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Zabala - Legal Writing Midterm

The document is an affidavit of undertaking submitted by Anderson V. Tan. It states that Tan is assisting his cousin, John Tan, in applying for a passport. Anderson undertakes to be jointly and severally liable for any damage or injury that John may cause to the government or any third party within one year from receiving his passport. Anderson acknowledges that he may be required to present himself before the proper authorities or be subjected to legal action if John fails to comply with the laws and regulations governing passport holders.

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Kin Carillo
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0% found this document useful (0 votes)
132 views13 pages

Zabala - Legal Writing Midterm

The document is an affidavit of undertaking submitted by Anderson V. Tan. It states that Tan is assisting his cousin, John Tan, in applying for a passport. Anderson undertakes to be jointly and severally liable for any damage or injury that John may cause to the government or any third party within one year from receiving his passport. Anderson acknowledges that he may be required to present himself before the proper authorities or be subjected to legal action if John fails to comply with the laws and regulations governing passport holders.

Uploaded by

Kin Carillo
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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Republic of the Philippines )

City of Naga ) S.S.

AFFIDAVIT OF LOSS

I, Stephen A. Curry, of legal age, Filipino, single, with residence and postal address at 11 th
Street, Sta. Cruz, Naga City after having been sworn to in accordance with law do hereby depose and
say:

That I was issued a Professional Identification Card with the license number of 101993 by the
Professional Regulatory Commission in Legazpi City, Albay;

That last 17 November 2021 at around 3 o’clock in the afternoon, I was at Jollibee at SM City
Naga, CBD II, Brgy. Triangulo, Naga City;

That after eating, I left the abovementioned fast-food restaurant after, soon after I noticed
that my card holder is missing;

That after noticing it, I immediately went back to the aforesaid fast-food restaurant and
informed the staffs that I left my black card holder;

That the above-mentioned black card holder of mine was nowhere to be found inside my bag
along with its contents;

That I tried looking for it and despite diligent effort to locate it the same prove futile;

That as a consequence of such, I endeavored to have the said incident reported and have it
recorded before Police Station 5 of Naga City.

That I am executing this affidavit to attest to the truth of the foregoing statements and for the
purpose requesting for a reissuance of my Professional Identification Card before the PRC of Legazpi
City, Albay, and for whatever legal purpose this may serve.

Further affiant sayeth naught.

IN WITNESS WHEREOF, I have hereunto set my hand this November 12, 2021 at Naga City,
Philippines.

STEPHEN A. CURRY
Affiant

SUBSCRIBED AND SWORN to before me this _______________ at Naga City, Philippines.


Affiant exhibiting to me his Driver’s License with No. E05-11-101057.

NOTARY PUBLIC

Doc. No. ______;


Page No. ______; ATTY. QUINN VLADIMIR C. ZABALA
Book No.______; Attorney-at-law
Series of 2021.
Republic of the Philippines )
Municipality of Daet ) S.S.

AFFIDAVIT OF LOSS

I, DRAYMOND I. GREEN, of legal age, Filipino, married, with residence and postal address at
Barangay 3, Daet, Camarines Norte after having been sworn to in accordance with law do hereby
depose and say:

That I am the Owner/Proprietor of STARK Transport and Service with principal business
address at Vinzons Ave., Daet, Camarines Sur;

That as such, I am the custodian of all the papers, documents, records and original Official
Receipts (OR) and Certificate of Registration (CR) of the motor vehicles, more particularly:

Make/Model : 2004 Nissan Sunny


Plate No. : 111419
Engine No. : 9BN90-310335
Chassis No. : RGHN90109
MV File No. : 0301-00000007136

That last October 2021, our office was caught fire, including our office in Vinzons Ave., Daet,
Camarines Norte, where I keep my files and documents including my ORs and CRs of my motor
vehicles;

That as a result of which majority of my files and documents were damage, thus, the office
had to move our center of operations at Gov. Panotes Ave, Daet, Camarines Norte;

That last 22 October 2021, I checked the files of what was left to look for the original OR and
CR of the aforementioned motor vehicle in our office but the same presumably destroyed;

That despite diligent effort to locate it the same prove futile;

That I am executing this affidavit to attest to the truth of the foregoing statements and for the
purpose of requesting for the reissuance of the OR and CR of the abovementioned motor vehicle
from the Land Transportation Office (LTO), and for whatever legal purpose this may serve.

