Beruflich Dokumente
Kultur Dokumente
ASHTON PAMINTUAN,
Defendant.
x-----------------------------------x
1
A copy of Letter sent by defendant is hereby attached and marked as Exhibit 1.
2
A copy of Registry Receipt is hereby attached and marked as Exhibit 2.
4. Julia de la Cruz, upon returning home from the United States, came
up with an oral agreement with the defendant dated April 6, 2011,
subjecting the Transfer Certificate of Title (TCT) No. 10070, which was
then still within the possession of the defendant, to a conditional sale,
hence the execution of the deed of sale;
6. Defendant denies paragraph 15 and 18, and asserts that the deed of
sale was genuinely and duly executed as it appears and that the
signatures which appears thereon are true as to the respective
signatories thereof, as sustained by the judicial affidavits of the
witnesses3 to the execution of the instrument;
Prayer
2. Confirming the validity of the sale and granting the subjected deed of
sale to be recorded in the proper Registry of Deeds;
3
Copies of the Judicial Affidavits of the Witnesses are hereby attached and marked as Exhibit 3, 4 and
5
4
Copies of the Receipts issued by Julia de la Cruz are hereby attached and marked as Exhibits 6, 7 and
8, 9, 10 and 11.
3. Denying the grant of the temporary restraining order sought by
plaintiff to restrain the defendant from fencing the property; and
4. Granting such other reliefs as are just and equitable under the
premises.
By:
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
VERIFICATION
I, ASHTON PAMINTUAN, of legal age and a resident at Brgy. 25
Tacloban City, after having been duly sworn, deposes and states that:
1. I am the respondent in the above stated case;
3. I have read the contents thereof and the facts stated therein are
true and correct of my personal knowledge and/or on the basis of
the documents and records in my possession;
ASHTON PAMINTUAN
Affiant
JURAT
Service of copy of this pleading upon ATTY. MARY IVY M. PACALA was done
by registered mail for the reason of lack of personnel to effect personal
service.
A Pleasant Day!
Hello! How are you? Hear that you are enjoying your new home out there.
Anyway, I have caused the making of this letter as I would like to notify you about the
transfer certificate title that I borrowed from you.
Hoping for your kind consideration and hope to hear from you, in as much as
I would like to see you soon. Take care!
Your friend,
Ashton Pamintuan
Exhibit 2
Exhibit 6
Exhibit 7
Exhibit 8
Exhibit 9
Exhibit 10
Exhibit 11