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JULIAN MORDEN TALLANO, Represented by Mario T. Papa, Complaina nts, – versus – ROLLY LIWAG, Respond ent. x-------------------------------------------x
I.S. No. XV-03-INV-11G05190 FOR: MALICIOUS MISCHIEF
C UTR FI AI ONE - F V A D T
I, ROLLY LIWAG y LEBAG of legal age, married with address at 12-F Gateway Garden Ridge Condominium, EDSA, Barangay Ilaya, Mandaluyong City, after having been duly sworn in accordance with law, hereby depose and say:
1. I am a former Overseas Filipino Worker with Philippine Passport No.
XX3587912, who has worked in the Middle East since 1978 and had just retired last June 30, 2010, copy of which passport as Annex “1” is made an integral part hereof;
2. I am the same person also known as “ORLANDO” or “ROLANDO”
LIWAG y LEBAG, as certified by VICE CONSUL GERMINIA V. AGUILARUSUDAN and entered in the Registry of the Embassy of the Philippines, stationed in Abu Dhabi, United Arab Emirates as Certificate No. 0048-
Barangay Culiat. situated along Congressional Avenue Extension. N-265460” of the Registry of Deeds of Quezon City. and which is more particularly described in “Transfer Certificate of Title No. XX4764514 is the registered and absolute owner in fee simple of a certain parcel of land denominated as Lot 1 Block 8 of (LRC) Pcs-13474. 5. situated along Congressional Avenue Extension. My daughter. 4. Quezon City. single. N265459” of the Registry of Deeds of Quezon City.m. Filipino. EB0721254 is the registered and absolute owner in fee simple of a certain parcel of land denominated as Lot 2 Block 8 of (LRC) Pcs-13474. Quezon City.” more or less.” more or less.m. and which is more particularly described in “Transfer Certificate of Title No. 3. holder of Philippine Passport No. copies of such 2 . ROLAND LIWAG y VILIRAN.). who are my children. My son. containing an area of “Four Hundred Seventy Six Square Meters (476 sq.). Barangay Culiat. ZAIDA LIWAG y VILIRAN. copies of their respective Special Powers of Attorney and Birth Certificates as Annex “3” to “31” and “4” to “4-1” are made an integral part hereof. single.2000. a copy of which certification as Annex “2” is made an integral part hereof. containing an area of “Four Hundred Fifty Three Square Meters (453 sq. Filipino. holder of Philippine Passport No. I am the attorney-in-fact of ZAIDA LIWAG y VILIRAN and ROLAND LIWAG y VILIRAN. copies of such passport and title as Annex “5” and “5-1” are made integral parts hereof.
copies of such “Deeds of Donation” as Annex “9” and “9-1” are made integral parts hereof. 2004 SALUD L.passport and title as Annex “6” and “6-1” are made integral parts hereof. 7. registered and absolute owners of the subject property. donated the aforementioned parcels of land to ZAIDA LIWAG y VILIRAN and ROLAND LIWAG y VILIRAN. LIWAG. 6. N-217606” and “Transfer Certificate of Titles No. My son and daughter intended to build a commercial building over the lots so that their earnings from working abroad will not go to waste. On March 12. who bought the above-described real property from JOSE ERNESTO GONZALEZ on June 21. LIWAG.” “Real Property Tax Bill. 9. copies of such “Deeds of Absolute Sale” as Annex “7” and “7-1” are made integral parts hereof.” and “Tax Declaration of Real Property” as Annex “10” and “10-1” to “12” and “12-1” are made integral parts hereof. Consequently. LIWAG. we have been religiously and regularly paying the right amount of taxes imposed by the government. 8. Both parcels of land were formerly owned by my mother. that being the true. 3 . N-217607” were issued under the name of SALUD L. copies of such titles as Annex “8” and “81” are made integral parts hereof. 1990. SALUD L. copies of such “Real Property Assessment Record. “Transfer Certificate of Titles No.
