XDRepublic of the PhilippinesREGIONAL TRIAL COURT

10th Judicial RegionBranch 18

Cagayan de Oro City

DR. DENNIS GARCES, Civil Case No. 2008-045Plaintiff,

-Versus- For: Accounting andDamages

DR. GRACE SOLERO andDR. MANFRED ANTHONY SOLERO,

Defendants,-------------------------------------------------/

MEMORANDUM FOR THE PLAINTIFF

Plaintiff, by the undersigned counsel to this Honourable Court, most respectfully submits his Memorandum in the above captioned civil case, to wit:

FACTS OF THE CASE

Sometime in December 2006, Plaintiff Dr. Dennis Garces was planning to expand his professional practice as a Dentist. He was then operating as a sole practitioner in his clinic located at UKC Building, Carmen Market, Carmen, Cagayan de Oro City.

To realize this expansion, Plaintiff invited his longtime friend and fellow dentist, Defendant Dr. Grace Solero, who was also practicing as a sole practitioner dentist with a clinic located at the second floor of De Leon Plaza, Yacapin-Velez Streets, Cagayan de Oro city, to form a general professional partnership for the exercise of their profession as dentists.

Plaintiff, having observed that a dental clinic located within a public market is a lucrative business idea, based on his experience in Carmen public market, he suggested to Defendant Grace Solero to put up their partnership dental clinic at Cogon Public Market and found a place at the corner of J.R. Borja and Osmena Streets, Cagayan de Oro City.

For purposes of convenience and registration, the partners agreed to place the name of the partnership in defendant’s Dr. Grace Solero alone. This was because, forming a formal professional partnership requires registration with the Securities and Exchange Commission (SEC) and would entail a lot of paper works and cost.

The dental clinic, after the lease was concluded with Ria Development Corp., was then readied for occupancy. It was Plaintiff Dr. Dennis Garces and defendant Dr. Grace Solero who made initial contributions for the clinic to be ready and operational. Plaintiff Dr. Dennis Garces hired carpenters and painters who renovated the place while Defendant Dr. Grace Solero advanced the lease payment to Ria

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Development Corp. The partners agree, that they will be reimbursed later from the professional fees that they generate from the dental clinic.

Plaintiff Dr. Dennis Garces and Defendant Dr. Grace Solero then contributed their respective materials for the clinic. Dr. Garces has made a dental chair available as well as consumables. For Plaintiff his capital contribution include cash (Php 11,613.00), low speed cleaning instruments, television set, mouth mirrors, explorer, gum sep, cotton flier hand piece, syringe, scaler tip, orthoplais, forces and elevator with a total value of Php 121,960.00. Likewise Defendant Dr. Grace Solero also made her capital contribution in the form of cash in the amount of Php 22,291.00, for the rental deposit and one month advance, a dental chair and consumables with a value of Php69,689.98.

The partners also opened a joint bank account under their names, Dr. Dennis Garces and Dr. Grace Solero. They have agreed that operating expenses are to be deducted from the daily fees collected and the remaining balance will be deposited to their joint bank account.

Plaintiff and Defendant then agreed on the division of the net profits. They have agreed that each will be entitled to a monthly allowance of Php2,500 and that they will accumulate the balance in their joint bank account to be divided equally between them on a yearly basis.

Plaintiff and Defendant likewise agreed on their schedules. Since both of them were full time practitioners in their respective clinics, Plaintiff at his Carmen Public Market dental clinic, and Defendant at her De Leon Plaza dental clinic, that they would employ a full time regular dentist and they will jointly supervise the clinic and committed to serve one half (1/2) day per week. They were able to hire Dr. Ken Barte who was paid a basic salary of Php375.00 per day plus a commission of Php30.00 per procedure.

Plantiff’s wife, Rosemarie Garces, who was also his secretary and bookkeeper at his Carmen Dental Clinic, acted as the partnership’s initial bookkeeper. She designed the books for the recording of the cash receipts and collections and also the vouchers for the disbursements. Rosemarie Garces also trained a newly hired secretary to eventually take her place as she is serving her husband at his dental clinic in Carmen on full time basis.

The dental clinic was formally opened on December 18, 2006.

Defendant Dr. Grace Solero, however, insisted that her husband, also a dentist, co-defendant Dr. Mark Manfred Solero, who is a full time government employee as the then deputy chief of the regional dental office of the Philippine National Police headquarters at Camp Alagar, Lapasan, Cagayan de Oro City, with a rank of Police Superintendent, be included in the partnership.

