Republic of the Philippines

REGIONAL TRIAL COURT

Third Judicial Region
BRANCH 23
Cabanatuan City

ALBERTO M. BUMANLAG,
Petitioner,

-versus- AGR. CASE NO. 198-AF

LAND BANK OF THE PHILIPPINES,

(LBP), AND DEPARTMENT OF
AGRARIAN REFORM (DAR),
Respondents.
x-----------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

Respondent LAND BANK OF THE PHILIPPINES (LBP), by the

undersigned counsel, and unto this Honorable Court most respectfully offers in
evidence the following documentary exhibits, stating their respective purpose or
purposes, for their admission, to wit:

1. Exhibit “1” and sub-marking

Certified True Copy of the Decision of the Provincial Adjudicator of

the DARAB of Nueva Ecija dated August 05, 2015 consisting of 3 pages and
the Registry Return Receipt dated August 05, 2015.

PURPOSE:

To prove that Provincial Adjudicator of DARAB rendered a Decision

on August 05, 2015 affirming the valuation of the Department of Agrarian
Reform And Land Bank of the Philippines. It is to further prove that the
said Decision was mailed to the _______on August 05, 2018.

2. Exhibits “2”

Certified True Copy of the Certificate of Finality of the Decision of

the Decision of the Provincial Adjudicator of the DARAB of Nueva Ecija
dated August 05, 2015, issued by the Clerk of Adjudicator of DARAB, Nueva
Ecija on February 09, 2016.

PURPOSE:

To prove that Decision of the Provincial Adjudicator of the DARAB of

Nueva Ecija dated August 05, 2015 has become final and executory.
FORMAL OFFER OF DOCUMENTARY EXHIBITS
Agrarian Case No. 198-AF
Page 2 of 8
-----------------------------------------------------------------

3. Exhibit “3” and sub-markings

Certified True Copy of the OLT Land Valuation Worksheet prepared

by Mr. Alipio R. Tupaz.

PURPOSE:

To prove that the valuation factors or inputs gathered during the

field investigation or ocular inspection as well as the data from other
sources such as industry data from the Department of Agriculture,
Municipal Assessors Office, National Statistics Office, or other related
offices, were recorded in the Land Valuation Worksheet.

To prove further that these valuation factors or inputs were used in

the computation of just compensation of the subject property under Claim
No. 03-EO-11-0233, which was reduced into writing, prepared, processed,
examined and reviewed pursuant to DAR AO 1, series of 2010, by the proper
authorities and officers of the Land Bank of the Philippines.

4. Exhibit “4”and sub markings

Certified True Copy of the Claim Processing Form approved by the

approving authorities Ms. Mina Grace C. Francisco and Ms. Lily M. San
Luis.

PURPOSE:

To prove that the revaluation of the subject property made by LBP in

the amount of Eight Hundred Eighty Four Thousand Four Pesos and
55/100 (Php884,004.55) has been approved by the approving authorities,
Ms. Mina Grace C. Francisco and Ms. Lily M. San Luis.

5. Exhibit “5”

Certified True Copy of Certification of Deposit from the OIC/Head of

Agrarian Operations Center III-A, dated December 16, 2011.

PURPOSE:

To prove that the LBP deposited in full the valuation of the subject
landholding in the amount of Eight Hundred Eighty Four Thousand Four
Pesos and 55/100 (Php884,004.55), under Claim No. 03-EO-11-0233 for
TCT No. NT-326005.
FORMAL OFFER OF DOCUMENTARY EXHIBITS
Agrarian Case No. 198-AF
Page 3 of 8
-----------------------------------------------------------------

6. Exhibit “6” submarkings

Certified True Copy of the Order of Payment, dated August 12, 2010

PURPOSE:

To prove that the Department of Agrarian Reform has ordered LBP

to pay the landowner the original valuation of the DAR in the amount of
Thirty Six Thousand, Two Hundred Seventy Seven Pesos and 85/100
(Php36,277.85) under PD 27.

7. Exhibit “7” and submarkings

Certified True Copy of the Land Valuation Summary and Farmer’s

Undertaking,

PURPOSE:

To prove that the land use or land category of the property of the
petitioner relative to Claim No. 03-EO-11-0233 for TCT No. NT-326005 is
LU or Riceland Lowland Unirrigated.

