Professional Documents
Culture Documents
6. That Perfecto Dima, who had worked with the spouses during planting
season on the said 3 parcels of land. He has been working on said
lands even when Santiago was still living with the defendants.
7. Perfecto Dima recalls that there were 10 of them working at the land
and that they would be planting and harvesting on the land three
times a year. He even continued to work on the lands even after the
death of Oswald.
8. He also recalls that Timoteo Arawiran was hired by Epifanio Lagdameo.
However, Arawiran stopped working on the lands at the time of death
of Santiago. He has no knowledge of the reason why Arawiran stopped
working.
II.
ISSUES TO BE TRIED OR RESOLVED
1. Whether or not Oswald Lagdameo executed a Deed of Donation
pertaining to the three parcels of land in favor of the spouses Epifanio
and Mercedita Lagdameo which makes them the rightful owners of the
land.
2. Whether Oswald Lagdameo recognized Christina as her daughter.
III.
Documentary Exhibits To Be Presented
1. Defendants will present the notarized Deed of Donation executed by
Oswald Lagdameo in favor of the spouses.
2. Judicial Affidavit of Atty. Joven Almedilla as proof of the due execution
of the Deed of Donation that was executed by Oswald Lagdameo.
3. Judicial Affidavit of Perfecto Dima for the purpose of contradicting the
statements of Timoteo Arawiran and also to prove the ownership and
possession of the Spouses Lagdameo of the parcels of land.
4. Judicial Affidavit of Epifanio Lagdameo for the purpose of proving that
Oswald donated the parcels of land to him and his spouse and that
they had been in possession of the land since 1994. The affidavit is
also to be presented in order to prove that Oswald never
acknowledged Christina as his daughter and that it was the latter who
claimed that Oswald was his alleged father.
IV.
WITNESSES TO BE PRESENTED
1. Atty. Joven Almedilla will testify as to the authenticity of the signature
of his father, Atty. George Almedilla, who notarized the Deed of
Donation in favor of the Defendants.
VI.
AVAILABLE DATES FOR TRIAL
The Petitioner respectfully requests that the trial dates be agreed upon
in open court at such dates and time convenient to the parties and the
calendar of this Honorable Court.