Republic of the Philippines

REGIONAL TRIAL COURT

Second Judicial Region
Branch 05
Tuguegarao City, Cagayan

MARIA CORPUZ,
Plaintiff,

- versus - Civil Case No. 5152

ARCADIA LOZANO,
Defendant.
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MOTION FOR PRODUCTION OF DOCUMENTS

DEFENDANT, through the undersigned counsel, unto this Honorable

Court most respectfully states that;

1. The defendant was the registered owner of a parcel of land situated

at Brgy. Masapulan, Tuguegarao City, Cagayan embraced and
covered by Transfer Certificate of Title No. T-112516 by virtue of a
Deed of Absolute Sale;

2. This was, however, disputed by herein plaintiff because allegedly,

the Transfer Certificate of Title was fraudulently obtained by the
plaintiff;

3. The authentic and original Transfer Certificate of Title No. T-112516

and Deed of Absolute Sale was in the custody, possession and
control of Department of Environment and Natural Resources
(DENR);

4. The aforementioned documents constitutes competent, material

and relevant evidence to the instant case;

5. Thus, the undersigned seeks the kind indulgence of this Court to

order the record custodian of Department of Environment and
 Natural Resources (DENR) to produce and permit the plaintiff to
inspect and copy the aforementioned documents;

6. The Motion is not intended to delay the proceedings of the case nor
is it meant to frustrate the administration of justice.

RELIEF

WHEREFORE, it is most respectfully prayed unto this Honorable

Court to order the record custodian of DENR to produce and permit the
defendant to inspect and copy the Transfer of Certificate Title No. T-112516
and Deed of Absolute Sale. Other just and equitable relief that may be
lawfully derived from the premises are likewise prayed for.

Done in Tuguegarao City, Cagayan on March 1, 2019.

MENDOZA & MONDRAGON LAW OFFICE

Archbishop’s Centennial Building, Arellano corner
Blumentritt Streets,
Tuguegarao City (Telephone No. 078-654398/
m2lawoffice@yahoo.com)

By:

ATTY. THEVY ALEJANDRE MENDOZA

Roll of Attorneys No. 901112
IBP Lifetime Membership No. 9767556
PTR No. 8457489678 (1/1/20)-Isabela
MCLE Compliance No. VI-986744 issued on January 1, 2019
(Valid until January 1, 2022)
Mobile No. 09268901271/ Email: thevymendoza@gmail.com

NOTICE OF FILING AND HEARING

Atty. Cristina Marie Agnas

Branch Clerk of Court
Regional Trial Court Branch 5
Tuguegarao City
Greetings! Please submit the foregoing Motion for the consideration of
the Honorable Court immediately upon receipt hereof or for its approval
on the scheduled hearing on April 15, 2019 at 8:30 o’clock in the morning.
Thank you.

Thevy Alejandre Mendoza

The Plaintiff

Greetings! Please be notified that the defendant, through counsel, have

submitted the foregoing motion for the immediate consideration of the
Honorable Court or for its approval on the scheduled hearing on April 15,
2019 at 8:30 o’clock in the morning. Thank you.

Thevy Alejandre Mendoza

PROOF OF SERVICE

The Plaintiff
Thru: Atty. Francisco Bannawag _______________
Tuguegarao City

EXPLANATION

For lack of messengerial help and due to the distance between the office
address of the counsel of the defendant and those of the adverse parties
and of the Honorable Court, the service and filing of the foregoing paper
have been made through registered mail. (Note: Please ignore the
explanation if personal mode of service/filing has instead been resorted to.)

Thevy Alejandre Mendoza