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Republic of The Philippines: (Attached To The Records of The Honorable Court)

This document is a formal offer of documentary exhibits submitted by the defendants in the civil case of Virginia L. Pabanil et al. vs Oscar A. Mojica et al. for the purpose of a judicial partition with damages. The defendants submit 11 exhibits including title certificates, affidavits, and agreements to prove that the deceased couple owned the subject property and that some of the defendants are rightful co-owners through inheritance. The defendants request that all exhibits and witness testimony be admitted for the purposes described.

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231 views3 pages

Republic of The Philippines: (Attached To The Records of The Honorable Court)

This document is a formal offer of documentary exhibits submitted by the defendants in the civil case of Virginia L. Pabanil et al. vs Oscar A. Mojica et al. for the purpose of a judicial partition with damages. The defendants submit 11 exhibits including title certificates, affidavits, and agreements to prove that the deceased couple owned the subject property and that some of the defendants are rightful co-owners through inheritance. The defendants request that all exhibits and witness testimony be admitted for the purposes described.

Uploaded by

annamariepagtabunan
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

Fourth Judicial Region


Regional Trial Court
Branch 91, Quezon City

VIRGINIA L. PABANIL,
ERLINDA L. RAMOS,
FRANCISCO M. LIGSAY,
JOSE M. LIGSAY,
AND GLORIA L. MOJICA,
Plaintiffs,

-versus- Civil Case No. Q-11-68590


For: Judicial Partition with
OSCAR A. MOJICA, Damages
JOSEPHINE M. PEDRINA,
ARMANDO L. MOJICA,
ROLANDO L. MOJICA,
AND WILFREDO L. MOJICA,
Defendants.
x--------------------------------------------x

DEFENDANTS FORMAL OFFER


OF DOCUMENTARY EXHIBITS

DEFENDANTS, through counsel and in compliance with the


Order of this Honorable Court, most respectfully submit their Formal
Offer of Documentary Exhibits and in support thereof states: That

EXHIBITS DOCUMENTS PURPOSE

1 TCT No. 53337 To prove that the deceased


(Attached to the Records spouses Francisco and
of the Honorable Court) Florencia Ligsay owned a real
property situated at No. 14
Mabilis Street, Barangay
Pinyahan, Quezon City
consisting of about 227.50
square meters, more or less and
such other relevant matters.

2 Memorandum of To prove that the plaintiffs


Agreement dated were able to sell their shares
22 July 2010
(Attached to the Records over the subject property to
of the Honorable Court) Spouses Lim and such other
relevant matters.

3 and Sinumpaang
To prove that Spouses Lim
4 Salaysay of Tirso
Senando and Nelia were renting out portions of the
Areza subject property to third
(Attached to the Records persons and such other
of the Honorable Court) relevant matters.

9 to 9- Judicial Affidavit and To prove that one of the


1 signature of Defendants, Josephine Pedrina
Josephine Pedrina
is one of the co-owners of the
(Attached to the Records
subject property being an heir
of the Honorable Court)
of Rosario L. Mojica (sister of
the Plaintiffs) and such other
relevant matters.

10 to Judicial Affidavit and To prove that one of the


10-1 signature of Defendants, Armando Mojica
Armando Mojica
is one of the co-owners of the
(Attached to the
subject property being an heir
Records of the
of Rosario L. Mojica (sister of
Honorable Court)
the Plaintiffs) and such other
relevant matters.

PRAYER

WHEREFORE, premises considered, it is most respectfully


prayed of this Honorable Court that the documentary exhibits formally
offered as well as all testimony of the witnesses in the instant case be
ADMITTED for the purposes for which they are being offered.

OTHER RELIEFS, just and equitable, are likewise being prayed


for.

RESPECTFULLY SUBMITTED.
Quezon City, 17 May 2017.
ALFEROS ARMAS & ASSOCIATES
Law Office
Unit K, No. 1143 San Francisco Del Monte Ave.,
Barangay Paltok 1105, Quezon City

By:

JOHN THOMAS S. ALFEROS III


PTR No. 3846308; 01.07.17 Q.C.
IBP No. 137009; 01.09.17; Q.C.
Roll No. 48188; Page No. 138; Book no. XX
MCLE Compliance No. V-0019255; 04.15.16 until 04.14.19
Mobile No. 0918-9390566
jtsalferosiiilaw@yahoo.com

Copy Furnished:

Atty. Emil Anton M. Coronel R.R. ___________


Unit 10 4F Manican Building 17 May 2017
9802 Kamagong St., Quezon City Hall P.O.
San Antonio Village, Makati City

Atty. Lenito T. Serrano R.R. ___________


12F Strata 100 Building, 17 May 2017
F. Ortigas Jr., Road, Quezon City Hall P.O.
Ortigas Center, Pasig City

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

Copy of the foregoing Formal Offer was served to the counsels of the
plaintiffs and plaintiffs-in-intervention by registered mail due to distance
and lack of personnel of the undersigned counsel to effect personal service
for which the kind understanding of this Honorable Court is pleaded.

JOHN THOMAS S. ALFEROS, III

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