhibited his Passport GG5876, issued on 01 September
2017 in Manila.

MARCUS GIDEON D. SUKAMULJO


Notary Public for Bacoor
456 Crescendo Building
Molino I, Bacoor
Commission Serial 17362
Until December 31, 2020
Roll of Attorney 77777
PTR 76548; 5-6-18; Manila
IBP 999999; 5-6-18; Manila

Doc. No. 11;


Page No. 9;
Book No. I;
Series of 2019.

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