REPUBLIC OF THE PHILIPPINES

THIRD JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 67
PANIQUI, TARLAC

ROLANDO ARCIAGA,
Plaintiff,

- versus - CIVIL CASE NO. 042-18

FOR: CANCELLATION OF DOCUMENTS
AND TITLES WITH DAMAGES

JOCELYNE SEMANERO,
SPS. JOHNIFER D. HONG and
RHODALYN R. HONG,
JOHN HENRY R. SEMANERO AND
THE OFFICE OF THE REGISTER OF
DEEDS OF THE PROVINCE OF TARLAC,
Defendants.
x----------------------------------------------------------x

COMMENT
(to the Entry of Appearance with Manifestation and Motion)

COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable
Court, most respectfully states that:

1. This is a comment to the Entry of Appearance (with Manifestation and Motion) filed
by Atty. Warren Wyndell D. Sarsagat and received by the undersignd on May 20, 2020;

2. As appearing in the records, defendant Sps. Johnifer D. Hong and Rhodalyn R.

Hong were delcared in default by reason of their failure to appear in the pre trial scheduled on
April 25, 2019;

3. For defendants Jocelyn Semanero and John Henry Semanero, they were declared
in default by reason of their absence on thr subsequently scheduled pre trial on December 12,
2019;

4. The notice of the pre trial sent to Jocelyn Semanero was returned to court with a
notation moved out, after several attempts were made by the postman to serve the notice. As
to defendant John Henry Semanero, he was notified through his counsel Atty. Torralba, prior
to the latter's withdrawal of his representation;

5. On February 6, 2020, an Order for the ex parte presentation of the evidence of the
plaintiff was issued by the court;
 6. Subsequently, Rolando Arciaga was presneted as witness. After which, the oral
formal offer of evidence enused accompanied by a prayer for the submission of the case for
Decision;

7. Based on the foregoing, it is clear that due process was afforded to the the
defendants before they were declared in deafult; ampple opportunity was given to them to
participate in the trial and state their defenses therein. They are aware of the pendency of the
case and their repeated neglect should ot prejudice the rights of the plaintiff.

PRAYER

WHEREFORE, the plaintiff most respectfully prays of the Honorable Court that the
instant motion be denied and the case be submitted for Decision.

Other just and equitable reliefs are likewise prayed for.

Paniqui, Tarlac. June 3, 2020.

PUBLIC ATTORNEY’S OFFICE

Department of Justice
Counsel for the Plaintiff
2nd Floor, Justice Hall, Mun. Compound,
Paniqui, Tarlac

By:

ATTY. ANTHONY M. MORALES

Public Attorney II
ROLL NO. 61016
IBP OR No. 120273/01-10-2020/Pasig City, Metro Manila
PAMPANGA CHAPTER
MCLE Compliance No. VI- 0009088/06-07-18/Metro Manila

Approved By:

ATTY. ROLANDO L. GRAGASIN

OIC/Public Attorney III
ROLL NO. 47145
IBP Lifetime Member No. 07354/Tarlac
MCLE Compliance No. VI- 0011993/06-07-18/ Metro Manila
 NOTICE

The Clerk of Court

RTC 67
Paniqui, Tarlac

ATTY. WARREN WYNDELL D. SARSAGAT

194 Salomague, Paniqui, Tarlac

G r e e t i n g s:

Kindly submit the foregoing pleading for the consideration of the Honorable Court
immediately upon receipt hereof.

A.M. MORALES

Copy Furnished:

ATTY. WARREN WYNDELL D. SARSAGAT

194 Salomague, Paniqui, Tarlac

EXPLANATION

Service of the foregoing pleading was done by registered mail as personal service is
not practical due to distance, time constraint and lack of personnel.

A.M. MORALES