Checklist
Checklist
Checklist
REVIEWER
1. JURAT
- PLEADING
2. ACKNOWLEDGEMENT
- CONTRACTS
3. AFFIRMATION OR OATH
4. AFFIDAVIT OF LOSS
5. COMPLAINT
6. SAMPLE CAPTIONS AND TITLES
7. COMBINED VERIFICATION WITH VERTIFICATE OF NON-FORUM SHOPPING
8. NOTICE OF HEARING
9. COMPLAINT BASED ON ACTIONABLE DOCUMENT
10. MOTION TO DISMISS
11. MOTION FOR BILL OF PARTICULARS
12. NOTICE OF APPEAL OR RECORD ON APPEAL
13. EXTRAJUDICIAL SETTLEMENT OF ESTATE OF A DECEASED PERSON
14. PROBATE OF WILL
15. PETITION FOR GUARDIANSHIP OF MINOR
16. CRIMINAL INFORMATION FOR QUALIFIED THEFT
17. CERTIFICATE OF PRELIMINARY INVESTIGATION
18. ARTICLES OF INCORPORATION
19. SALE OF REGISTERED LAND
20. CERTIFICATION OF BOARD RESOLUTION BY CORPORATE SECRETARY
21. COMPLAINT FOR RESCISSION OF CONTRACT
22. PROOF OF SERVICE
23. DEMAND LETTER
24. MOTION TO DECLARE IN DEFAULT WITH NOTICE OF HEARING
25. PROMISORY NOTE
26. JUDICIAL AFFIDAVIT
27. DACION EN PAGO
28. PRAYER
29. CONTRACT
30. SHAREHOLDERS AGREEMENT
31. MINUTES OF MEETING
32. CONTRACT (ATTY.)
This Deed of Absolute Sale executed on May 1, 2011 in Makati City by and between:
Maisie Karissa Zabala Filipino, of legal age, married, and resident of 2938 Kuratong Street, Makati
City as VENDOR.
and
Kevin Jonathan Lumbre Corporation, a Philippine company with a business address in Makunat Street,
Makati City, represented by its President, Kevin Jonathan Lumbre as VENDEE.
WITNESSETH THAT:
WHEREAS, the property subject of this instrument is a parcel of land located in No. 99 Jijiwap St. Makati City
with a total area of 69,000 sqm and covered by TCT No. 6969.
WHEREAS, the VENDORS are registered owners of the parcel of land as described in TCT No. 6969.
WHEREAS, the VENDEE has expressed its desire to purchase the said property for an aggregate purchase price
of P250 million and the same has been accepted by the VENDORS.
NOW, WHEREFORE, premises considered, especially the P250 million purchase price, the VENDORS hereby
sell, transfer and convey the subject parcel of land to the VENDEE, its successors-in-interest and assigns.
The VENDORS further warrant that they are the absolute owner of the property and that the title is free from any
claims, liens and encumbrances.
IN WITNESS WHEREOF, the parties have signed this agreement on the date and place abovementioned.
BEFORE ME, a Notary Public for and in the City of Makati, the parties acknowledge that the above instruments
was their true and voluntary act and deed. They have exhibited competent proof of identity to wit:
The Deed of Absolute Sale consists of 2 pages including the page wherein this acknowledgement is written and
has been signed by the parties on each page in the left hand corner.
WITNESS MY HAND AND SEAL, this 3rd day of May, 2011 in Makati City
Doc No. 32
Page No. 31
Book No. 12
Series of 2011
SECRETARY’S CERTIFICATE
Republic of the Philippines)
City of Makati ) S. S
SECRETARY’S CERTIFICATE
I, Sara Avillon, Filipino of Legal age, with office address in Samaguitta Street, Makati City, after having been
sworn to in accordance to the law do hereby state that:
1. I am the Corporate Secretary of Kevin Jonathan Lumbre Corporation, a Philippine Corporation with
office address at Makunat Street, Makati City;
2. I am the custodian of the books and records of the said company, including the Minutes of the Meeting
and Board Resolutions;
3. During the regular meeting of the Board of Directors on April 20, 2011, wherein a quorum was present,
the following resolution has been unanimously approved and adopted:
4. The said resolution have not been modified, altered, repealed or otherwise revoked and is still in force
and valid.
5. I am executing this instrument for whatever purpose it may serve
TO THE TRUTH OF THE FOREGOING, I have signed this document on May 15, 2011 in Makati City.
