REPUBLIC OF THE PHILIPPINES

NATIONAL APITAL JUDICIAL REGION

REGIONAL TRIAL COURT
VALENZUELA CITY
BRANCH 270

MARIA ANGELA PASCUAL

LUNA,
Petitioner

SP. Proc No. 14-V-21

-VERSUS- For: Habeas Corpus in
Relation to Custody

JHON ROMEL NUEVO,

Respondent.
X====================X

VERIFIED ANSWER
TO THE PETITION FOR THE ISSUANCE OF A WRIT OF HABEAS
CORPUS IN RELATION TO CUSTODY

Respondent Jhon Romel Nuevo unto this Honorable Court,

respectfully alleges:

ADMISSIONS and DENIALS

1. Paragraphs (2), (3), (5), (7), and (19) are ADMITTED without
reservations.

2. Paragraph (6) is DENIED as the truth of the matter is different from

the actual circumstance.

3. Paragraph (8) is DENIED as the truth of the matter is different from

the actual occurrence.

4. Paragraph (9) is ADMITTED as to the first sentence of the paragraph,

without reservations, but the second sentence is DENIED as to the
truth of the matter is different from the actual circumstance.

5. Paragraph (10) is DENIED as the truth of the matter is different from

the actual circumstance.
 6. Paragraph (11) is DENIED for want of knowledge sufficient to form a
belief as to the truth or falsity thereof.

7. Paragraph (12) is DENIED for want of knowledge sufficient to form a

belief as to the truth or falsity thereof.

8. Paragraph (13) is DENIED for want of knowledge sufficient to form a

belief as to the truth or falsity thereof.

9. Paragraph (14) is DENIED as the truth of the matter is different from

the actual occurrence.

10. Paragraph (15) is DENIED as the truth of the matter is different from
the actual circumstance.

11. Paragraph (16) is DENIED as the truth of the matter is different from
the actual circumstance.

12. Paragraph (17) is DENIED for want of knowledge sufficient to form

a belief as to the truth or falsity thereof.

13. Paragraph (18) is DENIED for want of knowledge sufficient to form

a belief as to the truth or falsity thereof.

RESPONDENT’S VERSION OF THE FACTS

Given that petitioner twisted the truth of the occurrences and
circumstances which transpired over the course of three (3) years. It would
be prudent for respondent to give the correct narration of the facts:

14.Petitioner and respondent began their relationship on April 6, 2016.

Out of their relationship, petitioner gave birth to Gavin Caleb on
March 1, 2017.

15. At the time of Gavin’s birth, respondent had to resign from his job as
lubeman at Shell Gasoline Station given that he was being forced by
his supervisor to perform dangerous jobs that would be detrimental
to him. Petitioner agreed to such given that respondent was still able
to provide the needs of Gavin.
16.Four months after Gavin was born, or June 2017, respondent began
his training for his new work as a collector for the Guanzon Group of
Companies.

17.It was July 2017 when petitioner asked permission from respondent
to attend a friend’s birthday party while leaving Gavin unattended.
Luckily, respondent was present to take care of Gavin, thus,
respondent allowed petitioner to attend her friend’s birthday party.

18. Respondent had access to the social media accounts of petitioner.

After a few days from the supposed “birthday party”, an Ar-Ar
Bulatao sent a message to petitioner saying, “Akala ko pupunta ka
ulit dito sa bahay.”

19.Respondent confronted petitioner about such, and she admitted that

she had sex with this Ar-Ar Bulantao and did not actually go to any
birthday party all while petitioner was working hard for their family.
Respondent originally wanted to end things with petitioner,
however, in the spirit of keeping their family together, he gave her a
second chance despite the immorality of her actions.

20. Despite petitioner’s cheating incident, respondent and family treated

her as if she were part of the family to the point that in December
2017, petitioner and respondent were invited to go abroad with
respondent’s uncle, Jose Jurel Nuevo, and aunt, Rowane Sor. When
asked if she wanted to come, petitioner herself excitedly agreed to
come with them especially since they were assured that it would not
affect their finances.

21. Petitioner was never forced to attend the said trip as it was under her
own volition to go to such.

22. On March 8, 2018, petitioner gave birth to the twins Sofia Kylie and
Sofia Kyline. It was the family of respondent who assisted them and
settled their expenses considering no help could be derived from
petitioner’s mother as the latter was always busy with her boyfriend
from Saudi Arabia.

