Republic of the Philippines

REGIONAL TRIAL COURT

1st Judicial Region
Branch 28
San Fernando City, La Union

Mona Papa, Plaintiff, CIVIL CASE No. 1

- versus FOR: Damages for death, Loss

of earning capacity, Moral
damages and Attorneys Fees.
Nestor Pol,
Hermogenes Yapit,
Spouses Angelito and
Zenaida Alviar and
Rico Nacario,
Defendants.
x- - - - - - - - - - - - - - - - - -
-----x

POSITION PAPER

UNTO THIS HONORABLE COURT, plaintiff, through counsel, in above-

captioned case, submit most respectfully, the foregoing POSITION PAPER for consideration, to
wit:
PREFATORY

Done this 15th day of November 2017, San Fernando City, La

Union.

For the Plaintif

By

ATTY. MARJORIE S. PADILLA

PADILLA Law Firm, NSEO Building,
 Poro Point, San Fernando City, La Union
PTR No. 12345678 5-20-2017 San Fernando City, La Union
IBP No. 911117 5-20-2017 San Fernando City, La Union
Roll No. 89994
MCLE Ex. No. 111-000748 1-13-2017

Republic of the Philippines )

San Fernando City, La Union )s.s
x- - - - - - - - - - - - - - - - - - - - - - - -x

VERIFICATION AND CERTIFICATION AGAINST FORUM-

SHOPPING

I Mona Papa, Filipino, of legal age, married and a resident

of residing at 07 Ortega St. San Fernando City, La Union, after
having been duly sworn to in accordance with law depose and
say, THAT:

1. I am a plaintif in the above-stated case;

2. I caused the preparation of the foregoing complaint;
3. I have read the contents thereof and the facts stated
therein are true and correct of my personal knowledge and/or on
the basis of copies of documents and records in my possession;
4. I have not commenced any other action or proceeding
involving the same issues in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;
5. To the best of my knowledge and belief, no such action or
proceeding is pending in the Supreme Court, the Court of Appeals,
or any other tribunal or agency;
6. If I should thereafter learn that a similar action or
proceeding has been filed or is pending before the Supreme
Court, the Court of Appeals, or any other tribunal or agency, I
undertake to report that fact within five (5) days there from to this
Honorable Court.
 Mona Papa
Affiant

SUBSCRIBED AND SWORN to before me this 15th day of

October 2017, by Mona Papa, who exhibited to me her Voters ID
No. 12345 issued at San Fernando City, La Union, Philippines on
May 12, 2016.

WITNESS MY HAND AND SEAL.

Doc. No. 0001;

Page No. 003;
Book No. 001;
Series of 2017.