Doc No. 32
Page No. 31
Book No. 12
Series of 2011
COMPLAINT FOR RESCISSION OF CONTRACT
I, Kevin Jonathan Lumbre, Filipino, of legal age, with office address at Makunat Street Makati City do hereby
state that:
1. I am the President of the plaintiff corporation and I am authorized to commence this action through
Board Resolution No. 17, dated June 1, 2011. (Annex B)
2. I have caused the preparation of the complaint above.
3. I have read and understood the contents of the same and attest that they are true based on my personal
knowledge.
4. I have not commenced any other action or claim involving the same issues in any other court, tribunal
or quasi-judicial agency.
5. There are no other case or claim pending involving the same issues.
6. Should I learn of any other pending case, I would report it to this Honorable Court within 5 days
therefrom.
SUBSCRIBED AND SWORN TO BEFORE ME, this 19th of June 2011 in Makati City. Affiant presenting his
Driver’s License No 3243, expiry on December 2020
Doc No. 32
Page No. 31
Book No. 12
Series of 2011
MOTION TO DISMISS
Republic of the Philippines
Regional Trial Court
National Capital Judicial Region
Makati City Branch 1
Kevin Jonathan Lumbre Corporation
Plaintiff
-versus - Civil Case No. 3423
For: Rescission of a Contract of Sale
Maisie Karissa Zabala
Defendant
x-----------------------------------------------------------------------------------x
MOTION TO DISMISS
Defendants, through the undersigned counsel and to this Honorable Court respectfully state that:
1. Defendants is of legal age, Filipino and a resident of 2938 Kuratong Street, Makati City;
2. Plaintiff is a Philippine Corporation with an office address in Makunat Street, Makati City;
3. In the complaint filed by the plaintiffs there was a failure to state all the elements of fraudulent
representation;
4. There was no specific ac of fraud averred
5. Under the Rules of Court, the failure to State a cause of action is one of the grounds for the dismissal of
the same
WHEREFORE, it respectfully prayed that the Honorable Court dismiss the complaint for the failure to state a
cause of action and other just and equitable reliefs also prayed .
(sgd.)
Minerva Timbang
Counsel for Defendant
No. 33 Ayala Avenue Makati
City
Roll No. 3432
IBP No. 2342
PTR No. 2132
MCLE Compliance No. 1508
I, Katriona Karaka, messenger of the counsel for defendants personally served the counsel for plaintiff with this
motion to dismiss on June 12, 2011 at its office address in No. 7 Ayala Avenue Makati.
IN WITNESS WHEREOF, I have signed this document on June 13, 2011 in Makati.
Katriona Karaka
Affiant
SUBSRIBED AND SWORN TO BEFORE ME, this 13th day of June in Makati affiant exhibiting his SSS ID
No. 1234-21.
Doc No. 32
Page No. 31
Book No. 12
Series of 2011
INFORMATION WITH THE CERTIFICATE AS TO THE CONDUCT OF PRELIMINARY
INVESTIGATION
Republic of the Philippines
Regional Trial Court
National Capital Judicial Region
Makati City Branch 1
People of the Philippines
Plaintiff
-versus - Criminal Case No. 18-00
For: Qualified Theft
Porky Jefferson
Accused
x-----------------------------------------------------------------------------------x
INFORMATION
The undersigned prosecutor, pursuant to a complaint filed by Loki Koala, hereby accuses and charges the
accused with QUALIFIED THEFT committed as follows:
That on or about May 15,2019 within the territorial jurisdiction of this court, did then and there wilfully and
feloniously took the money entrusted to her worth P10,000 from the cash register, being the cashier in the
complaint store, breaching the trust reposed to her.
CONTRARY TO LAW.
I hereby certify that I have personally conducted the requisite preliminary investigation and personally examined
the witness, finding probable cause to file this information with authority from the City Prosecutor.
SUBSCRIBED AND SWORN TO BEFORE ME this 19th dya of May 2019 in Makati City.
APPROVED BY:
(Sgd) June Lim
City Prosecutor
WITNESSES:
A 21232 Hidalgo St.Makati
B 43 Hidalgo St. Makati
Bail recommended P100,000
AFFIDAVIT OF LOSS
Republic of the Philippines )
AFFIDAVIT OF LOSS
I, Tin Penalosa, Filipino, of legal age, resident of 234 Forbes Park, Taguig City after having been sworn
according to law do hereby state that.
