Formal Offer of Exhiibts

8/2/2019 Formal Offer of Exhiibts

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Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Danao City

(HON. MA.JOSEFA C. PINZA-RAMOS)

HRS. OF JULIAN BATIQUIN,

Plaintiffs, CIVIL CASE NO.528

-versus-

GREGORIO PEQUILLA, ET. AL.,

Defendants.

X - - - - - - - - - - - - - - -/

FORMAL OFFER OF EXHIBITS

DEFENDANTS, by counsel, most respectfully and formally offer the following exhibits:

EXHIBIT 1[1] --- Tax Declaration No. 0-0201739 R

1-A-- 183 square meters. Area of Lot No. 1434
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PURPOSE:

As part of the testimony of Margie Pequilla and formally offered to prove that Lot No. 1434 was

declared under the name of Gregorio Pequilla married to Marina C. Pequilla and which lot has an aggregate

land area of 183 square meters. The corresponding boundaries were likewise indicated in said tax

declaration.

EXHIBIT 2[2] --- Sketch Plan of Lot No. 1434

2-A--- Portion highlighted with a yellow mark which is the area enclosed by a fence.

2-B--- Portion highlighted with a red/pink mark which is the area used by the plaintiffs as

passage.

2-C--- point no. 7 where the boundary or cylindrical post is located.

PURPOSE:

As part of the testimony of Margie Pequilla and formally offered to prove that there is actually no

encroachment committed by the defendants over Lot No. 1262 or over any other lots surrounding Lot No.

1434. The portion highlighted with a yellow mark would prove that a portion of Lot No. 1434 was

enclosed with a fence which spans from the window of the house of herein defendant Demosthenes

Pequilla up to a point midway between the boundary of Lot No. 1262 and Lot No. 1434. Said fence is well

within the boundary of Lot No. 1434. From the point where the fence is located and up to the boundary

between Lot No. 1262 and Lot No. 1434 lies the passageway used by the plaintiffs. Such passageway is

still part of Lot No. 1434. The portion highlighted with a pink/red mark would readily show such

passageway. Point No. 7 on the sketch plan would prove that the boundary or cylindrical post was located

at such point.

EXHIBIT 3--- Bureau of Lands Form No. 700-2A (Lot Data)
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3-A--- Cad 681-D, Case 2, Lot 1434, Location: Looc, Danao, Cebu

3-B--- Cad Survey Claimant: Gregorio Pequilla

3-C--- Area: 183 square meters

PURPOSE:

As part of the testimony of Margie Pequilla and formally offered to prove that per Lot Data found

in a document duly recorded with the Bureau of Lands, Department of Environment and Natural Resources,

Region 7, Banilad, Mandaue City, Lot No. 1434 was case 2 under Cad 681-D, located in Looc, Danao,

Cebu, surveyed on July 18-August 22, 1983 and approved on April 23, 1984. Said Lot No. 1434 contained

an area of 183 square meters. And was under the name of Gregorio Pequilla as claimant. All technical

descriptions are likewise contained therein which are reflective of the true condition of Lot No. 1434.

RESPECTFULLY SUBMITTED.

1 March 2011, Cebu City (for Danao City), Philippines.

JOSE NEIL L. NUEZ, Jr.

(Counsel for the Defendants)

888 Narra Street


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Greenplains Subdivision

Banilad, 6014 Mandaue City

Mobile Phone Nos. 0927-737-0840 begin_of_the_skype_highlighting 0927-737-0840 end_of_the_skype_highlighting / 0919-

274-4077 begin_of_the_skype_highlighting 0919-274-4077 end_of_the_skype_highlighting

Tel. No.(032) 321-5178

PTR No. 8140789~ 01/05/11, Cebu

IBP No. 821393~ 01/05/11, Cebu

Attorney Roll No. 42447

MCLE Compliance No. I - 0012473 {06-07-08}

MCLE Compliance No. II - 0016470 {02-10-09}

MCLE Compliance No. III 0012471 [04-19-10]

Copy furnished:

(By registered mail)

*Atty. Rolindo Navarro

Counsel for the Plaintiffs


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4th Floor, Cebu Holdings Building

Cebu Business Park, Cebu City

Registry Receipt No. ______________________ Date: _______________________

EXPLANATION

That albeit the New Rules of Civil Procedure, Section 11, Rule 13 thereof, provides thatwhenever practicable, the service and filing of pleadings and other papers shall be donepersonally, service of a copy of this FORMAL OFFER OF EXHIBITS was done by registered mailinasmuch as personal service thereof is not practicable on account of lack of messengerialpersonnel to effect such personal service and by reason of distance and lack of time.

JOSE NEIL LAO NUEZ, JR.

[1]Attached to the records of this case.[2]Original copy is submitted with marking & sub-markings duly copied and incorporated.
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Formal Offer of Exhiibts

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