23. Considering that she would not be expecting help from petitioner’s
mother, respondent suggested that they stay at respondent’s house to
which petitioner agreed to.
24.Respondent and her family were considerate of petitioner, thus, they
only required her to look after the children without doing any of the
housework. Respondent helped in caring for the children. Moreover,
the aunt and uncle of respondent also helped in caring for the
children as they love their grandchildren.

25. There was a time when petitioner confronted respondent with an

alleged cheating incident which the former attributed to the latter.
Respondent maintains that despite the fact another woman admitted
her feelings for him, he did not acknowledge the same considering
that he was in love with petitioner.

26.Despite his innocence, petitioner beat up the respondent which

prompted him to leave the house for the night, but he returned the
next day to make amends with petitioner to keep the sanctity of their
family.

27. Things went well for a while but on March 7, 2019, when Sofia Kylie
was admitted to the Philippine General Hospital, respondent
borrowed the phone of petitioner and he discovered that the latter
was having exchanges through text messages with a Rose Anne
Santiago in where petitioner stated that she had plans to renew her
relationship with a Razzel Gogola.

28.In his anger and disappointment, respondent confronted petitioner

about this to which the latter kept silent about. This urged
respondent to recall the incident with Ar-Ar Bulatao and he asked
how many times petitioner and the said person had sex to which the
petitioner admitted she did once.

29.Petitioner claimed that she and Ar-Ar Bulatao got drunk and fell
asleep, when she woke up, Ar-Ar Bulatao was having sex with her.
Respondent wanted to file a charge of rape against Ar-Ar Bulatao,
but petitioner went against it. Feeling suspicious, respondent asked
petitioner to message Ar-Ar Bulatao for him to send his exchanges
with petitioner.

30. When Ar-Ar Bulantao was messaged, he replied, “Bakit? Para saan?
Kaylangan pa ba?”
31. Respondent through petitioner replied, “Isesend mo ba o
ipapakulong kita sa ginawa mo sa sa akin.”

32. Ar-Ar Bulantao replied, “Ha? Ikaw ang nagpupumilit na pumunta

dito, kaya wala kang matatakot dito”. This is when respondent found
out that what transpired a year ago was something that petitioner
wanted. Even if he wanted to part ways with petitioner, he
maintained their relationship for the best interest of their children.

33. On March 19, 2021, respondent caught petitioner calling another

man through the telegram application. Petitioner denied any
relationship with this man. Thus, a few days later, respondent
checked the social media accounts, her Tiktok Account and Telegram
Application, of petitioner and there he discovered that petitioner was
having flirtatious exchanges with the man he was calling. They even
had an endearment term, “mahal”. Respondent was even able to
confront another man with the name “Asta” in Telegram whom the
latter claims that petitioner represented herself as being a single
mother.

34. Apart from these incidents, respondent knew that petitioner was
seeing other people because every time he would ask petitioner to
“make love”, petitioner would always say that they “do it at night”
but whenever night came, she would always say “No.”

35. Respondent never forced petitioner to have sex with him because of
the love and respect he felt for her.

36. From then on, things did not go well for petitioner and respondent
because apart from immorality exuded by petitioner, she was also a
poor mother to her children.

37. On March 26, 2019, the couple chose to permanently stay at the
house of Jose Jurel Nuevo, respondent’s uncle, so that Kylie’s
condition can be monitored as she was operated on her head.

38. During these times, respondent’s aunt, Rowane Sor, found out that
petitioner was very short-tempered and would not look after the
children to focus on doing things in her cellphone and play games
such as Mobile Legends.
39.There was a time when petitioner left Kylie in a toy car and instead of
looking after the child, petitioner just continuously played with her
cellphone.

40.Respondent and his family where shocked when they heard Kylie hit
and her head and saw the child crying. Respondent’s brother told
respondent, his aunt, and his uncle, that petitioner left the child at the
toy car without a helmet, and without supervision.

41.To note, Kylie needed extra attention as she was operated on her
head five (5) times.

42. Respondent’s uncle scolded petitioner and told her that the only
thing she needed to do was to watch over the children, to which she
failed to do so.

43.There were also several times that Rowane Sor would witness
petitioner throw the children at the sofa and leave them there, not
caring about them. Rowane pleaded not to do so but petitioner
would continue doing the same act.