1. I am issued by DFA with Passport No. 1298, which would expire on May 20,2021
2. While I was wondering around Rockwell Makati City, my bag was snatched by another person.
3. My passport was contained in the bag as I was about to go to the airport that same day for my flight to
Quatar.
4. I have diligently searched for my passport but to no avail.
5. I am executing this affidavit for the request for re-issuance of another passport that will file with DFA.
Tin Penalosa
Affiant
SUBSCRIBED AND SWORN TO BEFORE ME, on May 22, 2019 in Makati, affiant exhibiting her driver’s
license no 1234 to expire on June 20,2022
Doc No. 32
Page No. 31
Book No. 12
Series of 2019
CONTENTS OF THE ARTICLES OF CORPORATION
REVISED CORPORATION CODE
All corporations shall file with the Commission articles of incorporation in any of the official languages, duly
signed and acknowledged or authenticated, in such form and manner as may be allowed by the Commission,
containing substantially the following matters, except as otherwise prescribed by this Code or by special law:
(b) The specific purpose or purposes for which the corporation is being formed. Where a corporation has
more than one stated purpose, the articles of incorporation shall indicate the primary purpose and the
secondary purpose or purposes: Provided, That a nonstock corporation may not include a purpose which
would change or contradict its nature as such;
(c) The place where the principal office of the corporation is to be located, which must be within the
Philippines;
(d) The term for which the corporation is to exist, if the corporation has not elected perpetual existence;
(f) The number of directors, which shall not be more than fifteen (15) or the number of trustees which may
be more than fifteen (15);
(g) The names, nationalities, and residence addresses of persons who shall act as directors or trustees until
the first regular directors or trustees are duly elected and qualified in accordance with this Code;
(h) If it be a stock corporation, the amount of its authorized capital stock, number of shares into which it is
divided, the par value of each, names, nationalities, and residence addresses of the original subscribers,
amount subscribed and paid by each on the subscription, and a statement that some or all of the shares
are without par value, if applicable;
(i) If it be a nonstock corporation, the amount of its capital, the names, nationalities, and residence
addresses of the contributors, and amount contributed by each; and
j)Such other matters consistent with law and which the incorporators may deem necessary and
convenient. An arbitration agreement may be provided in the articles of incorporation pursuant to Section 181 of
this Code.
The articles of incorporation and applications for amendments thereto may be filed with the Commission in the
form of an electronic document, in accordance with the Commission’s rules and regulations on electronic filing.
NOTICE OF HEARING
Dear Gentlemen:
The undersigned shall submit the foregoing motion to dismiss for approval and consideration of the
Honorable Court on June 4, 2009 at 10:00 am.
Porky Manchester
Counsel for Plaintiff
PRAYER
WHEREFORE, it is respectfully prayed that the Honorable Court render judgment dismissing the complaint and
granting the counterclaim by ordering the defendant to 1) pay moral damages in the amount of P200,000 and 2)
pay attorney’s fees in the amount of P50,0000
The Plaintiff, by counsel manifests its intention to appeal, as it hereby appeals the decision of the
Honorable Court dated April 15, 2019 assail decision which was served received on April 20,2019.
On April 22, 2019 a Motion for Reconsideration was filed questioning the Assailed Decision. The
Plaintiff received the Honorable Court’s order dated April 24, 2019 denying the Motion for Reconsideration on
April 29,2019. Thus the Notice of Appeal was timely filed. The Plaintiff manifests its intention to appeal to the
Court of Appeals.
Respectfully submitted.
(sgd.)
Luigi Canoneo
Counsel for Plainiff
No. 7 Ayala Avenue Makati City
Roll No. 3432
IBP No. 2342
PTR No. 2132
MCLE Compliance No. 1508
COPY FURNISHED THROUGH PERSONAL SERVICE:
Tony Stark
Counsel for Defendant
No 9 Ayala Avenue Makati
DEED OF EXTRAJUDICIAL SETTLEMENT
Republic of the Philippines)
Makati City ) S. S
The Deed of Extrajudicial Settlement “The Agreement is entered into this day May 25, 2019 at 123
Hidalgo St. Makati City between:
1.
