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    Formal Offer of Exhibit

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    bayadtax
    This document is a formal offer of exhibits submitted by the plaintiff's counsel in a civil case regarding quieting of title, recovery of ownership and possession, and damages. It lists 24 exhibits labeled A through V to be submitted, along with a brief purpose statement for each exhibit. The exhibits include deeds of sale, notices, records, titles and certifications intended to prove the plaintiff's claims to the property and attempts to resolve the issue through other means prior to filing the case. The counsel requests the court admit the listed exhibits into the records and case.

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    Formal Offer of Exhibit

    Uploaded by

    bayadtax
    536 views7 pages
    This document is a formal offer of exhibits submitted by the plaintiff's counsel in a civil case regarding quieting of title, recovery of ownership and possession, and damages. It lists 24 exhibits labeled A through V to be submitted, along with a brief purpose statement for each exhibit. The exhibits include deeds of sale, notices, records, titles and certifications intended to prove the plaintiff's claims to the property and attempts to resolve the issue through other means prior to filing the case. The counsel requests the court admit the listed exhibits into the records and case.

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    This document is a formal offer of exhibits submitted by the plaintiff's counsel in a civil case regarding quieting of title, recovery of ownership and possession, and damages. It lists 24 exhibits labeled A through V to be submitted, along with a brief purpose statement for each exhibit. The exhibits include deeds of sale, notices, records, titles and certifications intended to prove the plaintiff's claims to the property and attempts to resolve the issue through other means prior to filing the case. The counsel requests the court admit the listed exhibits into the records and case.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    536 views7 pages

    Formal Offer of Exhibit

    Uploaded by

    bayadtax
    This document is a formal offer of exhibits submitted by the plaintiff's counsel in a civil case regarding quieting of title, recovery of ownership and possession, and damages. It lists 24 exhibits labeled A through V to be submitted, along with a brief purpose statement for each exhibit. The exhibits include deeds of sale, notices, records, titles and certifications intended to prove the plaintiff's claims to the property and attempts to resolve the issue through other means prior to filing the case. The counsel requests the court admit the listed exhibits into the records and case.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 7

    Republic of the Philippines

    REGIONAL TRIAL COURT


    Third Judicial Region
    Branch 13
    City of Malolos
    ALEXIS JEROME S. PANGANIBAN
    and FLORA S. PANGANIBAN
    Plaintiffs,
    -versus2015

    CIVIL CASE No. 462-MFor: Quieting of Title,


    Recovery of Ownership
    and Possession, and
    Damages

    PERLA MUTUC and all persons


    Residing, renting, and deriving
    Rights under her
    Defendants.
    x-------------------------------------------------x

    FORMAL OFFER OF EXHIBITS


    NOW COMES PLAINTIFFS, through counsel, unto this Honorable
    Court most respectfully submits his Formal Offer of Exhibits in the
    above-entitled case, stated as follows:

    EXHIBIT
    A
    PURPOSE
    :
    Alexis

    DOCUMENT
    Deed of Conditional Sale
    To prove sale between GSIS and plaintiff,
    Jerome Panganiban.

    Notice if Approval by GSIS

    PURPOSE
    :
    To prove approval from the Housing
    Department of GSIS dated November 22, 2010 with
    Control No. 102010-114

    Record on Housing Loan

    PURPOSE
    :
    To prove the record on Housing Loan
    issued by GSIS on June 17, 2015 under its Housing
    Account Reconciliation Department

    TCT No. T-80.570

    PURPOSE
    :
    To prove that GSIS is the registered
    owner of the subject property.

    Deed of Conditional Sale

    PURPOSE
    :
    To prove the sale on installment basis
    between William Jose and Phil-Ville Development and
    Housing Corporation dated July 14, 1984.