44. Petitioner would also harm the children which Rowane caught
doing. There was a time when she witnessed Angela painfully
smacking Gavin at the back. Rowane berated petitioner for such
actions, but the latter just ignored her. Given that she harms the
children, Gavin would openly tell respondent and his family that his
mother harms him.

45.Almost every day as well, petitioner would harm her children

whenever she combed their hair. Whenever the children would move
around while their hair is being combed, petitioner would pull the
hair of the children and smack them on their head especially if they
become a bit more unruly. Whenever she would be caught doing so,
she would lessen the pain she inflicts to the children, as if she were
just joking.

46. Apart from the pains he inflicts her children, petitioner says a lot of
vulgar words directed to the children.

47. In addition to the physical harm she caused to the children, as stated
above, she would neglect the children even if she wasn’t been bossed
around by anyone in the house.
48. Jose Jurel Nuevo, the uncle of respondent, would observe many
times whenever he checked on the children that petitioner would just
leave them be to play Mobile Legends or do business with her
cellphone. He would also find the room of the family in disarray as if
the petitioner did not care.

49. He also observed that whenever the children would seek attention
from their mother, the latter would ignore them and berate and shout
at them if they continue to get the attention of their mother.

50. Despite petitioner’s huge lapses as a mother, respondent and his

family treated her with utmost respect in trying to keep the family
from falling apart. Thus, it came to a surprise to respondent, his aunt,
and his uncle when on May 6, 2021, petitioner left the house despite
everybody’s pleas not for her to go.

51.Originally, respondent and his family wanted to give the custody of

the three children to the mother in recognition of the fact that
respondent and petitioner and respondent are not married, they
decided to go against the same when respondent told his uncle that
petitioner cheated on him five (5) times and the fact that petitioner
would threaten respondent multiple times into committing suicide,
bringing along the children.

52. Respondent even showed his uncle the screenshots of petitioner’s

search history where she searched “Hangman’s knot instruction” and
their conversation where she would tell respondent that she wanted
to commit suicide.

53.Respondent and his family made several attempts to come to an

amicable settlement with petitioner, but she filed a complaint before
the VAWC Desk Officer at Barangay Gen T. De Leon.
Petitioner was not given custody of the three children for the reasons
stated above, thus, she sought the help of the Public Attorney’s
Office.

54.Respondent and his family wanted to attend the mediation at the

Public Attorney’s Office which they were told about, however, they
only received a copy of the Patawag ng Pagharap on June 4, 2021.
 55.Respondent even wrote a letter to the Public Attorney who was
handling the case of petitioner, but the latter ignored his pleas. Thus,
it came to a surprise that on June 18, 2021, he received the Summons
for the Petition filed by petitioner.

ARGUMENTS AND DISCUSSIONS

56.Respondent recognizes the fact that under Article 176 of the Family
Code, illegitimate children shall be under the custody of their
mother, as an exception, however, Article 213 of the Family Code
provides that the Court may designate the parents to whom who
shall have parental authority and custody over the minor children
especially if one of the parents is deemed unfit to take care of them.

57.In Renalyn A. Masbate vs. Ricky James Relucio 1 the Supreme Court
cited what constitutes “compelling reasons to wrest away custody
from a mother over her children, to wit:

According to jurisprudence, the following instances may

constitute "compelling reasons" to wrest away custody from a
mother over her child although under seven (7) years of age:
neglect, abandonment, unemployment, immorality,
habitual drunkenness, drug addiction, maltreatment of the
child, insanity or affliction with a communicable disease.
(Emphasis supplied)

58.In the case at bar, petitioner is unfit to be the custodian of the three
children on the following grounds: (1) she is an immoral person for
having sex with other men while cohabiting with respondent, (2) she
is mentally unstable considering the fact that she has suicidal
tendencies as discovered by respondent, (3) she is unemployed and is
unable to provide for a good environment to raise the three children,
(4) she maltreats, harms, and neglects the children.

59.First, petitioner is a highly immoral person. As stated in the facts, she

has flirted with other men and had concurrent relationships while
cohabiting with respondent. Her immorality is so grave that barely a
few months after the eldest child was born, she already had sex with
another man.

60.Petitioner even admitted to her immoral was as when confronted by

respondent, she readily admitted them. Her immorality reveals her
character – one who is unfit to take care of the minor children.
1
GR No. 235498, July 30, 2018
61.Her immorality would only be detrimental to the growth of the
children given that they have a mother who would satisfy herself
with multiple partners which is negative to a child’s growth.

