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Manifestation - ELim 2

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REPUBLIC OF THE PHILIPINES

REGIONAL TRIAL COURT


NATIONAL CAPITAL JUDICIAL REGION
SAN JUAN CITY, METRO-MANILA
BRANCH 160

PETITION FOR ISSUANCE OF A


NEW CERTIFICATE OF TITLE
FOR UNIT B, 8th FLOOR,
GOLDLAND TOWER
CONDOMINIUM, EISENHOWER ST.,
GREENHILLS, SAN JUAN CITY,
METRO-MANILA, COVERED BY
CONDOMINIUM CERTIFICATE OF
TITLE NO. 4007-R OF THE REGISTRY
OF DEEDS OF SAN JUAN CITY.

L.R.C. CASE No. R-8463


(SJ)

EDWARD L. LIM,
Petitioner.
x------------------------------------------------------
---x

URGENT MOTION / MANIFESTATION

COMES NOW, PETITIONER, thru counsel, unto this Honorable Court,


most respectfully states, THAT:

1. Last April 5, 2019, the Honorable Court granted the “Motion For
Resumption of Proceedings” filed by herein Petitioner, and set the case for
hearing on April 11, 2019 at 8:30 o’clock in the morning for further presentation
of evidence;

2. After the review of the record of the case, and being apprised of the
evidence which is already in the record, Petitioner now hereby resolves and
manifests that he will no longer present any other witness, for which reason,
Petitioner likewise hereby requests the Honorable Court that he be allowed to file
his written formal offer of evidence within ten (10) days from today;

WHEREFORE, it is most respectfully prayed of this Honorable Court that


Petitioner be allowed to file his written formal offer of evidence within ten (10)
days from this date.

Petitioner prays for such other and further relief as this Honorable Court may
deem just and equitable under the premises.
San Juan City, M.M., Philippines.

April 8, 2019.

GERARDO I. PAYNO, JR.


Counsel for the Petitioner
No. 120-B R. Lagmay St., Brgy. Balong Bato
San Juan City, Metro-Manila 1500
Landline No. (632) 750-5098
Mobile No. (63) 906-2887048
Email Address : gerrlaw52@gmail.com
Roll of Attorneys No. 54184
PTR No. 1237734 | San Juan City, M.M. | 01-03-19
IBP O.R. No. 060522| Pasig City | 01-04-19
MCLE Cert. No. VI-0002214 | Issued May 10, 2017

NOTICE

The Branch Clerk of Court


Regional Trial Court
Branch 160

GREETINGS!

Please submit the foregoing Urgent Motion/Manifestation for the


consideration and appreciation of this Honorable Court, immediately upon receipt
hereof.

GERARDO I. PAYNO, JR.

Copy Furnished:

Office of the City Prosecutor


(San Juan City, Metro-Manila)
Santolan Road cor. P. Guevarra St. ____________________________
San Juan City, Metro-Manila (By personal service)

Office of the Solicitor General Per Registry Receipt No. _______


134 Amorsolo Street Date : ________________, 20___
Legaspi Village, Makati City

CERTIFICATION

This is to certify that copies of the foregoing Urgent Motion/Manifestation has


been furnished to one (1) of the above-named addressees by way of registered
mail, personal service thereof being impracticable due to time and distance
constraint.
GERARDO I. PAYNO, JR.

OFFICE OF THE SOLICITOR GENERAL


134 Amorsolo Street
Legaspi Village, Makati City

OFFICE OF THE SOLICITOR GENERAL


134 Amorsolo Street
Legaspi Village, Makati City

PAYNO LAW OFFICE


52 R. Lagmay St.
San Juan City, M.M. 1500

PAYNO LAW OFFICE


52 R. Lagmay St.
San Juan City, M.M. 1500

REGISTERED MAIL WITH RETURN CARD


Copy Furnished:

Office of the Solicitor General Per Registry


Receipt No. _________
134 Amorsolo Street Date :
___________________, 20__
Legaspi Village, Makati City

Office of the Register of Deeds Per Registry


Receipt No. _________
San Juan City, Metro-Manila Date :
___________________, 20__

Land Registration Authority Per Registry Receipt


No. _________
Binondo, Manila Date :
___________________, 20__

Land Mangement Bureau Per Registry Receipt


No. _________
Binondo, Manila Date :
___________________, 20__

CERTIFICATION

This is to certify that a copy of the foregoing judicial affidavit has been
furnished to one of the above-named addressees by way of registered mail,
personal service thereof being impracticable due to time constraint.

GERARDO I. PAYNO, JR.

OFFICE OF THE SOLICITOR GENERAL


134 Amorsolo Street
Legaspi Village, Makati City

OFFICE OF THE SOLICITOR GENERAL


134 Amorsolo Street
Legaspi Village, Makati City

PAYNO LAW OFFICE


52 R. Lagmay St.,
San Juan City, M.M.

PAYNO LAW OFFICE


52 R. Lagmay St.,
San Juan City, M.M.

OFFICE OF THE SOLICITOR GENERAL


134 Amorsolo Street
Legaspi Village, Makati City

OFFICE OF THE SOLICITOR GENERAL


134 Amorsolo Street
Legaspi Village, Makati City

PAYNO LAW OFFICE


52 R. Lagmay St.,
San Juan City, M.M.

PAYNO LAW OFFICE


52 R. Lagmay St.,
San Juan City, M.M.

OFFICE OF THE SOLICITOR GENERAL


134 Amorsolo Street
Legaspi Village, Makati City

OFFICE OF THE SOLICITOR GENERAL


134 Amorsolo Street
Legaspi Village, Makati City

PAYNO LAW OFFICE


52 R. Lagmay St.,
San Juan City, M.M.

PAYNO LAW OFFICE


52 R. Lagmay St.,
San Juan City, M.M.

PAYNO LAW OFFICE


52 R. Lagmay St., San Juan City
Metro-Manila, Philippines

OFFICE OF THE SOLICITOR GENERAL


134 Amorsolo Street
Legaspi Village, Makati City

PAYNO LAW OFFICE


52 R. Lagmay St., San Juan City
Metro-Manila, Philippines

OFFICE OF THE SOLICITOR GENERAL


134 Amorsolo Street
Legaspi Village, Makati City

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