8. Exhibit “8” and sub-marking

Electronic Copy of TCT No. NT-326005

PURPOSE:
To prove that the property covered by TCT No. NT-326005 is owned
by Maxima Ramos.

9. Exhibit “9” and sub-marking

Certified True Copy of the Certification as to AGP for the years 2008
to 2009, issued by the Department of Agriculture through the Office of the
Municipal Agriculturist of Rajal Centro, Santa Rosa, Nueva Ecija.

PURPOSE:

To prove that the Annual Gross Production for Riceland Unirrigated

covered by TCT No. NT-326005, located at Brgy. Rajal Centro, Cabanatuan
City, Nueva Ecija is 80 cavans per hectare.

10. Exhibit “10” and sub-markings

Farm Prices Provincial Summary for the period of July 2008 to June
2009 issued by the Bureau of Agriculture Statistics, Nueva Ecija.
FORMAL OFFER OF DOCUMENTARY EXHIBITS
Agrarian Case No. 198-AF
Page 4 of 8
-----------------------------------------------------------------

PURPOSE:

To prove that the average selling price of palay in the province of

Nueva Ecija for the period of July 2008 to June 2009 is Php14.71/kilogram
which was derived from the data in the Farm Prices Survey Provincial
Summary for the Province of Nueva Ecija issued by the Bureau of
Agricultural Statistics Office, Nueva Ecija.

11. Exhibit “11” and Sub-markings

Notice as to the Zonal Values per Department Order; the Definition

of Terms and the Classification Legend relative to the determination of
Zonal Values; and the Zonal Values of properties located in Barangays
Rajal Centro, Rajal Norte and Rajal Sur, Municipality of Santa Rosa, Nueva
Ecija with an effectivity date of May 08, 2005.

PURPOSE:

To prove that the Zonal Value of the properties classified as Riceland

Unirrigated located in Barangay Rajal Centro, Santa Rosa, Nueva Ecija is
Seven Pesos and 60/100 (Php7.60).

12. Exhibit “12” and submarkings

Summary of Agreements/Resolution on issues and concerns

discussed during the DAR-DENR-LBP-LRA Conference at the Bayview Park
Hotel on April 12 and 13, 2010.

PURPOSE:

To prove that the Zonal Values of real properties located in the

province of Nueva Ecija with an effectivity date of May 08, 2005 are still the
current and valid zonal values.

13. Exhibit “13”

Certification from the Office of the Revenue District Office No. 23B,
South Nueva Ecija dated February 26, 2010.

PURPOSE:

To prove that the first Revision of Zonal Values of Real Properties of

the Province of Nueva Ecija was approved by the Commissioner of Internal
Revenue as per Department Order No. 4-05 dated October 11, 2004 and
became effective May 07, 2005 and will be valid until new Zonal Values of
Real Properties were approved by the higher authority.
FORMAL OFFER OF DOCUMENTARY EXHIBITS
Agrarian Case No. 198-AF
Page 5 of 8
-----------------------------------------------------------------

14. Exhibit “14” and sub-markings

Certified True Copy of the Certification of the Schedule of Unit

Market Values from the Office of the Provincial Assessor, Palayan City dated
January 6, 2011 and Productivity Classification.

PURPOSE:

To prove that the 2006 Base Unit Market Values of different

Agricultural Lands in the province of Nueva Ecija was still the Market
Values implemented or being used at the time of revaluation of the subject
property under DAR AO No. 1, series of 2010.

To prove further that the subject property for Rice Lands (Lowland)
Without Irrigation Facilities is categorized under the 1 st Productivity Class
considering that the land is capable of producing annually for each hectare,
more than 65 cavans of palay, with a Base Unit Value per Hectare as
Php100,300.00.

15.Exhibit “15” and sub-marking

Certified True Copy of the Tax Declaration No. 05-23018-01020 for

Certificate of Title NT-326005.

PURPOSE:

To prove that Location Adjustment Factor (LAF) used in the

computation of Market Value Per Tax Declaration is 87%.