Further affiant sayeth naught.

IN WITNESS WHEREOF, I have hereunto set my hand this 24 November 2021 at Daet,
Camarines Norte, Philippines.

DRAYMOND I. GREEN
Affiant

SUBSCRIBED AND SWORN to before me this 24 November 2021 at Daet, Camarines Norte,
Philippines. Affiant exhibiting to me his PRC Identification card No. 101110.

NOTARY PUBLIC

Doc. No. ______;


Page No.______; ATTY. QUINN VLADIMIR C. ZABALA
Book No.______; Attorney-at-law
Series of 2021.
Republic of the Philippines )
City of Naga ) S.S.

JOINT AFFIDAVIT OF TWO DISINTERESTED PERSONS

We, STEPHEN SMITH CURRY and HEAVEN ISAIAH CRUZ both of legal age, Filipino citizen, with
residence and postal address at Poblacion II, Talisay, Camarines Sur and Zone 6 San Agustin, Canaman,
Camarines Sur respectively, under oath do hereby depose and say:

1. That we both personally know Mr. DENNIS P. RODMAN and Mrs. ELECTRA G. RODMAN of
Brgy 2, Daet, Camarines Norte;

2. That we know that based on our personal knowledge that Mr. DENNIS P. RODMAN and Mrs.
ELECTRA G. RODMAN got married on 13 October 2021 at the St. John the Baptist Church in
Barangay 2, Daet, Camarines Norte, and was officiated by Rev. Father Steve Kerr;

3. That the fact of their marriage was not immediately filed and registered in the Office of the
Civil Registry of Daet due to the couple’s inadvertence and the fact that they prioritize to
attend to an urgent matter which was a medical emergency of their child.

4. Thar we personally know the foregoing facts because we were present during the marriage
ceremony and we are long-time friends with Mr. DENNIS P. RODMAN and Mrs. ELECTRA G.
RODMAN.

5. That we are not related to the couple Mr. DENNIS P. RODMAN and Mrs. ELECTRA G.
RODMAN either by affinity or consanguinity and has no interest in whatever this affidavit
could be use either directly or indirectly.

6. That we execute this Joint Affidavit to attest to the truthfulness of the foregoing statement
and to support the application for delayed registration of marriage of Mr. DENNIS P.
RODMAN and Mrs. ELECTRA G. RODMAN with the Office of the Civil Registry of Daet, and
for whatever legal purpose this affidavit may serve.

IN WITNESS WHEREOF, we have hereunto affix our signature this 24 November 2021, at Daet,
Camarines Norte, Philippines.

STEPHEN SMITH CURRY HEAVEN ISAIAH CRUZ


Affiant Affiant

SUBSCRIBED AND SWORN to before me this 24 November 2021 at Naga City, Philippines,
affiants personally known to me and exhibiting to me their DOH ID with No. 176666 and PRC ID with
No. 10111, respectively.

NOTARY PUBLIC

Doc. No. ______;


Page No. ______;
Book No.______; ATTY. QUINN VLADIMIR C. ZABALA
Series of 2021. Attorney-at-law
Republic of the Philippines )
City of Naga ) S.S.

