REPUBLIC OF THE PHILIPPINES

Regional Trial Court

11th Judicial Region
Branch 55
General Santos City

GENSAN INDUSTRIAL CIVIL CASE NO. 18-9192

COMPRESSED GAS CORP.,
represented by ENGR. ROSLINDO
T. SIAO,
Plaintiff,

- versus - - for -

SOCSARGEN COUNTY COLLECTION OF SUM OF

HOSPITAL and/or MT. MONEY, & ATTORNEY’S
MATUTUM MEDICAL CENTER, FEES with PRAYER FOR
INC., represented by RAFAEL WRIT OF GARNISHMENT
ABANO, Managing
Director/President,
Defendants.
x-------------------------------------------x

SUPPLEMENT TO DEFENDANT’S PRE-TRIAL BRIEF

I. DOCUMENTARY EVIDENCE TO BE MARKED AS THE

FOLLOWING:

EXHIBIT DESCRIPTION
Exhibit “2” Incoming Cylinder Receipt No. 5447 & 5531
Exhibit “3” Incoming Cylinder Receipt No. 5566 & 5189
Exhibit “4” Incoming Cylinder Receipt No. 5393 & 5045
Exhibit “5” Incoming Cylinder Receipt No. 4836 & 4816
Exhibit “6” Incoming Cylinder Receipt No. 5246 & 4789
Exhibit “7” Incoming Cylinder Receipt No. 4763 & 5203
Exhibit “8” Incoming Cylinder Receipt No. 4529 & 4660
Exhibit “9” Incoming Cylinder Receipt No. 4394 & 4390
Exhibit “10” Incoming Cylinder Receipt No. 4411 & 4296
Exhibit “11” Incoming Cylinder Receipt No. 4258 & 4162
Exhibit “12” Incoming Cylinder Receipt No. 3859 & 4074
Exhibit “13” Incoming Cylinder Receipt No. 4026 & 3991
Exhibit “14” Incoming Cylinder Receipt No. 3965 & 3477
Exhibit “15” Incoming Cylinder Receipt No. 3703 & 3577
Exhibit “16” Incoming Cylinder Receipt No. 3530 & 3412
Exhibit “17” Incoming Cylinder Receipt No. 3366 & 3189
Exhibit “18” Incoming Cylinder Receipt No. 3224 & 2995
Exhibit “19” Incoming Cylinder Receipt No. 3076 & 2972
Exhibit “20” Incoming Cylinder Receipt No. 11957 & 11748
Exhibit “21” Incoming Cylinder Receipt No. 11744 & 11725
Exhibit “22” Incoming Cylinder Receipt No. 11483 & 11474
Exhibit “23” Incoming Cylinder Receipt No. 11504 & 11454
Exhibit “24” Incoming Cylinder Receipt No. 11232 & 10998
Exhibit “25” Incoming Cylinder Receipt No. 11164 & 10196
Exhibit “26” Incoming Cylinder Receipt No. 10961 & 8260
Exhibit “27” Incoming Cylinder Receipt No. 10869 & 10591
Exhibit “28” Incoming Cylinder Receipt No. 10678 & 10701
Exhibit “29” Incoming Cylinder Receipt No. 10295 & 10282
Exhibit “30” Incoming Cylinder Receipt No. 10044 & 10030
Exhibit “31” Incoming Cylinder Receipt No. 16951 & 9430
Exhibit “32” Incoming Cylinder Receipt No. 9415 & 9523
Exhibit “33” Incoming Cylinder Receipt No. 9384 & 9552
Exhibit “34” Incoming Cylinder Receipt No. 9243 & 9130
Exhibit “35” Incoming Cylinder Receipt No. 9043 & 8885
Exhibit “36” Incoming Cylinder Receipt No. 8974 & 8868
Exhibit “37” Incoming Cylinder Receipt No. 8861 & 8498
Exhibit “38” Incoming Cylinder Receipt No. 11703 & 8481
Exhibit “39” Incoming Cylinder Receipt No. 8644 & 8628
Exhibit “40” Incoming Cylinder Receipt No. 8436 & 8296
Exhibit “41” Incoming Cylinder Receipt No. 8138 & 8352
