Formal Offer of Exhibits

 

REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION REGIONAL TRIAL COURT BRANCH 100, QUEZON CITY

IN RE: CANCELLATION OF LEGAL ENCUMBRANCE UNDER SEC.7, R.A. NO. 26 ON TCT NO. N-41674 OF THE REGISTRY OF DEEDS OF QUEZON CITY LRC No. 123780 SPS. JUAN MIGUEL SANCHEZ and MARIA SANCHEZ, Petitioners. x-----------------------x------------------------------------------------------------------------------x ---------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE  Petitioners, by counsel, unto the Honorable Court, most respectfully offers for admission the following documentary exhibits which were identified by Petitioner Miguel Sanchez and who testified thereon, as part of his testimony, and for theJuan following specific purpose and other related matters:

EXHIBIT

NATURE

PURPOSE

“A” 

Petition for Cancella Cancellation tion of Encumbrance

To prove existence of the Petition

“B” 

Order of Hearing dated 9 December 2015

To prove complianc compliancee  with jurisdictional jurisdictional requirements requiremen ts of notice and posting

“B-1” 

Proof of mailing of copy of above Order to the Office of the Solicitor General

“B-2” 

Proof of mailing of copy of above Order to the Department Departme nt of Environmentt and Environmen Natural Resources

“B-3” 

Proof of mailing of copy of above Order to the Office of the City Prosecutor

“B-4” 

Proof of mailing of copy of above Order to the Register of Deeds of Quezon City

“B-5” 

Proof of mailing of copy of above Order to the

 

 

“B-6” 

“C”  “D” 

“D-1” 

“D-2” 

“E” 

Office of the City  Attorney Proof of mailing of copy of above Order to the Land Registration  Authority Certificate of Posting dated 14 January 2016 Copy of Deed of  Absolute Sale between between Spouses Juan Miguel Sanchez and Maria Sanchez and Philippine National Bank dated 3 March 2008

To prove that Petitioners legally acquired ownership of Lot No. 7H covered by Transfer Certificate of Title No. N- 41674 and the townhouse built thereon

Signature of Juan Miguel Sanchez as  vendee Signature of Maria Sanchez as vendee Copy of Transfer Certificate of Title No. N-41674

“E-1” 

Stamped annotation pursuant to Section 7 of RA 26 found at the back portion of TCT No. N41674

To prove that Petitioners are the registered owners of Lot 7-H covered by TCT No. N41674 To prove the existence of an encumbrance pursuant to Section 7, RA 26 on TCT No. N41674

“F” 

Original Certification dated 20 October 2015 issued by Ms. Rosanna Reyes, Records Officer, of the Register of Deeds of Quezon City

To prove that the Register of Deeds of Quezon City has issued a certification certificati on that the two-year lien provided under Section 7 of RA26 annotated at the back of TCT No. N-41674 has already expired on 20 November 1992 without anybody laying claim or interest thereon To prove that no person has registered any claim on the property subject of this case

“G” 

Certified Copy of Tax Declaration No. E125679

To prove that Petitioners are the declared owners of Lot 7-H covered by TCT No. N-41674

 

To prove that Petitioners are the declared owners of the townhouse built on Lot 7-H covered by TCT No. N-41674

“H”

Certified Copy of Tax Declaration Declarat ion No. D-15748 

“I”

Tax Clearance Certificate To prove that Petitioners issued by the City have paid taxes for the Treasurer of Quezon City lot for the current year.

“I-1” 

“J” 

“J-1” 

“K” 

“K -1” 

Notation above Tax Clearanceinthat previous payments are verified using computer records

To prove that Petitioners have been paying taxes for the lot for the previous years. Tax Clearance Certificate To prove that Petitioners issued by the City have paid taxes for the Treasurer of Quezon City townhouse on the subject lot for the Notation in above Tax current year. Clearance that previous payments are verified To prove that Petitioners using computer records have been paying taxes for the townhouse on the subject lot for the previous years.  Judicial Affidavit of To prove that he is one Juan Miguel Sanchez of the Petitioners in this dated 1 May 2016 case and he owns the parcel of land covered by TCT No. N-41674 Signature of Juan Miguel Sanchez To prove that TCT No. N- 41674 has an encumbrance relating to Section 7 RA26 annotated on the back portion thereof To prove that he has secured a Certification from the Registry of Deeds of Quezon City that above encumbrance on TCT No. N- 41674 has already expired on 11 November 1992 To prove that no person has made any claim on the property

To prove that, as owner of the property, he has  been paying taxes taxes for the same The foregoing exhibits were marked during the initial hearing or trial. Their original or certified true copies already form part of the record of this case and have already been submitted to the Honorable Court.

 

Comparison with the original documents was done during trial wherein  witness who testified thereon was presented and duly identified and affirmed the same. PRAYER  WHEREFORE, it is respectfully prayed that the foregoing exhibits be admitted for the purposes for which they are respectively offered in evidence.

Other reliefs which are just and equitable are likewise prayed for. 15 April 2016, Quezon City.

BERNADETTE STA. MARIA Counsel for Petitioners Roll No. ____ Lifetime IBP No. ____; Quezon City PTR No. _____ ; Quezon City MCLE Compliance No. _______; 2/20/2013; Pasig City Tel. No. _____

EXPLANATION The foregoing Formal Offer is being served through licensed courier due to

lack of personnel to effect personal service. BERNADETTE STA. MARIA

Copy furnished: Office of the Solicitor General 134 Amorsolo St., Legaspi Village, Makati City The Register of Deeds for Quezon City East Avenue, Diliman, Quezon City Land Registration Authority East Avenue, Diliman, Quezon City City Prosecutor’s Office  Office  Quezon City Hall, Quezon City City Attorney’s Office  Office  Quezon City Hall, Quezon City Dept. of Environmen Environmentt & Natural Resources  Visayas Avenue, Avenue, Quezon City