AFFIDAVIT
(One and the Same Person)

I, BARRY S. ALLEN, Filipino, of legal age, married, and with residence and postal address
at 1st Street, Barangay Sta, Cruz, Naga City, after having been sworn to in accordance with law, do
hereby depose and state:

1. I am known by the name “BARRY SMITH ALLEN” and have used the same in my
personal and official records and interactions as shown by the following (a copy of which
is hereto attached as Annex “A”):

PRC License

2. My name was recorded on the following as “BARRY SMITH PEREZ” (a copy of which
is hereto attached as Annex “B”):

Birth Certificate registered at the Civil Registry in Naga City.

3. Both the names “BARRY SMITH ALLEN” and “BARRY SMITH PEREZ” refer to
one and the same person, the Affiant.

4.

That I am executing this Affidavit of One and the Same Person to attest to the truth of the
foregoing statements and for whatever legal purpose this may serve.

Further affiant sayeth naught.

IN WITNESS WHEREOF, I have hereunto set my hand this 24th day of November 2021 at
Naga City, Philippines.

BARRY SMITH ALLEN


Affiant

SUBSCRIBED AND SWORN to before me this 24th day of November 2021 at Naga City,
Philippines. Affiant exhibiting to me her PRC ID License 100011.

NOTARY PUBLIC

Doc. No. ______;


Page No. ______;
Book No.______; ATTY. QUINN VLADIMIR C. ZABALA
Series of 2021. Attorney-at-law
Republic of the Philippines )
Municipality of Daet ) S.S.

AFFIDAVIT OF UNDERTAKING

I, ANDERSON V. TAN, of legal age, Filipino, single, presently residing at Barangay V, Daet,
Camarines Norte after having, been duly sworn to in accordance with law, do hereby depose and
state that:

1. I am an applicant for this CY 2021 – 2022 PO1/ Lateral Entry Program (Line/ Technical Officers)
recruitment program;

2. I am a graduate of Bachelor of Science in Psychology and holder of Professional eligibility;

3. I was born on October 13, 1993 as appearing in my PSA Birth Certificate, and that I am hereby
notified that my declared birth date indicated herein shall become incontestable in so far as
my service in the PNP is concerned after the lapse of six (6) months from the effectivity of my
appointment;

4. That in the event that I will fill a petition to alter or correct entries in my birth records before
any court or the CSC, I hereby undertake to first inform the DPRM before filing the same; and

5. That I am aware that any misrepresentation, omission, or misdeclaration of my birth date


committed during the initial recruitment/ appointment process, or finding that I entered the
service below the minimum or above the maximum allowable age at the time of my
appointment, without the necessary age waiver shall be a ground for the filing of an
administrative case/institution of termination proceedings for dishonesty, as applicable, as
well as the filing of criminal charges for perjury.

6. Further, affiant sayeth naught.

IN WITNESS WHEREOF, I have hereunto set my hand this 24 November 2021, at Daet,
Camarines Norte

ANDERSON V. TAN
Affiant

SUBSCRIBED AND SWORN to before me this 24 November 2021, at Daet, Camarines Norte,
affiant exhibiting to me his Driver’s License ID with No. N11-45-77777.

NOTARY PUBLIC

Doc. No. _______;


Page No._______;
Book No._______; ATTY. QUINN VLADIMIR C. ZABALA
Series of 2021 Attorney-at-law
Republic of the Philippines )
City of Naga ) S.S.

JOINT AFFIDAVIT OF COHABITATION

I/We, ROBERT YUZON and MICHELLE TIU, both Filipino, of legal age, with residence
and postal address at Purok 3, Barangay Calintaan, Talisay, Camarines Norte after having been duly
sworn to in accordance with law, do hereby depose and state;

That we voluntarily cohabited with each other and deported ourselves as husband and wife
without the benefit of marriage for more than five (5) years now from 2016 to present at Angeles City
and Talisay, Camarines Norte;

That we have no legal impediments to marry each other and was never forced to live with each
other either by means of threat, violence and/or intimidation;

That because of our love and affection with each other our act of cohabiting is voluntary and
not against our will;