Exhibit “42” Incoming Cylinder Receipt No. 8184 & 8152
Exhibit “43” Incoming Cylinder Receipt No. 7780 & 7841
Exhibit “44” Incoming Cylinder Receipt No. 7618 & 7575
Exhibit “45” Incoming Cylinder Receipt No. 7445 & 7391
Exhibit “46” Incoming Cylinder Receipt No. 7344 & 7240
Exhibit “47” Incoming Cylinder Receipt No. 7221 & 7307
Exhibit “48” Incoming Cylinder Receipt No. 7212 & 6982
Exhibit “49” Incoming Cylinder Receipt No. 6977 & 6886
Exhibit “50” Incoming Cylinder Receipt No. 6871 & 6393
Exhibit “51” Incoming Cylinder Receipt No. 6596 & 6544
Exhibit “52” Incoming Cylinder Receipt No. 6448 & 6480
Exhibit “53” Incoming Cylinder Receipt No. 6420 & 6294
Exhibit “54” Incoming Cylinder Receipt No. 6195 & 6137
Exhibit “55” Incoming Cylinder Receipt No. 6071 & 6025
Exhibit “56” Incoming Cylinder Receipt No. 5963 & 5951
Exhibit “57” Incoming Cylinder Receipt No. 5739 & 5719
Exhibit “58” Incoming Cylinder Receipt No. 18792 & 18951
Exhibit “59” Incoming Cylinder Receipt No. 18774 & 18770
Exhibit “60” Incoming Cylinder Receipt No. 18667 & 18586
Exhibit “61” Incoming Cylinder Receipt No. 18574 & 18376
Exhibit “62” Incoming Cylinder Receipt No. 18365 & 18351
Exhibit “63” Incoming Cylinder Receipt No. 18273 & 18253
Exhibit “64” Incoming Cylinder Receipt No. 17944 & 17975
Exhibit “65” Incoming Cylinder Receipt No. 17955 & 17590
Exhibit “66” Incoming Cylinder Receipt No. 16720 & 17569
Exhibit “67” Incoming Cylinder Receipt No. 17555 & 17242
Exhibit “68” Incoming Cylinder Receipt No. 17221 & 16990
Exhibit “69” Incoming Cylinder Receipt No. 16985 & 16979
Exhibit “70” Incoming Cylinder Receipt No. 16492 & 16543
Exhibit “71” Incoming Cylinder Receipt No. 16669 & 16515
Exhibit “72” Incoming Cylinder Receipt No. 16502 & 16187
Exhibit “73” Incoming Cylinder Receipt No. 16174 & 16171
Exhibit “74” Incoming Cylinder Receipt No. 16158 & 16116
Exhibit “75” Incoming Cylinder Receipt No. 15919 & 15881
Exhibit “76” Incoming Cylinder Receipt No. 15875 & 15442
Exhibit “77” Incoming Cylinder Receipt No. 15858 & 15646
Exhibit “78” Incoming Cylinder Receipt No. 15427 & 16271
Exhibit “79” Incoming Cylinder Receipt No. 15638 & 15585
Exhibit “80” Incoming Cylinder Receipt No. 15490 & 15480
Exhibit “81” Incoming Cylinder Receipt No. 15472 & 15100
Exhibit “82” Incoming Cylinder Receipt No. 15455 & 14545
Exhibit “83” Incoming Cylinder Receipt No. 15093 & 14887
Exhibit “84” Incoming Cylinder Receipt No. 15073 & 14883
Exhibit “85” Incoming Cylinder Receipt No. 15120 & 14879
Exhibit “86” Incoming Cylinder Receipt No. 15061 & 14800
Exhibit “87” Incoming Cylinder Receipt No. 14794 & 14782
Exhibit “88” Incoming Cylinder Receipt No. 14760 & 14852
Exhibit “89” Incoming Cylinder Receipt No. 14586 & 14579
Exhibit “90” Incoming Cylinder Receipt No. 14619 & 14428
Exhibit “91” Incoming Cylinder Receipt No. 14427 & 13992
