REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

8th Judicial Region
Branch ______
City of Tacloban

CHLOE MARIELLE DE LA CRUZ,

Plaintiffs,

-versus- CIVIL CASE No. _______

FOR: Quieting of Title with
Temporary Restraining Order
and Preliminary Injunction

ASHTON PAMINTUAN,
Defendant.

x-----------------------------------x

FORMAL OFFER OF EVIDENCE

COMES NOW, the defendant, through the undersigned counsels and

unto this Honorable Court, most respectfully offer the following evidences:

EXHIBIT DESCRIPTION PURPOSE

Exhibit 1 Registry Receipt To prove that the defendant send a

letter to Julia de la Cruz while the
latter is in US.

Exhibit 2 Deed of Conditional Sale To prove the veracity of the

document and that plaintiff, Julia
de la Cruz consciously and
voluntarily executed the Deed of
Conditional Sale
 Exhibit 3-1 Judicial Affidavit of defendant, To prove that the parties, Julia de la
Ashton Pamintuan Cruz and Ashton Pamintuan the
defendant consciously and
voluntarily executed the Deed of
Conditional Sale

Exhibit 3-2 Judicial Affidavit of Nico Robin, To prove that the Deed of
witness; Conditional Sale was voluntarily
signed personally by Julia de la
Cruz without attending any
circumstances.

Exhibit 3-3 Judicial Affidavit of Felipe Same as above.

Manciano, witness;

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed

that this Honorable Court take cognizance of the evidences offered.

Other reliefs just and equitable are likewise prayed for.

1 February 2016, Tacloban City, Philippines

Leonida, Marquez, and Montallana Law Office

4th Flr. Bldg.
Cor. Real and Imelda Avenida Sts.
Tacloban City

By:

ATTY. KERWIN GERARD REYNATO LEONIDA

Counsel for the Defendant
PTR No. 1326618 01/02/2013
IBP No. 884305 12/20/2012
 Roll No. 57384
MCLE No. III-0019301
Date Issued: 10/10/2012

ATTY. ROD FRANCIS MARQUEZ

Counsel for the Defendant
PTR No. 1326619 01/02/2013
IBP No. 884306 12/20/2012
Roll No. 57385
MCLE No. III-0019302
Date Issued: 10/1/2014

NEIL MONTALLANA
Counsel for the Defendant
PTR No. 1326620 01/02/2013
IBP No. 884307 12/20/2012
Roll No. 57386
MCLE No. III-0019303
Date Issued: 09/1/2013

Copy Furnished By Personal Service:

Atty. MARY IVY M. PACALA Receipt No. ____________

Counsel for Petitioner
2nd Flr BPI Bldg
cor. J. Romualdez del Pilar st.,
Tacloban City
 PROOF OF SERVICE

I, Tim Machiney, messenger of Atty. Niel A. Montallana, herein

counsel for Defendant Ashton Pamintuan, hereby certify that I
personally delivered Defendants Formal Offer of Evidence dated 1
February 2016 to Atty. Mary Ivy M. Pacala, counsel for the Plaintiff,
with address at 2th Floor, BPI Bldg, cor. J. Romualdez del Pilar st.,
Tacloban City. The defendant Formal Offer of Evidence was received
by counsel personally.

TIM MACHINEY

SUBSCRIBED AND SWORN to before me this 1TH day of February

2016 at Tacloban City, personally appeared affiant TIM MACHINEY
and exhibiting to me his Drivers License with License No. N-12345,
issued at the Tacloban City on 12 February 2014.

Doc. No.______;

Page No.______;

Book No.______;

Series of 2016