That there are no other persons related to us either by consanguinity or affinity who have forced
us to cohabit with each other;

That out of the said relationship we begot one child in the name of Romiel Yvan T. Yuzon
who was born on January 1, 2018 at Angeles City, Pampanga was registered respectively in the Local
Civil Registry of Talisay, Camarines Norte;

That we are executing this affidavit to attest to the truth of the foregoing statements and for the
purpose of complying with the provisions of Art. 34 of the new Family Code of the Philippines which
substantially provides that: “No marriage license is necessary for a man and a woman who have lived
together as husband and wife for at least five (5) years and without any legal impediment to marry
each other.”

IN WITNESS WHEREOF, We have hereunto affixed our signatures this __________ at


Naga City, Philippines

ROBERT YUZON MICHELLE TIU


Affiant Affiant

SUBSCRIBED AND SWORN to before me this __________ at Talisay, Camarines Norte,


Philippines by Robert V. Yuzon with his PRC ID with No. 11111 and Michelle D. Tiu with her SSS
ID No. 01-1111111-11.

Notary Public

Doc. No. ______;


Page No. ______;
Book No.______;
ATTY. QUINN VLADIMIR C. ZABALA
Series of 2021.
Attorney-at-law
Republic of the Philippines )
City of Naga ) S.S.

AFFIDAVIT OF WARRANTY

I, TONY J. ANGELES, of legal age, married, presently residing at Purok 4, Brgy, Bactas, Basud,
Camarines Norte after having been duly sworn to in accordance with law hereby depose and say:

1. That I am the registered and lawful owner of a certain motor vehicle described as follows:

MAKE : Honda
PLATE NO. : 5555EE
CHASSIS NO. : MMDMD67888
ENGINE NO. : YUMMSSS9800
MV FILE NO. : 6666-0000000000

2. That I am presently applying for a duplicate copy of the aforesaid motor vehicle with the
Land Transportation Office, Daet, Camarines Norte;

3. That the fact of purchase is evidence by the Sales Invoice No. 999999 dated July 21, 2021
whereby Stark Corporation is the seller and I am the buyer;

4. That in my capacity as the buyer/owner, I hereby unconditionally warrant the absolute


title and ownership over the above-described motor vehicle and I hereby declare that the
same is free from any liens, suits, claims or encumbrances of whatsoever or any matter
which may prove adverse thereto;

5. That I hereby release the Land Transportation Office, its Officials, Staff and Personnel
from any suits, claims or liabilities may arise from the approval of the said application for
motor vehicle Registration or any process or matter pertinent thereto, and in the event
of any Suit, claim or liability, I hereby undertake to defend such title, as well as assume
and satisfy any and all such suits or claims resulting therefrom, without cost, charge or
liability whatsoever accruing to the land Transportation Office, its Official, Staff and/or
Personnel;

6. That I am executing this affidavit to attest to the truth of the foregoing facts, to warrant
the title and ownership of the aforementioned motor vehicle, and for whatever legal
intent and purpose this may serve.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 24 November 2021 at Daet,
Camarines Norte

TONY J. ANGELES
Affiant

SUBSCRIBED AND SWORN to before me this 24 November 2021 in the Municipality of Daet,
Camarines Norte by TONY J. ANGELES exhibiting to me his Driver’s License I.D. with No. E05-5555555

Notary Public
Doc. No. ______;
Page No. ______;
Book No.______; ATTY. QUINN VLADIMIR C. ZABALA
Series of 2021. Attorney-at-law
Republic of the Philippines )
City of Naga ) S.S.