62.Second, as revealed above, petitioner is very mentally unstable. As

revealed by the facts, she had multiple searches on the internet in
where she searched “how to tie a hanging noose”.

63.Furthermore, she and respondent had several exchanges via text

messaging and social media where she would tell respondent that
she wanted to commit suicide.

64.Moreover, she would openly tell respondent from time-to-time that

she wanted to commit suicide and that she would also include the
children in said suicide fact.

65.Considering that respondent has suicidal tendencies, respondent

respectfully requests from this Honorable Court to conduct Mental
Examination under Rule 28 of the Revised Rules of Civil Procedure
on petitioner to ascertain her mental fitness to take care of the
children for fear that their life may be in peril due to the mental
condition of their mother.

66. Third, petitioner is unemployed and could not provide the needs of
the minor children. From the beginning of their relationship, it was
respondent and his family who provides for the needs of the children
which includes their food, shelter, clothing, toys or whatever needs
they had.

67. Even during the time when one of the twins, Kylie, was operated at
the Philippine General Hospital, it was respondent and his family
who provided for everything to ensure the survival of the said child.
Petitioner and her family never gave any amount for the needs of the
children, nor did they give gifts to them.

68. More so, even the needs and wants of petitioner was provided by
respondent. Respondent readily gave what she wanted and needed.
At present, petitioner claims to be engaged in “live selling” to
provide for the children, however, such is not enough to provide for
the three children especially since Kylie has greater needs than that of
her siblings.
69. Next, the place that the children would be staying in would not be a
conducive environment for their growth. At present, petitioner
currently lives with her mother, sister, and uncle in a very small
house where they would only sleep in a tiny room with a single foam
to fit all of them, whereas respondent provides the three (3) children
with a spacious environment to live in with comfortable rooms to
stay in with the care of their grandparents.

70. Moreover, petitioner lives in an area where there is copious amount

of shouting and swearing where they would not be looked after
considering that their mother does not actually devote time to their
needs and advances her own needs than that of their own. In
respondent’s home, the children are looked after by respondent and
his family ensuring that they are safe and grow up properly.

71. Thus, it is in the best interest of the children to be raised in the

environment where their father is residing in as respondent is in a
better position to provide the needs, wants and love that the children
need.

72. Fourth, one of the issues that respondent has with petitioner is the
fact that she maltreats and hurts the children. There were several
instances when petitioner is going with her business in her mobile
phone, the children would seek her attention, she would curse at the
children and hit them, particularly the eldest child, Gavin. The eldest
child would tell his father that petitioner hit her near his shoulder
and the same happens on multiple occasions.

73. Next, there were several occasions when respondent’s aunt caught
petitioner hitting her children’s head whenever they would be active
while petitioner is combing their hair, even to Kylie, the child who
was operated on her head.

74. These two occurrences were among those that the children suffered
while at the hands of their mother who only cared about her needs
and interests, as apart from inflicting physical pain, she would also
say vulgar words to the children.

75. It is not true that petitioner endured in caring for the three (3)
children because in fact, it was respondent and his family who would
take care of them and give them the attention they need.

76. Petitioner was a neglectful mother to the point that respondent’s

uncle had to berate her several times that she had to look after the
children, considering that she was not being given any house chores
to focus on the children.
 77. Her neglect was so gross that there were occasions that the children
would get hurt but she would not lift a finger and focus on whatever
she is doing in her mobile phone, be it doing Tiktok dances or flirting
with other men.

78. Her neglect and maltreatment of the children can be even solidified
by the fact that the children do not look for their mother when she
left the house of respondent. After the incident, whenever the eldest
child, Gavin, is asked where his mother is, he would only exclaim,
“Layas.”

79. The children can be asked who they want to be with, and they would
readily say that they want to be with their father and their
grandparents who were the actual ones who took care of them.

80. Given that petitioner is unfit to become a mother to her children,

jurisprudence provides that the best interest of the child should be
taken into primary consideration in determining which parent
should have custody over them.

