Republic of the Philippines

METROPOLITAN TRIAL COURT

National Capital Region
Branch 71, City of Pasig

ARIEL M. ANTONIO (ATTY.-IN-

FACT OF ANNA ROSA CARPIO,
MILAGROSA ANTONIO, MA.
LOURDES ANTONIO
ESPADINES, MANUEL M-PSG-18-01585-SC
ANTONIO, ALLAN ANTONIO, For: Ejectment and Damages
ARNOLD ANTONIO, MARIA
TERESA ANTONIO AND
DANILO ANTONIO,
Plaintiffs

- versus –

CARMELITA ANUNUEVO,
AMELITA ANUNUEVO AND
EDITHA CRUZ
Defendants.
x------------------------------------------------------x

SUBMISSION

The undersigned counsel, most respectfully submits the herein

attached Judicial Affidavit of the following:

1. EDITHA CRUZ
2. DEO CRUZ
3. ROSANNA I. MANGILA PALOMA

The following are the purposes of their testimony:

1. To prove that Editha Cruz has been in the lawful possession of a

portion of the subject property;
2. To prove that the subject property remains undivided;
3. To prove that the Epifania Ignacio and her legal heirs gave her the
permission to occupy a portion of the subject property;
4. To prove that said tolerance and permission has not been revoked;
 5. To prove that the Plaintiffs has failed to comply with the essential
requisites for a case of ejectment to prosper;
6. To prove that the legal heirs of Epifania Ignacio has donated to
Editha Cruz a portion of the subject parcel of land; and
7. To prove that some of the Plaintiffs have already sold their share over
the parcel of land.

Pasig City, 7 October 2018.

KATRINA C. MULI
Counsel for Defendant
IBP Lifetime Member No. 0811843
Roll No. 62271
MCLE Compliance V-4367/10.17.2014
40. JR Jabson St., Bambang
Pasig City

COPY FURNISHED:

ARIEL ANTONIO
As Plaintiff and Attorney-in-Fact of
Anna Rosa Carpio, Milagrosa Anotnio,
Ma. Lourdes Carpio Espadines, Manuel
Antonio, Allan Antonio, Arnold Antonio,
Ma. Teresa Antonio and Danilo Antonio

No. 5 Parkwood Lane, Parkwood Greens Phase 2,

Executive Village, Maybunga, Pasig City

E X P L A N A T I ON
(Under Sec.11, Rule 13, and New Rules on Civil Procedure)

The foregoing SUBMISSION was served by REGISTERED MAIL

due to lack of personnel to effect personal service and distance between
offices.

KATRINA C. MULI