Since co-defendant Dr. Mark Manfred Solero has no capital contribution of his own, it was agreed that he renders three (3) days of duties, every Tuesday afternoon and on weekends, whole day on Saturday and half day on Sunday.

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Furthermore, the profit sharing arrangement was changed to include co-defendant Dr. Mark Manfred Solero so that he also enjoyed a Php2,500 monthly allowance plus commission of every procedure that he performed.

The relationship, however, of the partners was becoming problematic principally due to their working schedules as co-defendant Dr. Mark Manfred Solero was complaining why he was working for three (3) days a week while Plaintiff was only serving half a day per week and they get the same compensation of Php2,500.00 allowance per month plus commission.

The friction escalated and Plaintiff because of the escalating friction and refusal of the defendants to provide Plaintiff with financial report, made a formal demand to his partners, the defendants herein, that they formally register their professional partnership with the Securities and Exchange Commission (SEC). This was, however, rebuffed by both defendants.

Unknown to Plaintiff, defendants had schemed and planned to oust him from the partnership and appropriate the clinic for themselves.

The defendants unilaterally closed the dental clinic on the pretext that it will be renovated and Plaintiff received a letter from Defendants’ counsel, Atty. Oscar Musni, to get his dental chair and hand instruments from the clinic. This happened on January 16, 2008. Plaintiff was not consulted on the closure and it was against his will.

On December 19, 2007, Plaintiff received Php 140,897.33 from defendant Dr. Grace Solero as his alleged one-third (1/3rd) share in the dental clinic’s operation since December 18, 2006, or exactly one year from the start of the partnership.

To add insult to injury, on January 24 2008, Plaintiff’s wife, Rosemarie Garces, received another letter from Atty. Oscar Musni threatening her for alleged Qualified Theft for allegedly stealing the financial records and books of the clinic.

Plaintiff then filed a complaint before barangay lupon of Macasandig for his unjust expulsion from the partnership. The case, was however, not settled as defendants refused to re-admit the Plaintiff and only refused to compensate him for damages.

Plaintiff suffered actual damages arising from the non return of his investments, dental chair and dental instruments, and opportunity cost by way of lost income as the clinic was already operating well and has attracted loyal and drop in clients. He also suffered moral damage because of his unjust expulsion resulting to stress and sleepless nights. He and his wife were also harassed no end by the defendants, Dr. Garces was sued by defendant Dr. Mark Manfred Solero for alleged dental malpractice for allegedly allowing his wife to act as a dentist despite not being licensed as such. His wife, Rosemarie Garces, was likewise sued by defendant Dr. Grace Solero for allegedly stealing the dental financial records and books and also for dental practice.

ISSUES FOR RESOLUTION BY THE HONOURABLE COURT

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Plaintiff is submitting to the Honourable Court, the following issues for resolution:

(1) Whether or not a professional partnership was formed between the Plaintiff and Defedants?

(2) Whether or not defendants are liable for actual, moral and exemplary damages

ARGUMENTS AND DISCUSSION

I. A general profession partnership was created among the plaintiff and the two defendants

Partnerships are created by law, either express or implied. As defined by the New Civil Code under Art. 1767 a partnership is:

“Art. 1767. By the contract of partnership two or more persons bind themselves to contribute money, property, or industry to a common fund, with the intention of dividing the profits among themselves.

Two or more persons may also form a partnership for the exercise of a profession.”

In the case at bar, both the Plaintiff and the two defendants are professional dentists, having been recognized by the Professional Regulation Commission (PRC). By pooling their resources and combining their skills in one dental clinic, they are exercising their profession as dentist by way of a professional partnership.

The partnership that they have entered is a particular partnership as defined by the Civil Code, thus:

“Art. 1783. A particular partnership has for its object determinate things, their use or fruits, or specific undertaking, or the exercise of a profession or vocation.”

Plaintiff and defendant Dr. Grace Solero are capitalist and industrial partners at the same time, whereas co-defendant Dr. Mark Manfred Solero is a purely industrial partner.