AFFIDAVIT OF LATE REGISTRATION

I, ROUX C. PADILLA, of legal age, single a resident of Poblacion 2, Mercedes, Camarines


Norte after having been duly sworn to in accordance with law, hereby depose and say:

That I am the father of ROJINN T. PADILLA;

That right after his birth until today, I was not able to register the birth and apply for a
Philippine Passport for my said son due to a mere inadvertence;

That I am executing this affidavit to attest to the truth and veracity of the foregoing statements,
and to support the registration of birth of JETHRO B. ASETRE and for whatever legal purpose this
may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 24 November 2021 at Daet,
Camarines Norte

ROUX C. PADILLA
Affiant

SUBSCRIBED AND SWORN to before me this 24 November 2021 at Naga City, Philippines.
Affiant exhibiting to me her PRC ID License with No. 100111

Notary Public

Doc. No. ______; ATTY. QUINN VLADIMIR C. ZABALA


Page No. ______; Attorney-at-law
Book No.______;
Series of 2021.
Republic of the Philippines )
City of Naga ) S.S.

JOINT AFFIDAVIT OF PARENTAL CONSENT

I/We, ROUX C. PADILLA and KRIS T. PADILLA, both of legal age, Filipino citizens with
residence and postal address at Poblacion 2, Mercedes, Camarines Norte, after having been duly
sworn to in accordance with law hereby depose and state:

That we are the legitimate parents of Rojinn T. Padilla, who was born on September 1, 2002
at Naga City;

That our son, Rojinn T. Padilla, is already 18 years old, single and who is about to contract
marriage with his long-time girlfriend, Ms. Hillary R. Guzman;

That there is/are no legal impediment/s that exist between them why they should not be
married;

That by this Affidavit, we are giving our favorable consent to the intended marriage of our
son Rojinn T. Padilla with Ms. Hillary R. Guzman;

That we are giving our consent for them to be Legally married;

That we are executing this affidavit to attest to the truth of the foregoing statements and for
whatever legal purpose this may serve.

IN WITNESS WHEREOF, we have here affixed our signatures this 24th day of November, 2021
at Daet, Camarines Norte, Philippines.

ROUX C. PADILLA KRIS T. PADILLA


Affiant Affiant

SUBSCRIBED AND SWORN to before me this 24th day of November 2021 at Daet, Camarines
Norte, Philippines. Affiants exhibiting to me their Driver’s License No. 444444444 and PRC ID License
No. 33333333 respectively.

Notary Public

Doc. No. ______;


Page No. ______;
Book No.______; ATTY. QUINN VLADIMIR C. ZABALA
Series of 2021. Attorney-at-law
Republic of the Philippines )
City of Naga ) S.S.

AFFIDAVIT OF ADJOINING OWNERS

That We, ROUX C. PADILLA and RICKY T. ESQUETA, all Filipino, all legal ages and
resident of Purok 3, Itomang, Talisay, Camarines Norte, Philippines, after having sworn to in
accordance with law hereby depose and state.

That We personally known John D. Regalado;

That he is the true lawful owner of parcel of the land situated at Purok 1, Itomang, Talisay,
Camarines Norte;

That the said parcel of land was surveyed by Geodetic Engineer Anton G. Galvez dated
September 13, 2021 and found out that the exact area was Five Hundred Twenty-Nine Square Meters
(529 square meters).

That we are the owners of the land adjoining in front and at the back of his property/ties and
that there is no conflict or legal encumbrances between/among us with respect to said exact
boundaries;

That we executing this affidavit to attest the truth that the exact area of the land is Five Hundred
Twenty-Nine Square Meters (529 square meters) as per plan attached there to for taxation purposes.

Further Affiant sayeth naught.

IN WITNESS WHEREOF, I have here unto set my hand this 24th day of November 2021 at
Daet, Camarines Norte, Philippines.

ROUX C. PADILLA RICKY T. ESQUETA


Affiant Affiant

SUBSCRIBED AND SWORN to before me this 24th day of November 2021 at Daet,
Camarines Norte, Philippines. Affiant exhibiting to me their PRC ID License No. 455555 and Driver’s
License No. 55555555

Notary Public

Doc. No. 1;
Page No. 1; ATTY. QUINN VLADIMIR C. ZABALA
Book No. 256; Attorney-at-law
Series of 2021.
Republic of the Philippines )
City of Naga ) S.S.

