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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


REGIONAL TRIAL COURT
BRANCH 201
LAS PINAS CITY

CARINA V. NAVAL-HAMOND,
Represented by her attorney-in-fact
RITA LINDA V. JIMENO,
Petitioner,

- versus - CASE NO. LP-05-0113


For: Annulment and/or Cancellation
of Title and Recovery of Possession
with Damages

PABLITO S. PAGBILAO, LOLITA R.


PAGBILAO, SHIELA MARIE S.
SAMANIEGO, PABLO C. APOSTOL,
ARNELIA V. APOSTOL, JOSELITO
D. CULLA, GINA C. CULLA, EDWIN
D. DUMAGPI, EVANGELINE T.
DUMAGPI, ROBERTO C. SACLOLO,
FLORECITA B. SACLOLO and THE
REGISTRY OF DEEDS OF
LAS PINAS CITY,
Respondents.
x------------------- -------------- x

NOTICE OF LIS PENDENS

The Register of Deeds


Las Pinas City

Greetings:

Notice is hereby served regarding the filing and pendency of the above-

entitled case before the Regional Trial Court of Las Pinas City, Branch 201

involving the following properties covered by Transfer Certificate of Title Nos.

29770; T-59362; T-59423; T-66124; T-60606;T-59361; T-60217 which was already

registered in the names of the private respondents.

In the Petition, the petitioner prays, to wit:


1, Annulling and/or cancelling the following titles:

a. TCT No. T-59362 purportedly issued in


the names of respondent spouses PABLITO S.
PAGBILAO and LOLITA R. PAGBILAO by the
Registry of Deeds of Las Pias City;

b. TCT No. T-59423 purportedly issued in


the names of respondent SHIELA MARIE S.
SAMANIEGO by the Registry of Deeds of Las Pinas
City;

c. TCT No. T-66124 purportedly issued in


the names of respondent spouses PABLO C.
APOSTOL and ARNELIA V. APOSTOL by the
Registry of Deeds of Las Pinas City;

d. TCT No. T-60606 purportedly issued in


the names of respondent spouses JOSELITO D.
CULLA and GINA C. CULLA by the Registry of
Deeds of Las Pinas City;

e. TCT No. T-59361 purportedly issued in


the names of respondent spouses EDWIN D.
DUMAGPI and EVANGELINE D. DUMAGPI by the
Registry of Deeds of Las Pinas City; and

f. TCT No. T-60217 purportedly issued in


the names of respondent spouses ROBERTO C.
SACLOLO and FLORECITA B. SACLOLO by the
Registry of Deeds of Las Pinas City; and,

2. Ordering private respondents to vacate the


subject parcel of lands and remove all improvements they
might have introduced in the parcel of land covered by TCT
No. 29770 issued in the name of petitioner since 16 April 1980;

3. Ordering private respondents to pay petitioner


the following:

a. Actual damages in the form of


reasonable rentals in the amount of at least P2,000.00
per month from the date of the issuance of their
alleged titles up to the time they actually vacate the
property and turn over the possession thereof to the
petitioner; and,
b. Attorneys fees and costs of suit
amounting to P100,000.00.

In this regard, please find enclosed a copy of the instant Complaint with

attachments, including copies of TCT Nos. 29770; T-59362; T-59423; T-66124; T-

60606; T-59361; T-60217.

Makati for Las Pinas City, March 26, 2012.

JIMENO COPE AND DAVID


LAW OFFICES
37 Floor Rufino Pacific Tower
th

6784 Ayala Ave. cor. V.A. Rufino Street


Makati City

By:

RITA LINDA V. JIMENO


PTR#3184972, 1-10-12, Makati City
Lifetime IBP Member No. 07157
Roll No. 33922
MCLE Compliance No. III-0006700, 12-23-09