Bugoy Buguyan , Filipino, of legal age, single and with residence at 234 Soy Gardens, Quezon
City
And
2. Manay Buguyan, Filipino of legal age, single and with residence at 123 Sauce Ser, Makati City
WITNESETH that:
WHEREAS, we are the sole heirs of deceased Baratingas Jusmi Buguyan who died on May 1, 2019 at Makati
City. A copy of his death certificate is attached herein as “Annex A”
WHEREAS, Baratingas Jusmi Buguyan died intestate and without any outstanding debts or obligations against
any person or entity.
WHEREAS, Baratingas Jusmi Buguyan is the absolute owner and registered owner of a parcel of land located in
Makati City covered by TCT No 12344 and with a total area of 69 sqm.
WHEREFORE premises considered, pursuant to Rule 74, Section 1 of the Revised Rules of Court, and with full
capacity, we adjudicate into ourselves the above mentioned parcel of land in equal shares.
IN WITNESS WHEREOF, we have affixed our signatures this May 29, 2019 at Makati City .
(sgd) (sgd)
Bugoy Buguyan Manay Buguyan
Republic of the Philippines)
Makati City ) S.S
Acknowledgement
Before me, a Notary Public in Makati City, personally appear
Who are identified by me through competent evidence of identity to be the same persons who presented the
foregoing instrument and acknowledged to me that the signatures in the instrument were voluntarily affixed by
them for the purpose stated therein, and that the instrument represents their free and voluntary act and deed.
Doc No. 32
Page No. 31
Book No. 12
Series of 2019
CONTRACT ** PRINT FILE FROM ATTY.PILARES
JURAT
SUBSCRIBED and sworn to before me, this 19 th day of April 2019 in the City of Makati Jhonny
Dalumping with Passport No. EEB323 issued on September 2,2018 at DFA San Fernando Papangga
Doc No. 32
Page No. 31
Book No. 12
Series of 2019
ACKNOWLEDGEMENT
Republic of the Philippines )
City of Makati ) S.S
BEFORE ME, this 19th day of April 2019 in the City of Makati, Jhonny Dalumping with Passport No.
EEB323 issued on September 2, 2018 at DFA San Fernando Pampanga, known to me to be the same person who
executed the foregoing instrument and acknowledged that the same are their free act and deed.
IN WITNESS WHEREOF, I set unto my hand and seal on the date and place above written
Doc No. 32
Page No. 31
Book No. 12
Series of 2019
DEMAND LETTER
April 9,2019
FINAL DEMAND
Madam:
We write in behalf of our client, Jhonny Dhepp, on the matter of your non-payment of your obligation.
Records disclose that you have an outstanding obligation with our client in the amount of P270,000.00 with
interest at 6% per annum, and despite repeated demands you have failed and continuously fail to pay the
aforesaid amount.
Accordingly, FINAL DEMAND is hereby made upon you to settle the amount of P270,000.00 within three (3)
days from the receipt of this letter. Otherwise we will be constrained to file the necessary legal action against
you to protect the interest of our client.
We trust that you will give this matter your prompt and preferential attention to avoid the expense and
inconvenience of litigation.
Truly yours,
(Sgd.) Atty. Luningnining Garutay
MOTION TO DECLARE DEFENDANT IN DEFAULT
(sgd.)
Luigi Canoneo
Counsel for Plainiff
No. 7 Ayala Avenue Makati City
Roll No. 3432
IBP No. 2342
PTR No. 2132
MCLE Compliance No. 1508
COPY FURNISHED THROUGH PERSONAL SERVICE:
Tony Stark
Counsel for Defendant
No 9 Ayala Avenue Makati
PROMISSORY NOTE
April 9, 2019
P10,000.00
10 days after date, I Potpot Maalam, promise to pay to the order of Maisie Karissa Zabala, the sum of
Ten Thousand Pesos (P10,000.00)
Bato Pick, 22 years old, employed as a businessman, residing at #123, 1 st Street, San Miguel Manila,
after having been duly sworn in accordance with law, hereby dispose and state:
PRELIMINARY STATEMENT
That the person examining me is Atty. Kurutong Baleleng with law office at #123 Sketchy Street,
Makati City. My Judicial affidavit is being taken at the above mentioned place, in the presence of Judith
Makapili and my companions.
That the questions are asked in English language but are translated in Tagalog dialect which I speak and
fully understand and I am giving my answers fully conscious that I do so under oath and I am aware that I may
face criminal liability for false testimony or perjury for false made or given by me.