Plaintiff and defendant Dr. Grace Solero contributed funds and property to the partnership. Their respective contributions, as stated in the facts of the case are as follows:

“Plaintiff Dr. Dennis Garces and Defendant Dr. Grace Solero then contributed their respective materials for the clinic. Dr. Garces has made a dental chair available as well as consumables. For Plaintiff his capital contribution include cash (Php 11,613.00), low speed cleaning instruments, television set, mouth mirrors, explorer, gum sep, cotton flier hand piece, syringe, scaler tip, orthoplais, forces and elevator with a total value of Php 121,960.00. Likewise Defendant Dr. Grace Solero also made her capital contribution in the form of cash in the amount of

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Php 22,291.00, for the rental deposit and one month advance, a dental chair and consumables with a value of Php69,689.98.”

These capital contributions were never challenged nor contradicted by the defendants both in their judicial affidavits and oral testimonies.

Furthermore, Plaintiff and defendant Dr. Grace Solero as well as co-defendant Dr. Mark Manfred Solero as industrial partners. An industrial partner is one who contributes only services or industry. The services rendered by Plaintiff and Defendants come in the form of duties at the clinic, with both Plaintiff and defendant Dr. Grace Solero serving half (1/2) days clinic every week and co defendant Dr. Mark Manfred on duty for three (3) days a week.

Another evidence of the existence of a partnership is the division of profits among the partners. As they have agreed, each one was entitled to a monthly allowance of Php2,500.00 and after deducting all the operating expenses, including salaries and wages of the clinic dentist and staff, the balance was to be divided equally among the three every year. As a matter of fact, the records show that each one has received their respective Php2,500.00 monthly allowance and at the end of one year (from 18 December 2006 to 17 December 2007), Plaintiff was given by defendant Dr. Grace Solero the amount of Php 140,897.33.

Again the law is instructive as to determining the existence of a partnership, when it is not in black or white. Thus:

“ Art. 1769. In determining whether a partnership exists, these rules shall apply:

(1) Except as provided by Article 1825, persons who are not partners as to each other are not partners as to third persons;

(2) Co-ownership or co-possession does not of itself establish a partnership, whether such-co-owners or co-possessors do or do not share any profits made by the use of the property;

(3) The sharing of gross returns does not of itself establish a partnership, whether or not the persons sharing them have a joint or common right or interest in any property from which the returns are derived;

(4) The receipt by a person of a share of the profits of a business is prima facie evidence that he is a partner in the business , but no such inference shall be drawn if such profits were received in payment:

(a) As a debt by installments or otherwise;

(b) As wages of an employee or rent to a landlord;

(c) As an annuity to a widow or representative of a deceased partner;

(d) As interest on a loan, though the amount of payment vary with the profits of the business;

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(e) As the consideration for the sale of a goodwill of a business or other property by installments or otherwise. (n)”

In the case at bar, Plaintiff received from co defendant Dr. Grace Solero, the amount Php 140,897.33 as his share for the period 18 December 2006 to 17 December 2007 after deducting all expenses and disbursements for the same period. This share in the net profits is exclusive of the monthly allowance of Php2,500 given to each partner.

By jurisprudence, this conclusion is aligned with decisions rendered by the Supreme Court in cases where there is no formal partnership contract. Thus, in Heirs of Jose Lim represented by Elinito Lim vs. Juliet Villa Lim, G.R. 172690, March 3, 2010, the Supreme Court said:

“At this juncture, our ruling in Heirs of Tan Eng Kee v. Court of Appeals is enlightening. Therein, we cited Article 1769 of the Civil Code, which provides:

Art. 1769. In determining whether a partnership exists, these rules shall apply:

(1) Except as provided by Article 1825, persons who are not partners as to each other are not partners as to third persons;

(2) Co-ownership or co-possession does not of itself establish a partnership, whether such co-owners or co-possessors do or do not share any profits made by the use of the property;

(3) The sharing of gross returns does not of itself establish a partnership, whether or not the persons sharing them have a joint or common right or interest in any property from which the returns are derived;

(4) The receipt by a person of a share of the profits of a business is a prima facie evidence that he is a partner in the business, but no such inference shall be drawn if such profits were received in payment:

(a) As a debt by installments or otherwise;(b) As wages of an employee or rent to a landlord;(c) As an annuity to a widow or representative of a deceased partner;(d) As interest on a loan, though the amount of payment vary with the profits of the business;(e) As the consideration for the sale of a goodwill of a business or other property by installments or otherwise.