81. In Jocelyn Pablo-Gualberto vs. Crisanto Rafaelito Gualberto V 2, the

Supreme Court revisited the principle of “best interest of the child”,
to wit:

The principle of "best interest of the child" pervades

Philippine cases involving adoption, guardianship, support,
personal status, minors in conflict with the law, and child
custody. In these cases, it has long been recognized that in
choosing the parent to whom custody is given, the welfare of
the minors should always be the paramount consideration.
Courts are mandated to take into account all relevant
circumstances that would have a bearing on the children’s
well-being and development. Aside from the material
resources and the moral and social situations of each
parent, other factors may also be considered to ascertain
which one has the capability to attend to the physical,
educational, social and moral welfare of the children.
Among these factors are the previous care and devotion
shown by each of the parents; their religious background,
moral uprightness, home environment and time
availability; as well as the children’s emotional and
educational needs. (Emphasis supplied)

2
GR No. 154994, June 28, 2005
82. Respondent submits that it is in the best interest of Gavin, Kyline,
and Kylie to be under the custody of their father considering the
following factors:

82.1. It is respondent and his family that truly give care, love, support,
and time to take care of the children.

82.2. Petitioner exhibits an immoral life by having carnal knowledge

with different men and flirting with multiple men which will
bring confusion to the children.

82.3. Respondent is in a household with highly educated individuals

who were raised morally upright and to be God-fearing while
petitioner lives in a household of loose morals considering that
even her mother has relationships with different men that are not
her father.

82.4. The overall environment of respondent’s home is much better

than that of petitioner’s considering that they live in a more
spacious house with bigger rooms and with all their needs
adequately being provided.

82.5. It is respondent who is employed and at a better position to

provide for the education, medical, security and social needs of
the children. Assuming arguendo he is not employed, his family is
still the main provider of the needs of three children.

82.6. Respondent and his family do not harm and neglect the
children.

83.With all taken into consideration, it is in the best interest of the

children that custody and parental authority be given to their father
as their mother is unfit to be one and that respondent will be able to
provide a better upbringing to the children that puts their best
interest upfront.

84.At present, respondent fears for the well-being of the three minors as
when he visited the children on June 19, 2021, Sofia Kyline showed
him a wound he incurred in the foot, just barely a day after the
hearing on June 18, 2021. For the safety and well-being of the
children, it is respectfully prayed for by respondent that the custody
of the children be temporarily granted to him to ensure that the
children are well-taken care of.
 TESTIMONIAL EVIDENCE TO BE PRESENTED

The following witnesses will be presented during the trial to prove

that it is respondent who has a better right to take the custody of the
children:

a. Respondent, Jhon Romel Nuevo, himself to disprove the falsity

spewed by petitioner in her version of the facts and give support to
the facts stated in this answer, and to prove the immorality and the
mental instability of petitioner. Attached herewith is the Judicial
Affidavit of Jhon Romel Nuevo (ANNEX 1).

b. Jose Jurel Nuevo, the respondent’s uncle who will testify to give
support to the facts stated in this answer, and to support the
testimony of respondent and prove that petitioner neglected and
maltreated her children. Attached herewith is the Judicial Affidavit of
Jose Jurel Nuevo (ANNEX 2).

c. Rowane Sor, the respondent’s aunt who will testify to give support to
the facts stated in this answer, support the testimonies of the other
witnesses, and to prove that petitioner neglected and most especially
maltreated her children. Attached herewith is the Judicial Affidavit of
Rowane Sor (ANNEX 3).

Respondent respectfully reserves the right to present other witnesses

that will help establish his right to the custody of the three minor children.

OBJECT AND DOCUMENTARY EVIDENCE TO BE PRESENTED

a. Screenshots of conversations between petitioner and the other man

he is in relationship with are being presented to show that she has a
propensity to be promiscuous. Attached herewith are screenshots of
the conversations in Tiktok, Telegram, and Facebook Messenger
(ANNEX 4 – Series).

b. Screenshot between respondent and the other man petitioner had a

relationship with are being presented to prove that petitioner lied
about her status to the other man which the said man admitted.
Attached herewith is the telegram conversation between respondent
and the man (ANNEX 5 – Series)
c. Screenshot of petitioner’s search history where she searched for
instructions on how to hang a tying known are being presented to
prove that petitioner has the propensity to be suicidal. Attached
herewith are screenshots of such (ANNEX 6 – Series).

d. Screenshots of petitioner and her friend wherein she admitted that

she had anxiety and was suicidal are presented to support the
allegation of petitioner’s suicidal tendencies. Attached herewith are
screenshots of Facebook Conversations between petitioner and her
friend. (ANNEX 7 – Series).

e. Screenshot of the conversation between petitioner and her friend

where she admitted that she cheated on respondent which was the
cause of their break-up is being presented to solidify petitioner’s
promiscuity. Attached here is a copy of the Facebook conversation
between petitioner and her friend (ANNEX 8).