AFFIDAVIT OF AUTHENTICITY

I, ROBERT A. CRUZ, of legal age, married, a resident of Purok 2 Barangay 2, Daet, Camarines
Norte, after having been duly sworn to in accordance with law, hereby depose and say:

That I am an applicant for work abroad and I secured the following documents for
authentication:

a. RELEASE LETTER: dated November 10, 2021 issued in my name by Wayne Corp., Gotham
City, USA duly signed by Bruce Wayne, Director, Human Resource Department;

b. EMPLOYMENT CERTIFICATE: dated March 30, 2018 issued in my name by Stark Technologies
Inc. H/R Division, Tokyo, Japan, duly signed by Hinata Kirishima, Assistant President, Human Resource
Division;

c. CERTIFICATION: dated December 21, 2012 issued in my name by ACME Technology Inc.
signed by Rica Heneral, Human Resources Manager;

That all the documents herein presented were issued by the foregoing Companies, duly signed
by each and every custodian thereof;

That the issuance thereof of the said documents were in consequence of my employment
therein.

That I am executing this affidavit to prove the foregoing facts in order to support my request
for authentication thereof at the DEPARTMENT OF FOREIGN AFFAIRS (DFA) and by concerned
authorities and for any other legal purpose this may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 24th of November 2021 at Daet,
Camarines Norte, Philippines.

ROBERT A. CRUZ
Affiant

SUBSCRIBED AND SWORN to before me this 24th of November 2021 at Daet, Camarines
Norte, Philippines by Robert A. Cruz with his Driver’s License with No. E05-444-5555555.

Notary Public
Doc. No. ______;
Page No. ______;
Book No.______; ATTY. QUINN VLADIMIR C. ZABALA
Series of 2021. Attorney-at-law
NOTICE OF HEARING

QUINN VLADIMIR C. ZABALA


Counsel for Complainant
Daet, Camarines Norte

Dear Ma’am,

Greetings!

Please take notice that on Friday, December 3, 2021, at the Daet


Regional Trial Court Branch 38 at 10 o’clock a.m., or as soon thereafter
as counsel can be heard, the undersigned will submit the foregoing
motion for the approval of the court.

Daet, Camarines Norte, Philippines. November 29, 2021

JOHN CRISTIAN F. CRUZ


Counsel for the Respondent
Roll No. 11111111
PTR No. 11111/11-11-11/Daet
IBP No. 222222/22-22-22/Daet
MCLE No. 333333/33-33-33/Daet
PERMANENT PROTECTION ORDER (R.A. 9262)
(Motion to Quash Information)

Republic of the Philippines


National Capital Judicial Region
REGIONAL TRIAL COURT
Naga City, Branch VII

The People of the Philippines,


Plaintiff,

Criminal Case No. 11111


- versus - For: Protection Order
(Sec.8, R.A.9262)

John Santos,
Accused.
x------------------------x
MOTION TO QUASH

Accused JOHN SANTOS, through the undersigned counsel, and


respectfully alleges:

1. That he is the accused in the above-entitled case of the crime of


Violation of RA 9262 committed against May De los Santos;

2. That the act held as criminal is a defensive act of the respondent


thus doesn’t hold liable whatsoever;

3. That the facts charged do not constitute an offense as previously


expounded in the other pleadings related to this case.

WHEREFORE, it is respectfully prayed that the complaint and


information filed in this case be quashed, with costs de oficio.

November 24, 2021. Daet, Camarines Norte.

Respectfully submitted,

QUINN VLADIMIR C. ZABALA


Counsel for the Respondent
Roll No. 11111111
PTR No. 11111/11-11-11/Daet
IBP No. 222222/22-22-22/Daet
MCLE No. 333333/33-33-33/Daet

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