Está en la página 1de 4

REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION REGIONAL TRIAL COURT, BRANCH 12 QUEZON CITY MICHAEL ROMERO,

Plaintiff, Civil Cases No. 5501 -versusMARIO DINGLASAN, Defendant. x------------------------------x MARIO DINGLASAN, Third-Party Plaintiff -versusWINLEY JOY SUPNET Third-Party Defendant THIRD-PARTY COMPLAINT COMES NOW, the Third-Party Plaintiff, through counsel, and unto his Honorable Court, most respectfully avers: 1. That Third-Party Plaintiff is of legal age, Filipino Citizen, with residence at 212 Sta. Maria Street, Pasig City, Metro Manila; 2. That Third-Party Defendant is also of legal age, Filipino Citizen, with residence address at 180 Fitness First Street, Diliman, Quezon, Metro Manila, where he may be served with summons and other processes by this Honorable Court; 3. That the Third-Party Defendant was hired by herein Third-Party Plaintiff as a sub-agent for a Contract of Consignment between the former and the Original Plaintiff. Evidenced by Annex 1. 4. In the course of the business, Third-Party Defendant was allowed to sell subject office equipment amounting to One Million Pesos (Php 1,000,000.00); 5. That after selling said office equipment aforementioned, Third-Party Defendant was not able to remit said amount in spite demand without just and valid cause.

PRAYER WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable Court that, after hearing, judgment be rendered as follows: 1. Ordering the Third-Party Defendant to remit Third-Party Plaintiff for the cost of office equipment sold in the amount of One Million Pesos (Php 1,000,000.00); 2. Ordering the Third-Party Defendant to indemnify the Third-Party Plaintiff for whatever is adjudged against the latter in favour of the said original Plaintiff. Such other relief and remedies as may be deemed just and equitable under the premises are likewise prayed for. Quezon City, August 19, 2013.

PEREZ, PARK, KIM LAW OFFICE Counsel for Defendant Unit 8D, Madison Place, Cubao, Quezon City Contact Number: 419-37-28 Perez.kbiancaetal@gmail.com

By:

ATTY. KATERINA BIANCA C. PEREZ Roll No. 385769 IBP No. 874986/02-14-2012/Quezon City PTR No. 95857639/01-15-2013/Quezon City MCLE: April 22, 2013

Republic of the Philippines ) Quezon City ) S.S.

VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING

I, MICHAEL DINGLASAN, of legal age, Filipino Citizen, single and resident of 212 Sta Maria Street, Pasig City, Metro Manila, after having been duly sworn to in accordance with law do hereby depose and say: 1. That I am the Third-Party Plaintiff in the above-entitled case; 2. That I have caused the preparation of the foregoing Third-Party Complaint and have read the allegations contained therein; 3. The allegations in the said complaint are true and correct to my own knowledge and authentic records; 4. I hereby certify that I have not commenced any other action or or proceeding involving the same issues in the Supreme Court, Court of Appeals, or any other tribunal or agency; 5. That if I should thereafter learned that a similar action or proceedings has been filed or is pending before the Supreme Court, Court of Appeals, or any other tribunal agency, I hereby undertake to report that fact within five (5) days therefrom to the court or agency wherein the original pleading and sworn certification contemplated herein have been filed; 6. I executed this verification/ certification to attest to the truth of the foregoing facts and to comply with the provisions of Adm. Circular No. 04-94 of the Honorable Supreme Court, IN WITNESS WHEREOF, I have hereunto affixed my signature this 19th of August 2013, in the City of Quezon.

MARIO DINGLASAN Affiant

SUBSCRIBED AND SWORN, to before me this 17th day of August, 2013, in the City of Quezon, affiant exhibiting to me his SSS no. 4809375928-5 issued at Quezon City on May 3, 2008.

ATTY. PRINCESS KIM GUARINO Notary Public Commission Expires Dec. 31, 2014 Roll of Attorney No. 483937 IBP No. 12495/2-5-12/Quezon City PTR No. 87494/12-22-11/Quezon City

Doc No. _____ Page No. ____ Book No. ____ Series of 2013

EXPLANATION

Due to lack of manpower and time, the undersigned counsel cannot effect personal service and is constrained to serve a copy of the pleading through registered mail.

MARIA OBBANIA Roll of Attorney No. 14344 IBP No. 12345/2-5-12/Manila PTR No. 87654/12-22-11/Manila

También podría gustarte