11. I reported the matter to Barangay Culiat and was informed by a certain MRS.” copy of which certification as Annex “13” is made an integral part hereof. clandestinely erected on the property with the intention of enclosing it permanently without our consent. 13. issued a certification stating therein that their “office interposes no objection to the proposed two (2) storey commercial building. In order to prevent the threatened unlawful invasion and usurpation and to protect the proprietary or possessory rights of my children. 2011. so I immediately informed ATTY. HOMOBONO ADAZA instructed that construction materials be dumped on the property. PAPA are full of lies and meant to prop up and strengthen the fabricated charges. Immediately I applied for a building permit for the construction of the two-storey commercial building at Quezon City Hall. 12. There is no truth to the charges being levelled at me for the statements of the Complainant MARIO T. 2011. during the clean-up. my helpers discovered that there was a fence made up of concrete posts and barbed wires. so I had the lot prepared for the construction materials and instructed my helpers to clean-up the area in anticipation for the upcoming construction. BABY LIM that ATTY. appropriately. I applied for a Clearance Permit from BARANGAY CULIAT which has jurisdiction over the parcel of land to construct a two-storey commercial building. On April 4. to commence after issuance of the permit. BARANGAY CHAIRMAN JAIME GARCIA. for the reason that on March 4.10. ADAZA that I represent the legitimate and lawful 4 .
however. 2001.” since the aforementioned Transfer Certificates of Title are likewise declared NULL and VOID. 408.” as reported in a MANILA DAILY BULLETIN article dated December 16. but Atty. TCT No. privies or anyone acting for and in behalf of JM TALLANO be enjoined from representing or exercising any acts of possession/ownership or from disposing in any manner.R. 5 . and TCT No. Due to the continuous disturbance of possession. I was constrained by legitimate necessity to report the matter to the LAND REGISTRATION AUTHORITY. 70014 and 104604 that has finally adjudged that “the heirs.owners of the property. Adaza retorted that what I had was a fake title. I was also cautioned that this group is attempting to rewrite the history of the Philippines through their incredible and preposterous assertions of ownership over the entire archipelago. agents. T-408. 15. portions of the land covered by alleged TCT No. quite alarming were the documents given to me by the LRA INVESTIGATIVE SECTION-TASK FORCE TITULONG MALINIS finding that the “TALLANO-MADRIGAL-ACOP GROUP is one of the PROFESSIONAL SQUATTERS and SQUATTING SYNDICATES preying on hard-up Filipinos in need of shelter.” copies of such news clipping and report as Annex “15” and “15-1” are made integral parts hereof. RTC PASAY CITY. copy of which “Barangay Blotter” as Annex “14” is made an integral part hereof.” docketed as CA-G. T498. SP Nos. 99-0151. in a COURT OF APPEALS decision entitled “REPUBLIC V. 14. entitled “President orders drive on squatters” and “LRA Report: Task Force TM No. copy of the decision as Annex “16” is made an integral part hereof.
for LACK OF MERIT. Respondent reserves the right to file SUPPLEMENTAL and REJOINDER AFFIDAVIT. and that I reiterate that I am ABSOLUTELY INNOCENT of any criminal offense.” as well as to persecute and ridicule the legitimacy of realty ownership. The allegations of the complainant are untrue and malicious. That I am prepared to cooperate and establish my INNOCENCE of any violation of law which was allegedly committed. all my life. From the above narration and from the allegations in the complaint itself. For indeed. it is clear that there was NO MALICIOUS MISCHIEF COMMITTED. motivated by evil desire to intrude into the property with a “squatter and land grabber mind. stemming from Complainant’s ill intent to obviously harass me and my children. There is NEITHER LEGAL NOR FACTUAL BASIS for the criminal complaint for malicious mischief filed by the Complainant against me. 17. I have never been known to be a violent person since I abhor violence in any form. Thus. and will assert my INNOCENCE in any forum and will seek justice for this wrong against my person and that of my family in the proper forum under the laws of our country. I reiterate my strong denial of the malicious and unfair accusation and all allegation of wrong doing against anyone.16. 19. 18. To this end. the instant criminal complaint should be DISMISSED. 6 .
Philippines. August 24. understood and read his statements and that he freely and voluntarily made the allegations herein and therein and affirmed the same to be facts. _______________________________________________ Administering Officer/Prosecutor 7 . ORLANDO L. I further certify that I have personally examined the affiant and I am convinced and satisfied that he voluntarily executed. true and correct. LIWAG Affiant SUBSCRIBED AND SWORN to before me this 24th day of August 2011 at Quezon City.20. Philippines. Quezon City. 2011. the respondent respectfully prays for such and other reliefs as may be deemed just and equitable under the law and the premises. Further.
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