REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
BRANCH 13, BAGUIO CITY
SPOUSES TYRONE AND SUSAN DIAZ,
Plaintiffs,
-versus-

Civil Case No: 101279-Q

ALLYSON FANGKINGAN and REGISTER OF DEEDS

BAGUIO CITY,
Defendants.
x----------------------------------------------------------------------------x
COMMENT ON THE FORMAL OFFER
OF DEFENDANTS EVIDENCE
PLAINTIFF, thru undersigned counsel, in the above-entitled case, and unto this
Honorable Court most respectfully manifests her comments and objections to the
Defendants Formal Offer of Evidence for the following reasons:

EXHIBIT

Document

Comment/Objection

Original Certificate of Title Admits

the
existence
and
No. P-2412
authenticity of said exhibit but
objects to the purpose for which it
was offered for being misleading.
The subject property is owned by
both Tyrone and Susan Diaz.

1-A

Name of Tyrone Diaz

Admits the existence of the said

exhibit.

Deed of Absolute Sale of

Realty

Denies the existence and

authenticity of said exhibit but
objects to the purpose for which it
was offered for being misleading.
The deed of sale was simulated
and that the plaintiff has no
intention to sell the property to the
defendant.

2-A
2-B
2-C

2-D

Signature of Tyrone Diaz

Denies the existence and

authenticity of said exhibit.
Signature of Allyson
Denies the existence and
Fangkingan
authenticity of said exhibit.
The portion in the third
Denies the existence and
paragraph which states I authenticity of said exhibit.
hereby sell, transfer, and
convey absolutely and
irrevocably unto and in
favour of Allyson
Fangkingan a five
hundred seventy-one
(571) square meter
portion of the abovedescribed property
The portion in the same
Denies the existence and
paragraph which states
authenticity of said exhibit.
That for and in
consideration of the sum
of one million four
hundred thousand
(1,400,000.00),
Philippine Currency

2-E

The fifth paragraph of the

Deed of Absolute Sale of
Realty which states That
I warrant absolute
ownership of the 571
portion sold herein and
peaceful possession
thereof to the buyer free
from any lien and
encumbrance
whatsoever

Denies the existence and

authenticity of said exhibit.

3 And series

Acknowledgment
Receipts

Denies the existence and

authenticity of said exhibit.

4 And series Checks

5

Denies the existence and

authenticity of said exhibit.
Transfer Certificate of Title Plaintiff admits the same with
no. T-101
reservation as to its genuineness
and due execution.
PRAYER

WHEREFORE, premises considered, the Plaintiff respectfully prays to this

Honorable Court to deny the admission of the foregoing exhibits objected to for the
reasons stated above.
Other reliefs just and equitable are likewise prayed for.

Baguio City, Philippines , 25 March 2016.

Respectfully Submitted:
Counsel for Plaintiffs
Vargas-Abat and Associates
LAW OFFICES
Room 103, BBCCC Bldg,Baguio City
Atty. Ace Vargas
Counsel for the Plaintiffs
PTR No. 078728-1/5/12-Baguio City
IBP no. 892145-1/5/12-Baguio City
Roll No. 32768-Manila
No. 26 Palispis Highway, Bakakeng Central, Baguio City
MCLE COMPLIANCE NO. III-0002134
Tel. No. (074) 444-4444 Cel. No. 0917-444-4444

Copy furnished through Personal Service To:

Rhea B. Maguilao
Counsel for Petitioner
3rd Floor Saklot Plaza,
Legarda Rd, Baguio City