REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
BRANCH 12, LAOAG CITY

REPUBLIC OF THE PHILIPPPINES

Represented by the DEPARTMENT
OF ENERGY (DOE),
Plaintiff,

-versus- CIVIL CASE NO. 16903-12

For: Expropriation

THE UNKNOWN HEIRS OF MAURA

LIGOT and the CITY ASSESSOR OF
LAOAG CITY, ILOCOS NORTE,
Defendants.
x------------------------------------------------------x

MOTION FOR LEAVE TO INTERVENE

COMES NOW THE MOVANTS, through counsel, before this

Honourable Court, most respectfully requests for leave to intervene in the
above-captioned case, on the following grounds:

That the movants are the purchasers of the real property (Lot No.
12859) subject matter of the instant case;

That the movants have a personal, direct and legal interest in the
matter in litigation, and in the outcome of this case, not to mention that
they are so situated as to be adversely affected by the expropriation or
other disposition of the parcel of land, subject matter of the instant case;

That this intervention will not, in the least, unduly delay or prejudice
the rights of the original parties in the case;

That the rights of the movants rights can be fully protected in this
proceeding rather than by filing a separation action.

WHEREFORE, premises considered and in the interest of justice, it

is most respectfully prayed that after due notice and hearing, an Order be
issued by this Honourable Court:

a. Allowing the movants to intervene in this action as a party

defendant;

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 b. Giving movants a period of FIFTEEN (15) DAYS to file their Answer-
in-Intervention, attached to this Motion.

Other reliefs that are just and equitable under the premises are
likewise prayed for.

RESPECTFULLY SUBMITTED. January _____, 2020. Laoag City,

Philippines.

ATTY. JASON BADER LL. PERERA

Counsel for Movants
Roll of Attorney’s No. 54820 / 30 April 2008
IBP No. 089752 / L.C. – 12/28/2019
PTR NO. 2043610 / L.C. - 01/02/2020
MCLE No. VII-0000263, 07/30/2019
Brgy. 6, #62, Rizal St., Laoag City
Mobile Phone No. +639207042030

NOTICE

OFFICE OF THE SOLICITOR GENERAL

Counsel for the Plaintiff Department of Energy

GREETINGS: Kindly take notice that the foregoing Motion For Leave to Intervene
will be submitted for the consideration of this Honourable Court on January 31, 2020
at 8:30 AM, or as soon as matter and counsel may be heard.

ATTY. JASON BADER LL. PERERA

THE CLERK OF COURT

RTC BRANCH 12
LAOAG CITY

GREETINGS: Kindly submit the foregoing Motion For Leave to Intervene on

January 31, 2020 at 8:30 AM, for the consideration and approval of this Honourable
Court, or as soon as matter and counsel may be heard.

ATTY. JASON BADER LL. PERERA

Copy Furnished:
OFFICE OF THE SOLICITOR GENERAL
134 Amorsolo Street, Legaspi Village
Makati City

EXPLANATION/COMPLIANCE

The foregoing pleading is being served by registered mail due to distance, time
constraints and lack of personnel to effect personal service.

ATTY. JASON BADER. LL. PERERA

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