Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Second Judicial Region
Branch 02
Santiago City

ELCY T. AALA,
Plaintiff,
CIVIL CASE No. II=17-008
-versus- For: Annulment of Transfer
Certificate of Title No. 165-
2016003386, Deed of Sale and Tax
PHILIP C. ALMAZAN, Declaration No. 175-0018-04879
with Damages and Prayer for
SPOUSES NOMER and
Temporary Restraining Order and
HERMINIGILDA D.
Writ of Preliminary Injunction.
COLOBONG and THE
REGISTER OF DEEDS OF
SANTIAGO CITY,
Defendants.
x- - - - - - - - - - - - - - - - - - - - -x

FORMAL OFFER OF EXHIBITS

(For the Plaintiff)

The undersigned counsel for the plaintiff in the above-entitled case,

unto this Honorable Court most respectfully submit the foregoing
documentary exhibits, and avers:

EXHIBIT PARTICULARS

“A” - Transfer Certificate of Title No. T-

273981 in the name of
Hermenegilda D. Colobong married
to Nomer G. Colobong issued on 30
September 1997;

“A-1” - Entry No. 1331 found on page 2 of

the title;

“A-2” - Entry No. 1686 found on page 2 of

the title;
 “A-3” - Entry No. 2015003421 found on page
5 of the title;

PURPOSE: To prove that Hermenigilda D. Colobong was the registered

owner of the land subject of this case which was mortgaged
subsequently to QUEDAN AND RURAL CREDIT
GUARANTEE CORPORATION on 25 January 1999 for and in
consideration of the sum of Php150,000.00. The mortgage loan
was subsequently paid on 28 May 2013 upon the execution of
Release of Mortgage both entered at the back of the title. Also,
to prove that plaintiff executed a Notice of Adverse Claim
dated 14 July 2015;

“B” - Statement of Account in the sum of

Php 150,000.00;;

PURPOSE: To prove that plaintiff and defendant Hermenigilda agreed to

obtain a loan from Edmund Alvarez in the sum of
Php150,000.00 on 19 January 2004;

“C” - Deed of Absolute Sale dated 18

September 2008 executed by
Hermenigilda D. Colobong in favor
of Elcy T. Aala;

PURPOSE: To prove that Hermenigilda Colobong with the marital

consent of her husband, Nomer G. Colobong sold the land in
suit to Elcy T. Aala for and in consideration of the sum of
Php750,000.00;

“D” - Affidavit of Adverse Claim dated 14

July 2015 executed by Elcy T. Aala;

PURPOSE: To prove that Elcy T. Aala executed an Affidavit of Adverse

Claim which was duly annotated on the title of Hermenegilda
D. Colobong;

“E” - Deed of Absolute Sale dated 2

November 2016 executed by
Hermenigilda D. Colobong with the
marital consent of Nomer G.
Colobong;

2
PURPOSE: To prove that Hermenegilda D. Colobong with the marital
consent of Nomer G. Colobong sold the land in suit in favor of
Philip Almazan for a price of Php250,000.00;

“F” - Transfer Certificate of Title No. 165-

2016003386 in the name of Philip C.
Almazan issued on 6 December
2016;

PURPOSE: To prove that a title of ownership over the subject parcel of

land was issued in favor of Philip C. Almazan;

“G” - Contract of Lease dated 15 April

2014 executed by Elcy T. Aala as
Lessor and Aurel Abner L. Medina
as Lessee;

PURPOSE: To prove that Elcy T. Aala and Aurel Abner L. Medina entered
into a Contract of Lease over the subject parcel of land;

“H” - Tax Declaration of Real Property

No. 175-0018-04879 in the name of
Philip C. Almazan;

Purpose: To prove that Philip C. Almazan was able to secure a Tax

Declaration over the subject property;

With the admission of the foregoing Documentary Exhibits and the

testimony of the plaintiff herself, we respectfully rest our case.

RESPECTFULLY SUBMITTED.

Santiago City, 10 September 2018.

THE LAW OFFICES OF DAMASEN & SUBIA

Unit 5, Mango Suites, Calao East, Santiago City
E-mail: lmdlawoffice@gmail.com
Mobile No.: 09178730405
Tel. No.: (078) 305-2392

By:

3
 ATTY. LUCKY M. DAMASEN
Counsel for the Plaintiff
MCLE Compliance No. V-008089/06-04-15
PTR No. 2398537/Santiago City/01-03-2018
IBP No. 021276/IBP National Office, Pasig City/01-05-2018
Roll No.37959/07-24-92

Copy furnished:

Atty. Earnest A. Soberano

130 Carreon Street, Centro East
Santiago City
/by registered mail

EXPLANATION
(Pursuant to Section 11; Rule 13
of the 1997 Rules of Civil Procedure)

Copy of this Formal Offer was duly served to Atty. Earnest A.

Soberano via registered mail with return card, instead of personal service,
due to time constraints and lack of personnel to effect personal service.

RYAN JAY P. BAÑEZ