Exhibit “92” Incoming Cylinder Receipt No. 13983 & 14189
Exhibit “93” Incoming Cylinder Receipt No. 14184 & 14221
Exhibit “94” Incoming Cylinder Receipt No. 13966 & 13845
Exhibit “95” Incoming Cylinder Receipt No. 13956 & 13872
Exhibit “96” Incoming Cylinder Receipt No. 13808 & 13498
Exhibit “97” Incoming Cylinder Receipt No. 13483 & 13423
Exhibit “98” Incoming Cylinder Receipt No. 13464 & 13285
Exhibit “99” Incoming Cylinder Receipt No. 13144 & 13260
Exhibit “100” Incoming Cylinder Receipt No. 13306 & 12789
Exhibit “101” Incoming Cylinder Receipt No. 13111 & 12599
Exhibit “102” Incoming Cylinder Receipt No. 12759 & 12615
Exhibit “103” Incoming Cylinder Receipt No. 12449 & 12508
Exhibit “104” Incoming Cylinder Receipt No. 12280 & 12172
Exhibit “105” Incoming Cylinder Receipt No. 12162 & 11944
Exhibit “106” Incoming Cylinder Receipt No. 62381 & 61996
Exhibit “107” Incoming Cylinder Receipt No. 60507 & 60022
Exhibit “108” Incoming Cylinder Receipt No. 59543 & 58749
Exhibit “109” Incoming Cylinder Receipt No. 54317 & 53530
Exhibit “110” Incoming Cylinder Receipt No. 53903 & 52546
Exhibit “111” Incoming Cylinder Receipt No. 53062 & 52165
Exhibit “112” Incoming Cylinder Receipt No. 67168
Exhibit “113” Incoming Cylinder Receipt No. 51688 & 50661
Exhibit “114” Incoming Cylinder Receipt No. 50056 & 49544
Exhibit “115” Incoming Cylinder Receipt No. 49481 & 48764
Exhibit “116” Incoming Cylinder Receipt No. 48526 & 48229
Exhibit “117” Incoming Cylinder Receipt No. 47788 & 47670
Exhibit “118” Incoming Cylinder Receipt No. 45887 & 47294
Exhibit “119” Incoming Cylinder Receipt No. 45585 & 45271
Exhibit “120” Incoming Cylinder Receipt No. 43398 & 43549
Exhibit “121” Incoming Cylinder Receipt No. 42292
Exhibit “122” Incoming Cylinder Receipt No. 77577 & 77278
Exhibit “123” Incoming Cylinder Receipt No. 77368 & 72893
Exhibit “124” Incoming Cylinder Receipt No. 71493 & 71101
Exhibit “125” Incoming Cylinder Receipt No. 70876 & 69898
Exhibit “126” Incoming Cylinder Receipt No. 70265 & 68746
Exhibit “127” Incoming Cylinder Receipt No. 69407 & 69076
Exhibit “128” Incoming Cylinder Receipt No. 68790 & 69054
Exhibit “129” Incoming Cylinder Receipt No. 67839 & 67328
Exhibit “130” Incoming Cylinder Receipt No. 67907 & 66884
Exhibit “131” Incoming Cylinder Receipt No. 66450 & 66853
Exhibit “132” Incoming Cylinder Receipt No. 66190 & 65847
Exhibit “133” Incoming Cylinder Receipt No. 66183 & 65803
Exhibit “134” Incoming Cylinder Receipt No. 65742
Exhibit “135” Incoming Cylinder Receipt No. 86484 & 81366

RESPECTFULLY SUBMITTED:

VLO Law & Notarial Offices

Door 7, 2nd Flr, Yusepeng Bldg.,
National Highway, General Santos City
9500 Philippines
By:

CARMELO L. VALENZUELA, JR.

Roll No. 55045
PTR NO. 0034527-JAN-4-2022-GSC
IBP NO. 196261-JAN-5-2022
GENERAL SANTOS CITY CHAPTER
MCLE Compliance No. VI-0021400
(April 11, 2019)