OFFER OF TESTIMONY
The testimony of the witness Bato Pick is being offered to prove that he is an eyewitness to the crime of
Estafa. He will testify what he saw the day of their transaction with the accused and what later transpired in their
agreement dated July 22, 2018. The witness will identify the accused in open court as the person who committed
the crime.
1. Q:
A:
2. Q:
A:
3. Q:
A:
Manifestation: May I request this honorable court a few words to ponder in the act of the client by mere hiding
this past 4 years constitutes abuse of confidence over my client. The mere fact that he ran and hid from his
obligation shows that the trust entrusted was violated.
IN WITNESS WHEREOF, I have hereunto set my hand this 20 th day of August 2018 at Makati City.
I,Atty.Kurutong Baleleng, of legal age, with office address at #123 Sketchy Street, Makati City, do
hereby certify that:
I propounded question to Bato Pick and faithfully recorded or caused to be recorded the questions I
have asked and the corresponding answers that Bato Pick gave as above stated.
Neither I nor any other person then present or assisting the witness coached the latter regarding his
answers.
IN WITNESS WHEREOF, I have hereunto set my hand this 20 th day of August 2018 at Makati City.
SUBSCRIBED and sworn to before me, this 19 th day of April 2019 in the City of Makati Kuratong
Baleleng with Passport No. EEB323 issued on September 2,2018 at DFA San Fernando Papangga
Doc No. 32
Page No. 31
Book No. 12
Series of 2018
MOTION FOR BILL OF PARTICULARS
Defendant thru counsel and unto this Honorable Court respectfully avers:
1. That the plaintiff’s complaint in its par. 3 alleges
“Maling Akala, borrowed money from me on January 10,2010”
2. That said allegation was insufficient and defective in that it fails to specify the amount
3. That a more definite statement on the matter as above indicated is necessary in order to enable
the defendant to properly prepare his responsive pleading
WHEREFORE, defendant prays that plaintiff be ordered to file a bill of particulars of the facts and acts
constituting the conclusion alleged in the complaint.
NOTICE OF HEARING
Dear Gentlemen:
The undersigned shall submit the foregoing motion to dismiss for approval and consideration of the
Honorable Court on June 4, 2009 at 10:00 am.
I, Katriona Karaka, messenger of the counsel for defendants personally served the counsel for plaintiff with this
motion to dismiss on June 12, 2011 at its office address in No. 7 Ayala Avenue Makati.
IN WITNESS WHEREOF, I have signed this document on June 13, 2011 in Makati.
Katriona Karaka
Affiant
SUBSRIBED AND SWORN TO BEFORE ME, this 13th day of June in Makati affiant exhibiting his SSS ID
No. 1234-21.
Doc No. 32
Page No. 31
Book No. 12
Series of 2019
MINUTES OF MEETING
MARUPOK CORPORATION
Minutes of the Special Meeting of the Board of Directors
Held on 23 August 2017
In Las Piñas City
DIRECTORS PRESENT:
ALSO PRESENT:
RHEA KARUNUNGAN
I. CALL TO ORDER
The Chairman, Allan Peter Cayetano , called the meeting to order and presided over the same. The
Corporate Secretary, Atty. Rhea Karunungan , recorded the minutes of the meeting.
The Corporate Secretary certified that a quorum was present for the transaction of business by the
Board. The directors consented to waive their right to notice of the meeting.
Upon motion duly made and seconded, the Board passed and approved the following resolutions:
“RESOLVED FINALLY, that the foregoing authorities shall remain in full force and
effect and binding on the Corporation until a written notice to the contrary is issued by the
Corporation revoking, amending or otherwise modifying the same;
IV. ADJOURNMENT
There being no other matters to discuss, the meeting was adjourned upon motion duly made and
seconded
CERTIFIED CORRECT:
RHEA KARUNUNGAN
Corporate Secretary
ATTESTED:
Petitioner
4. The petitioner is legally qualified to act as executor and hereby consents to accept said trust;
5. The property left by the decedent consist of real and personal property, the gross value of which
is FIVE MILLION P5,000,000.00;
6. The testator at the time of the execution of the said will was 72 years old, of sound and disposing
mind, and not acting under duress, fraud or undue influence and was in every respect capacitated
to dispose of his estate
7. Petitioner as named executor, moves and prays that letters testamentary be issued to him; that he
is competent to serve as executor and is ready to give a bond as required by the Rules of Court.