Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

MANIFESTATION AND MOTION TO ISSUE CERTIFICATE OF FULL COMPLIANCE WITH CIVIL OBLIGATION

Accused by counsel, to this Honorable Court respectfully states:

On 10 March 2012, herein parties submitted to this Honorable Court a Motion to Approve Compromise Agreement and To Render Judgment on the Basis Thereof the pertinent portion of which are, to wit:

For the settlement of the civil aspect of the above-entitled case, First Party hereby agrees to the following sum of money as the total amount of civil liability of the Second Party, to wit:

Php 200,000.00 - the total amount of money allegedly stolen by the Second Party

Php 50,000.00 - Attorney’s Fee

The Second Party, upon signing hereof, hereby agrees to pay the First Party and tenders the sum: Php 100,000.00 as down payment of the aforesaid amount Php 50,000.00 as and in payment for the said Attorney’s fee.

The First Party hereby acknowledged receipt of the total sum of Php 100,000.00 from the second party on the date of signing this instrument to be applied for the purpose aforesaid;

The Second Party hereby agrees and undertakes to pay the remaining balance of Php 100,000.00 in four (4) equal monthly installments at Php 100,000.00 per month. The schedule of payments are as follows:

1st installment Php 25,000.00 – payable on or befor e April 9, 2011

2nd installment Php 25,000.00 – payable on or befor e May 9, 2011

3rd installment Php 25,000.00 – payable on or befor e June 9, 2011

4th installment Php 25,000.00 – payable on or befor e July 9, 2011

It is hereby agreed that the payment of the foregoing four (4) installments shall be covered by four (4) postdated checks;

The failure and/or refusal of the Second Party to replace with cash any and /or all of the above postdated check/s, if the same is/are dishonored upon presentment for payment on its due date, after five banking days from notice shall render the entire remaining obligation immediately due and demandable;

In the latter case, Second Party hereby agree that an Order of the Court for the issuance of the writ of execution shall be issued outright upon motion for the satisfaction of his remaining civil obligation;

The parties herein agree that the foregoing Compromise Agreement shall be submitted to the Honorable Court for approval.

On 09 July 2012, accused has fully complied with his full obligation by paying the total amount of TWENTY FIVE THOUSAND PESOS (Php 25,000.00) in accordance with the said Agreement.

To support its claim, the undersigned attached the bank certification, photocopies of the encashed checks and application form of BPI Managers Checks in favor of private prosecutor Atty. Jeffrey Paril Into and private complainant Og Sabado which are hereto attached as Annexes “A” to A-1,B and C respectively.

In view of the foregoing, accused prays for the issuance of the certificate of full compliance of the civil obligation and permanent dismissal of the above-entitled criminal case.

City of Manila, for Imus City, 25 July 2012.

BAQUIRAN, CORONADO & RICAFRANCA Counsel for Accused

Jasper Sol Cruz 2nd Floor, RCVJ Building,

Don P. Campa Avenue, Barrio Uno,

2662 Dasmarinas City, Cavite

by:

____________________________________________

Roll No. __________

IBP No. __________/ __________/__________

PTR No. __________/ __________/__________

MCLE Compliance No. __________

Notice of Hearing

PROSECUTOR JACK MIOF

Office of the City Prosecutor

Imus City, Cavite

CLERK OF COURT

Regional Trial Court

Branch 21, Imus City

ATTY. JEFFREY PARIL

1080 Negros Street, Balic- Balic

Sampaloc, Manila

ATTY. ALEXANDER LIQUIGAN

Unit 3C, De Quiroz Bldg.,

Aguinaldo Highway, Perpetual Village,

Palico III, Imus City, Cavite

Greetings:

Please submit the foregoing Manifestation for the consideration and approval of the Honorable Court immediately upon receipt hereof.

Copy furnished:

PROSECUTOR JACK MIOF

Office of the City Prosecutor

Imus City, Cavite

ATTY. JEFFREY PARIL

1080 Negros Street, Balic- Balic

Sampaloc, Manila

ATTY. ALEXANDER LIQUIGAN

Unit 3C, De Quiroz Bldg.,

Aguinaldo Highway, Perpetual Village,

Palico III, Imus City, Cavite

Explanation

The pleading is being filed, with copy furnished the other parties, by private couriers due to the distance of the undersigned from the Court and the said parties, making personal service thereof not practicable.

RAPHAEL ENRIQUE V. CORONADO