Applying the legal provision to the facts of this case, the following circumstances tend to prove that Elfledo was himself the partner of Jimmy and Norberto: 1) Cresencia testified that Jose gave Elfledo P50,000.00, as share in the

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partnership, on a date that coincided with the payment of the initial capital in the partnership;1 (2) Elfledo ran the affairs of the partnership, wielding absolute control, power and authority, without any intervention or opposition whatsoever from any of petitioners herein;2 (3) all of the properties, particularly the nine trucks of the partnership, were registered in the name of Elfledo; (4) Jimmy testified that Elfledo did not receive wages or salaries from the partnership, indicating that what he actually received were shares of the profits of the business; and (5) none of the petitioners, as heirs of Jose, the alleged partner, demanded periodic accounting from Elfledo during his lifetime. As repeatedly stressed in Heirs of Tan Eng Kee, a demand for periodic accounting is evidence of a partnership.

Furthermore, petitioners failed to adduce any evidence to show that the real and personal properties acquired and registered in the names of Elfledo and respondent formed part of the estate of Jose, having been derived from Jose's alleged partnership with Jimmy and Norberto. They failed to refute respondent's claim that Elfledo and respondent engaged in other businesses. Edison even admitted that Elfledo also sold Interwood lumber as a sideline. Petitioners could not offer any credible evidence other than their bare assertions. Thus, we apply the basic rule of evidence that between documentary and oral evidence, the former carries more weight.

Finally, we agree with the judicious findings of the CA, to wit:

The above testimonies prove that Elfledo was not just a hired help but one of the partners in the trucking business, active and visible in the running of its affairs from day one until this ceased operations upon his demise. The extent of his control, administration and management of the partnership and its business, the fact that its properties were placed in his name, and that he was not paid salary or other compensation by the partners, are indicative of the fact that Elfledo was a partner and a controlling one at that. It is apparent that the other partners only contributed in the initial capital but had no say thereafter on how the business was ran. Evidently it was through Elfredos efforts and hard work that the partnership was able to acquire more trucks and otherwise prosper. Even the appellant participated in the affairs of the partnership by acting as the bookkeeper sans salary.

It is notable too that Jose Lim died when the partnership was barely a year old, and the partnership and its business not only continued but also flourished. If it were true that it was Jose Lim and not Elfledo who was the partner, then upon his death the partnership should havebeen dissolved and its assets liquidated. On the contrary, these were not done but instead its operation continued under the helm of Elfledo and without any participation from the heirs of Jose Lim.

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Whatever properties appellant and her husband had acquired, this was through their own concerted efforts and hard work. Elfledo did not limit himself to the business of their partnership but engaged in other lines of businesses as well.

With more reason that Plaintiff should be considered a partner is G.S. Dentista ng Bayan. He did not only contribute fund and property to the common fund, he was also actively engaged as a dental practitioner of the Clinic.

Against this overwhelming evidence of the existence of existence of a general professional partnership, defendant Dr. Grace Solero is claiming that the G.S. Dental Clinic is a sole proprietorship and that she merely accommodated Dr. Dennis Garces in her Clinic. She claims that the clinic was registered in her name, that she was the one paying the rental and utilities such as power and water.

While defendant Dr. Grace Solero was claiming that she owned exclusively the dental clinic, it was shown during her cross examination that she was in fact reimbursed by the dental clinic out of the revenues for the payment of the montly rental and deposit as well as the utilities payments for water, electricity and telephone.

Thus, on the cross examination by the undersigned counsel of defendant Dr. Grace Garces, Transcript of Stenographic Notes (TSN, Sept. 10, 2014) on page 33-34) the following appears:

Atty. Diao: You are telling this Court tha you made a one month advance, (and) one month deposit?

Dr. Grace Solero: Yes, That is the policy of the building.

Q : And you paid them out of your own money?

A : Yes.

Q :That deposit that you made in Door No. 1, was it not refunded form the income of the clinic?

A : I cannot recall.

Q : I am showing to you, Doctor, that a voucher refund to Dr. Grace Solero for deposit of Door 1 in the amount of P8,000, wherein among others, the signatories there are Plaintiff-Dr. Dennis Garces, you and your husband-Mark Solero..

A : What is the question sir?

Q : Was this deposit that you made out of your own personal money, was this not refunded to you by the income of the clinc?

A : Yes

Q : This was also refunded. Similarly, Door No. 2 was also rented for

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P8,000?

A : Yes

Q : And also this was refunded to you by the income of the clinic? Is that correct?

A : Yes

Defendant Dr. Grace Solero expressly acknowledged and admitted that both initial the deposits and rentals were reimbursed to her by the income of the clinic. If indeed she is the sole owner of the clinic, why should she reimburse herself?

