Republic of the Philippines
REGIONAL TRIAL COURT
SIXTH JUDICIAL REGION
Branch 55, Bacolod City
SPOUSES ROLANDO T. LIMA AND
ROSEMARY LIMA,
Plaintiffs,
-versus- Civil Case No. 887
Annulment of Declaration
of Heirship and TCT No.
T- 17899 with Damages
HEIRS OF THE LATE TOMAS
LEDESMA herein represented by
RESTITUTA LEDESMA AND CONCEPCION
LEDESMA, HEREIN REPRESENTED BY
JOSE MARIA LEDESMA, Attorney-in-fact,
Defendants.
X--------------------------------X
ENTRY OF APPEARANCE
WITH NOTICE OF DEATH, SUBSTITUTION OF
PARTIES AND MOTION TO REVIVE
COME NOW, the heirs of Rolando Lima namely her spouse Rosemary, her children
Rolando, Jr., Rommel, Rothschild, Reinhart, Barbara Jessica, all surnamed Lima, through the
undersigned counsel, and unto this Honorable Court, respectfully state:
1. That the undersigned counsel hereby formally enters his appearance as counsel of
the plaintiffs in this case; thus, he requests that he be furnished with all communications,
correspondence, pleadings, orders, decisions and other similar documents in this case;
2. That on August 12, 2005, Acting Presiding Judge Edgardo L. Catilo rendered an
Order sending this case to the archive on the ground that summons was not properly sent to
defendant Concepcion Ledesma thereby jurisdiction over her was not acquired;
3. That Plaintiff Rolando Lima who actively initiated this case, died on October 21,
2008, thus no efforts were made to supply this Court with the correct address of the respondents,
a copy of his Certificate of Death is attached hereto as Annex “A”;
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4. That Plaintiff Rolando Lima was survived by his wife Rosemary Lima and the above-
named children; that the heirs respectfully request that they be substituted on behalf of Rolando
T. Lima as plaintiffs in this case;
5. That the heirs have received information that the defendants live at 199 Brgy San
Pedro, Binalbagan, Negros Occidental, where they could be served with summons and other
processes of this court.
PRAYER
WHEREFORE in view of the foregoing, it is respectfully prayed that the entry of the
undersigned counsel for the plaintiffs be noted, that plaintiff Rolando T. Lima be substituted by
his heirs, that the case be revived and that summons be sent to the defendants at the above-
mentioned address.
Other reliefs which are just and equitable in the premises are likewise prayed for.
Bacolod City, December 19, 2012.
MANLAPAO & MANLAPAO
LAW OFFICE
Counsel for the Petitioners
759 Javelona St., Villamonte
Bacolod City
(034)434 8355
attyjunmanlapao@ymail.com
By:
EDMUNDO F. MANLAPAO, JR.
IBP No. 848771-1/06/2012
PTR No. 4646263
Issued in Bacolod City
On January 6, 2011
MCLE Compliance. No. III 0007592, January 19, 2010
MCLE Compliance. No. IV 0001437, February 9, 2011
Issued in Pasig City, Philippines
NOTARIAL COMM. NO. 0070-12
Roll of Attorneys No. 50955, May 5, 2005
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The Clerk
RTC, Branch 55,
Himamaylan City
Greetings:
Please submit the foregoing motion for the consideration and approval of this Court on
Friday, January 25, 2012 at 8:30 AM.
EDMUNDO F. MANLAPAO, JR.
RESTITUTA and
JOSE MARIA LEDESMA,
199 Brgy San Pedro, Binalbagan,
Negros Occidental
Greetings:
Please take note that the undersigned counsel will submit the foregoing motion for the
consideration of the Honorable Court on Friday, January 25, 2012 at 8:30 AM.
EDMUNDO F. MANLAPAO, JR.
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VERIFICATION
I, ROSEMARY LIMA, of legal age, Filipino, and resident of Himamaylan, Negros
Occidental, after first being duly sworn to an oath depose and state:
That I am one of the plaintiffs in this case;
That I have caused the foregoing to be prepared;
That I have read the same and all allegations thereof are true and correct of my personal
knowledge and based on authentic records of this case;
IN WITNESS WHEREOF, I have hereunto affixed my signature this 19 th day of
December, 2012 in the City of Bacolod, Philippines.
ROSEMARY LIMA
Affiant
SUBSCRIBED AND SWORN to before me this 19 th day of December, 2012 in the City
of Bacolod, Philippines, by affiant who exhibited to me her
___________________________________________.
Doc. No. _______;
Page No. _______; EDMUNDO F. MANLAPAO, JR.
Book No. ______; NOTARY PUBLIC
Series of 2012. UNTIL DEC. 31, 2012
PTR NO. 4205885
ISSUED AT BACOLOD CITY
ON JAN. 4, 2011
NOTARIAL COMM. NO. 0070-12
Roll of Attorneys No. 50955
Copy furnished:
RESTITUTA and
JOSE MARIA LEDESMA,
199 Brgy San Pedro, Binalbagan,
Negros Occidental
RR No. _____________
December 19, 2012
