Republic of the Philippines

REGIONAL TRIAL COURT

First Judicial Region
Branch 64
Abatan, Buguias, Benguet

HEIRS OF ABC,
Plaintiffs, CIVIL CASE No. xxxx-xx-xxx

-versus- for:
QUIETING OF TITLE, RECOVERY OF
POSSESSION with prayer for
PRELIMINARY INJUCTION & DAMAGES

HEIRS OF DEF,
Defendants.
x------------------------------------------------x

COMMENT ON THE PLAINTIFF’S

FORMAL OFFER OF EVIDENCE

The defendants, by and through the undersigned counsel, to this Honorable

Court, by way of comment to the plaintiff’s formal offer of evidence, most respectfully
state as follows:
1. Defendants vehemently object the admission of EXHIBIT “A” of the
plaintiff. It was not established that the parcel of land subject of the
 complaint is covered by Tax Declaration marked as Exhibit “A” by the
plaintiffs;
2. Defendants likewise object the admission of EXHIBITS “B” “C” “E” “K” and
its corresponding sub-markings and the purpose for which they are
offered for being clearly self-serving as it was prepared only upon the
instance of the plaintiffs;
3. Defendants do not object to the admission of EXHIBITS “D”, “F”, ‘G’, “H”, “I”
, “J” and its sub-markings;

PRAYER

WHEREFORE, PREMISES CONSIDERED, it is most respectfully prayed of the

Honorable Court that this COMMENT be noted and considered in resolving the Formal
Offer of the Plaintiff.
Such other reliefs just and equitable in the premises are likewise prayed for.
January 4, 2016, La Trinidad, Benguet for Abatan, Buguias, Benguet, Philippines.

HIJ ASSOCIATES LAW OFFICE

Counsel for the Defendants
2 Floor Al’s Bldg. Capitol Drive, Poblacion, Km 6 La Trinidad, Benguet
nd

BY:
KLM
Of counsel
PTR No. xxxxxxx, 01-07-16, Benguet
LIFETIME IBP No. xxxxx, 01-08-08
Baguio-Benguet Chapter
Roll No. xxxxx, 5-6-05
MCLE Compliance Certificate No. IV-0000560, 09-29-10

COPY FURNISHED:
NOP