Defendant in paying for the utilities such as water was evasive in her answer.

When she was asked why was it that the disbursement vouchers in support of the payment for the water requires the signature of the Plaintiff she answered that his signature was not required but only because Plaintiff will be charged for it.

Thus:

“Atty. Diao: Can you explain to this Honourable Court why these (vouchers) require a signature of three (3) persons, Dr. Garces, Dr. Grace and Mark Solero?

Dr. Grace Solero: It does not require any of these signature(s) sir. The reqson why Dennis Garces put his signature there is because he said that he wanted to recognize the payment because I’m also charging him with the covered expenses.”

However, the voucher is an authority for the validity of the payment. It is clear that for the water expense to be charge to the operating expenses of the clinic, Plaintiff, Dr. Dennis Garces, as a partner must authorize it so that was the reason why his signature is required in the disbursement voucher. The explanation offered by defendant Dr. Grace Garces is not only unbelievable, but is outright ridiculous. This only shows the propensity of defendant Dr. Grace Solero to lie.

As a matter of fact another demonstration of her lying is her refusal to recognize that in the check issued for the payment of the expenses, the signature of Plaintiff, Dr. Dennis Garces, also appeared. It is again downright ridiculous for defendant Dr. Grace Solero that she could not recognized the signature of Dr. Dennis Garces which is side by side with her signature on the check. Thus, in the cross examination (p. 37, TSN, Sept. 10, 2014):

“Atty. Diao: How about for the month of June 2007, whose signature appears on the check?

Dr. Grace Solero: Mine, Sir

Q : Who is the other signature (sic)?

A : I have an explanation for that, sir

Q : Can you recognize whose signature is that?

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A : I cannot say that for a fact because that is not my signature

Q : This is not your signature, there are two (2) signatures here and you are one of the signatories, and the other one you cannot recognize?

A : Yes, I cannot recognize.”

Defendant Dr. Grace Solero confirmed that she and her husband, co- defendant Dr. Mark Manfred Solero, received Php2,500.00 monthly allowance from the income of the clinic. This is consistent with the claim of Plaintiff that each one of them received from the dental clinic a basic monthly allowance.

The idea that Plaintiff, Dr. Dennis Garces, was allowed only by defendant Dr. Grace Solero to practice in the clinic and out of the income per procedure, after getting the share of the clinic for the fixed expenses and cost of the material, the remaining balance is released to the dentist is not only unbelievable but also absurd.

First, why would Plaintiff go to the G. S. Dentista ng Bayan located in Cogon Public Market, just to practice one half (1/2) days work every week, when he could have just stayed at his clinic in Carmen public market and earn more for a half days work? The only reason why Plaintiff would go to G.S. Dentista ng Bayan is because he is a co-owner and partner of the clinic.

Second, and more importantly, why did defendant Dr. Grace Solero gave Plaintiff the sum of Php 140, 897.33 after the end of one year’s operation of the clinic if the argument of defendant that Plaintiff, being allowed to use the clinic for free, would already get his exclusive share per procedure conducted? If this was the arrangement, then Dr. Garces should not be entitled to any share in the profits of the clinic.

The undeniable fact, however, is that defendant Dr. Grace Solero gave to Plaintiff his net share in the profits of the dental clinic after deducting all expenses.

II. Plaintiff is entitled to damages

The issue of the existence of the general professional partnership having been duly established, the next issue now is whether Plaintiff is entitled to actual, moral and exemplary damages.

Under the Civil Code, on Human Relations, Chapter 2, damages arising from the conduct of one person to another may be recoverable, thus:

“Art. 19. Every person must, in the exercise of his rights and in the performance of his duties, act with justice, give everyone his due, and observe honesty and good faith.

Art. 20. Every person who, contrary to law, wilfully or negligently causes damage to another, shall indemnify the latter for the same.

Art. 21. Any person who wilfully causes loss or injury to another in a

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manner that is contrary to morals, good customs or public policy shall compensate the latter for the damage.”

Furthermore, under the same law, actual or compensatory damages may likewise be recovered, thus:

“Art. 2199. Except as provided by law or by stipulation, one is entitled to an adequate compensation only for such pecuniary loss suffered by him as he has duly proved. Such compensation is referred to as actual or compensatory damages.