16. Exhibit “16” and sub-marking

Certified True Copy of the Regional Consumer Price Index (RCPI)

for all income households from the National Statistics Office, with Base Year
2000.

PURPOSE:

To prove that the RCPI (Region III for Nueva Ecija) for January
2006 (effectivity of the Schedule of Unit Market Values) is Php131.2.

17. Exhibit “17” and sub-marking

Certified True Copy of the Memorandum from the First Vice

President of Landowners Compensation and Assistance Group, Atty. Ma.
Victoria A. Reyes, dated July 08, 2009.
FORMAL OFFER OF DOCUMENTARY EXHIBITS
Agrarian Case No. 198-AF
Page 6 of 8
-----------------------------------------------------------------

PURPOSE:

To prove that the Regional Consumer Price Index of Region III for
the month of June 2009, taken from the National Statistics Office (NSO) is
Php158.1.

18. Exhibit “18” and sub-markings

The Judicial Affidavit of Ms. Mina Grace C. Francisco comprising of

22 pages and annexes.

PURPOSE:

To prove that the same shall take the place of LBP’s witness - Ms.
Mina Grace C. Francisco’s direct testimony.

To further prove that Ms. Mina Grace C. Francisco revalued the

subject property under TCT No. NT-326005 for Claim No. 03-EO-11-0233
pursuant to the formula as translated in the DAR Administrative
Order No. 01, series of 2010, implementing Republic Act No. 9700.

WHEREFORE, in view of the foregoing above enumerated exhibits, it

is respectfully prayed of this Honorable Court that the Exhibits “3” to “18”
and submarkings duly marked and identified by LBP’s witness during her
direct testimonies and which were attached in her Judicial Affidavit filed
before this Honorable Court and hereto attached certified true copies of
Exhibit “1” and “2”, be considered and admitted as documentary evidence
for respondent Land Bank of the Philippines.

Other reliefs as it may deem just and equitable under the premises are
likewise prayed for.

Respectfully submitted.

Cabanatuan City, Nueva Ecija this 16th day of October 2018.

LBP LEGAL SERVICES GROUP

FIELD LEGAL SERVICES DEPARTMENT
AREA LEGAL UNIT II-CENTRAL LUZON
Counsel for Respondent LBP
FORMAL OFFER OF DOCUMENTARY EXHIBITS
Agrarian Case No. 198-AF
Page 7 of 8
-----------------------------------------------------------------

3rd Floor, LBP Building

Cor. Gen. Tinio and Gabaldon Sts. Cabanatuan City
Tel No. 044-463-2703

By:

JAYBEE LYN G. LIKIGAN

Roll No. 68879
PTR NO. Exempt per SC En Banc Resolution
dated 12-10-14 on B.M. 2889
IBP NO.0999292/ 01-09-2018 Mountain Province Chapter
MCLE Exemption No. Exempt (New Passer)
(By Authority of the Office of the Government
Corporate Counsel (OGCC) dated June 28, 2018)

Copy furnished :

ATTY. ALVIN B. SORIANO

DAR-Legal Office
Mabini Extension, Cabanatuan City

ATTY. FELIPE R. DE BELEN

#150 Gabaldon St., Cabanatuan City

MAXIMA RAMOS, Rep. By:

Alberto Bumanlag
Sto. Tomas, Aliaga, Nueva Ecija

EXPLANATION

Copies of the foregoing Formal Offer were sent to the other parties and
counsels thru registered mail for lack of messengerial officer who would effect
personal service.

JAYBEE LYN G. LIKIGAN

FORMAL OFFER OF DOCUMENTARY EXHIBITS
Agrarian Case No. 198-AF
Page 8 of 8
-----------------------------------------------------------------

NOTICE OF HEARING

The Branch Clerk of Court/OIC

Regional Trial Court
Branch 23
Cabanatuan City

Madam:

Please submit the foregoing Formal Offer of Documentary Evidence for the
kind consideration and admission of the Honorable Court immediately upon
receipt hereof.

Thank you very much.

JAYBEE LYN G. LIKIGAN

EXPLANATION

Copies of the foregoing Formal Offer were sent to the other parties and
counsels thru registered mail for lack of messengerial officer who would effect
personal service.

JAYBEE LYN G. LIKIGAN