f. Screenshot of the conversation between petitioner and respondent

where respondent told petitioner that she was not barred from seeing
her children and in fact being asked to return to them is being
presented to prove that respondent tried his best to make amends
with petitioner, but the latter would not budge. Attached herewith is
a copy of the Facebook messenger conversation (ANNEX 9).

g. A copy of the letter respondent wrote to the Public Attorney is being

presented to prove that he exerted efforts to have a mediation before
the Public Attorney, but the latter refused his pleas. Attached
herewith is the letter of respondent to Public Attorney Michael
Gerard S. Hernandez dated June 7, 2021 (ANNEX 10).

PRAYER

Accordingly, respondent respectfully prays that the Honorable

Court:

a. That the Petition for the Issuance of a Writ of Habeas Corpus in

Relation to Custody dated June 8, 2021, be dismissed.

b. That respondent
 c. That respondent be declared to have custody and parental
authority over the minors Gavin Caleb Luna Nuevo, Sofia Kylie
Luna Nuevo, and Sofia Kyline Luna Nuevo.

d. That a mental examination be conducted on petitioner, Maria

Angela Pascual Luna, to ascertain her mental fitness to exercise
parental authority and custody over the three minors.

Other reliefs just and equitable under the premises are likewise
prayed for.

Marikina City for Valenzuela City, June 23, 2021.

RL LEGAL CONSULTANCY
Counsel for Respondent
17 Summer Street, Benedicto Compund,
Concepcion I, Marikina City 1807
[email protected]
Tel No. (02) 7624-6264

By:

MARIO RYAN E. LAUZON

Roll of Attorney No. 59730
Lifetime IBP No. 018064/09-20-2017/RSM
PTR No. 0914788/01-28-2021/Q.C.
MCLE Compliance No. VII – 0002161/04-15-2019

Copy furnished:

ATTY. MICHAEL GERARD S. HERNANREZ

Public Attorney’s Office
Valenzuela City District Office
Ground Floor, MeTC Bldg, Bulwagang Pangkatarungan,
Justice Hall Compound, Brgy. Malinta
Valenzuela City
 WRITTEN EXPLANATION

Due to the lack of messengerial services and distance of the

Honorable Court and the other party at the present time, the service of the
foregoing pleading was made through private courier and/or electronic
mail in lieu of the preferred mode of personal service pursuant to the
Revised Rules of Civil Procedure.

MARIO RYAN E. LAUZON

VERIFICATION AND CERTIFICATION

ON NON-FORUM SHOPPING

I, JHON ROMEL NUEVO., Filipino citizen, of legal age and with address
above-stated, after having been sworn in accordance with law do hereby depose
and state that:

1. I am the Respondent in the above-captioned case.

2. I have caused the preparation of the foregoing Answer.
3. I have read and understood the same and attest that: (a) the
allegations herein are true and correct based on my own personal
knowledge, or based on authentic documents; (b) this answer is not
 filed to harass, cause unnecessary delay, or needlessly increase the
cost of litigation; and (c) the factual allegations herein have
evidentiary support or, if specifically so identified, will likewise
have evidentiary support after a reasonable opportunity for
discovery.
4. The allegations therein are true and correct based on my personal
knowledge and/or authentic records.
5. I hereby certify that: (a) I have not commenced any other action or
proceeding involving the same issues thereto with this Honorable
Court, the Court of Appeals, or any other tribunal or agency; (b) to
the best of my knowledge, no such action or proceeding involving
the same issues is pending before this Honorable Court, the Court of
Appeals, or any other tribunal or agency; (c) if there is any action or
proceeding involving the same issues pending before this Honorable
Court, the Court of Appeals, or any other tribunal or agency, I will
state the status thereof; and (d) should I learn thereafter that a
similar action or proceeding involving the same issues is pending
before this Honorable Court, the Court of Appeals, or any other
tribunal or agency, I will report the fact within five (5) calendar days
therefrom to this Honorable Court, and to the court where the
original pleading has been filed.

Affiant further sayeth naught.

IN WITNESS WHEREOF, I have hereunto set my hand this 23rd day of June
2021 in Quezon City, Philippines.

JHON ROMEL NUEVO

Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, this 23rd day of June 2021,
with affiant exhibiting to me her valid identification card bearing her photograph
and signature as competent proof of her identity.