Art. 2200. Indemnification for damages shall comprehend not only the value of the loss suffered, but also that of the profits which the obligee failed to obtain.”

Actual and consequential damages.

First, the initial contribution of Plaintiff to the partnership was not returned. His initial contribution consisted of cash (Php 11,613.00), which was refunded, and dental instruments and materials with a total value of Php 121,960.00. The latter was not returned to Plaintiff. There was, however, a feigned attempt to allegedly return the dental chair, through a letter made by defendants’ counsel. So this amount should be first be refunded to Plaintiff.

Second, lost partnership profit due to Plaintiff. Plaintiff was receiving a monthly allowance of Php2,500.00 from the partnership. Had he not been unlawfully expelled from the partnership, he would have continually received this monthly allowance. In addition, Plaintiff lost a share in the net partnership profits, which upon computation made by an independent Certified Public Accountant (CPA), was determined to be at least Php 153,285.58 per annum.

This figure is very near the amount which defendant released to plaintiff sometime on December 17, 2007 as his partnership share for the years, from December 18, 2006 to December 17, 2007, which was Php 140,897.33.

Since Plaintiff was unlawfully expelled from the partnership, then he is entitled to received his share of at least Php140,897.33 per annum until this case is finally decided which is considered as consequential damages as a result of his expulsion.

Therefore from December 17, 2007 up to the year 2015, or a period of eight (8) years and counting, Plaintiff should be compensated for at least One Million One Hundred Twenty Seven Thousand One Hundred Seventy Eight and 64/100 Pesos (Php 1,127,178.33), exclusive of legal interest and effect of inflation.

Since legal demand was made, then an interest of six per cent (6%) per annum should be added and inflation factor of four per cent (4%) should be added compounded every year. This would be total to ten per cent (10%) per annum.

Hence, the total amount due to Plaintiff, as of the end of 2015 would already amount to Two Million Four Hundred Sixteen Thousand Two Hundred Six and 85/100 Pesos (Php2,416,286.55).

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Added to this would be the monthly allowance of Php2,500 per month for eight years, or Php240,000.00, the gross amount receivable as of December 31, 2015 by the Plaintiff from the defendant for actual or compensatory damages would be Two Million Six Hundred Fifty Six Thousand Two Hundred Eighty Six and 55/100 Pesos (Php2,656,286.55).

Moral damages and Exemplary Damages. Due to the unlawful expulsion of plaintiff from the partnership coupled with the defendants scheming way of justifying his expulsion for alleged renovation and plaintiff’s suffering from unjustified harassments against him and his wife, arising from his complaint for accounting and damages, both defendants should be made liable for moral damages in the amount of not less than One Million Pesos (Php1,000,000.00).

Furthermore, exemplary damages of at least Two Hundred Thousand Pesos (Php200,000.00) should be imposed against the defendants, their acts clearly against the law on Human Relations and they should be taught an example that they cannot just get away with impunity for what they have done to plaintiff.

CONCLUSION

WHEREFORE, foregoing premises considered, it is most respectfully prayed of this Honourable Court to declare the existence of a general professional partnership and to order the defendants, jointly and severally, to pay the plaintiff the following sums of money, computed as of December 31, 2015, as follows:

(1). Actual and consequential damages, One Hundred Twenty One Thousand Nine Hundred Sixty Pesos (Php 121,960.00) and Two Million Six Hundred Fifty Six Thousand Two Hundred Eighty Six and 55/100 Pesos (Php2,656,286.55), respectively;

(2) Moral damages of One Million Pesos (Php1,000,000.00);

(3) Exemplary damages of Two Hundred Thousand Pesos (Php200,000.00)

It is likewise prayed that defendants be ordered to reimburse plaintiff for the cost of this suit plus the legal expenses incurred which is at least ten per cent (10%) of the total amount due to the plaintiff.

20 November 2015, Cagayan de Oro City.

ATTY. ELEUTERIO F. DIAO IVCounsel for Plaintiff Dr. GarcesMCLE IV-0022917 Issued on 24 Jan 2014PTR no. 2950581 Sept. 2015IBP no. 1009281 Sept 2015Corner Arch Hayes Ext and Lim Ket Kai Drive, Macajalar, Camaman-an, Cag.de Oro CityMobile No. 09272485996Phone No. (088)8803895/8573672

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Email Address:

ATTY. OSCAR P. MUSNIGround Floor, KRYZL condominium12-29th Streets, Nazareth,Cagayan de Oro City

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