    Deed of Absolute Sale

    PURPOSE
    :
    To prove the sale of the same property
    including its improvements between Spouses William
    and Lita Jose and Spouses Generoso and Ma. Teresa
    Cereno dated December 18, 1984 consisting of two
    pages

    Special Power of Attorney

    PURPOSE
    :
    To show power of attorney executed by
    Generoso Cereno in favor of Perla Mutuc dated
    December 27, 1884 consisting of 1 page

    Deed of Absolute Sale

    PURPOSE
    :
    To
    prove
    sale
    between
    Spouses
    Generoso and Ma. Tersa Cereno and Perla Mutuc dated
    December 27,1984 consisting of 1 page

    Memorandum of Agreement

    PURPOSE
    :
    To prove undertaking between Spouses
    Generoso and Ma. Tersa Cereno and Perla Mutuc dated
    December 27,1984 consisting of 1 page that defendant
    Mutuc shall assumed obligations to GSIS

    J
    2002

    Notice from GSIS dated October 9,

    PURPOSE
    :
    amortization

    K
    2005

    Notice from GSIS dated January 10,

    PURPOSE
    :
    amortization

    L
    Sale

    To prove failure of William Jose to pay

    To prove failure of William Jose to pay

    Cancellation of Deed of Conditional

    PURPOSE
    :
    To prove that since there is no response
    from William Jose, GSIS was constrained to cancel the
    deed of conditional sale and foreclosed the property on
    March 16, 2005

    M
    9,2011
    M-1

    Demand Letter served on June


    Certification of Delivery

    PURPOSE
    :
    To prove the demand to Perla to vacate
    property and the corresponding certification of delivery
    by Meycauayan Post Office

    N
    2011

    Certification to file action June 2,

    PURPOSE
    :
    To prove that Plaintiff, Flora Panganiban
    has earnestly tried to settle amicably through the
    barangay

    Civil Case No. 495-M-2011

    PURPOSE
    :
    To prove that amidst the effort of
    Plaintiff, Flora Panganiban, to settle the issue to vacate
    the property outside the court, defendant Perla Mutuc,
    instead file a civil case against her and GSIS, et al.

    P
    2014

    Court Order dated November 4,

    PURPOSE

    To show proof that Civil Case No.

    495-M-2011 has been dismissed accordingly.


    R

    Entry of Judgment

    PURPOSE

    To show proof the finality of Court

    Order dated November 4, 2014 as issued by


    Supreme Court dated April, 2015
    S
    9,2015

    Certificate to file action dated July

    PURPOSE
    :
    To prove that once again, Plaintiff, Flora
    Panganiban has earnestly tried to settle amicably
    through the barangay for defendant, Perla Mutuc and
    all those deriving rights under her to vacate the
    property

    Special Power of Attorney for Flora


    Panganiban

    PURPOSE
    :
    To prove legal authority of Flora
    Panganiban to represent Alexis Jerome Panganiban

    Engagement Contract

    PURPOSE
    :
    To prove that towards all efforts of the
    plaintiff to settle the issue outside of the court, she had
    been left with no other choice but to secure the
    services of the undersigned counsel to enforce their
    right on the property that they bought from GSIS

    Notice of Hearing to declare defendant


    in Default

    PURPOSE
    :
    defendant

    To prove the lack of interest of the

    PRAYER
    WHEREFORE, it is most respectfully prayed to this Honorable
    Court that the foregoing attached marked documentary exhibits
    10, including Exhibit 1, 2,3,4 to 4-F-a, 5, 7, 8,
    9, 11 12 13 14 and 15 attached in the records of this
    Court be admitted, including the purposes for which they are
    being offered.
    Upon admission of the foregoing documentary
    testamentary exhibits, the accused rests his case.
    RESPECTFULLY SUBMITTED.
    Marilao for City of Malolos, Bulacan, May ____, 2016.

    and

    NENITA D.C. TUAZON


    TUAZON LAW
    Counsel for the Defendants
    Unit J, 2nd floor, FNR Bldg, MacArthur Hway, Abangan Norte, Marilao, Bul.

    Landline (044) 7111709/mobile 0998-5602610/0922-8431235


    Email address: tuazonlawoffice@yahoo.com
    Roll of Attorney No. 47194
    IBP LIFE NO. 591042 5/19/2003
    PTR NO. 0604821, 1/4/16 Marilao, Bulacan
    MCLE Exemption No. V-001622, Valid until April 14, 2019

    Copy furnished by Registered Mail:

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