Republic of the Philippines

REGIONAL TRIAL COURT

5th Judicial Region
Branch 30
San Jose, Camarines Sur

Civil Case No. 2016-1309

For: Unlawful Detainer plus Attorney’s
Fees and Damages
HEIRS OF SALVACION VALER
represented by Salve C. Lim;
Plaintiffs,

-versus-

MARIBEL PUERTA, ET. AL

Defendants.
x----------------------------------------------------x

MANIFESTATION WITH MOTION FOR DEFERMENT

OF THE ISSUANCE OF THE WRIT OF DEMOLITION

Plaintiffs, by counsel, and unto this Honorable Court,

respectfully state:

1. That on March 28, 2019, the Honorable Court issued an Order

on the above-captioned case, stating, among others, as follows:

“xxx. Defendant Blandino Bantog, and all persons deriving their

right to possess the subject lot from the latter are hereby given a
reasonable period of 30 days from receipt of this order within which to
remove the improvements erected/constructed on the subject property,
otherwise, failure to do so, a Writ of Demolition shall be forthwith issued
against them.

SO ORDERED.”

2. That the Plaintiffs, through the undersigned counsel, hereby

manifest that he had a conference with Marlon Bantog, representing
his father Defendant Blandino Bantog, last May 25, 2019 at the
former’s office regarding the intention of an amicable settlement as
regards the case of the latter.

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3. That with intent to finally settle the matter amicably, Marlon
Bantog offered to purchase the two lots occupied by his father which
was Lot 1, Blk. 2 with an area of 121 square meters (sq.m) and Lot 4,
Blk 1 with an area of 248 sq.m based on the decision of the Municipal
Trial Court of Goa, Camarines Sur as affirmed by this Honorable
Court;

4. That upon relocation survey of the Plaintiffs, through their

geodetic engineer, the two (2) lots new areas are 146 and 246 sq.m,
respectively.

5. That Marlon Bantog was amenable with said new

measurements and was willing to pay the purchase price offered by
the Plaintiffs, through their representative Salve C. Lim, which was
PhP268,600.00.

6. That Marlon Bantog gave the full amount of the purchase price
to Salve C. Lim on May 26, 2019 which was duly received and
acknowledged by the latter.

7. That Plaintiffs and Marlon Bantog are on the process of

preparing and executing the Deed of Sale of the lots in favor of the
latter;

8. That upon execution of the Deed of Sale, the Plaintiffs and

Marlon Bantog would be submitting a Compromise Agreement for
approval of this Honorable Court to fully settle and dismiss the case
as against Blandino Bantog.

9. That in view of the amicable settlement of the parties herein

and pending the submission of the aforementioned documents,
Plaintiffs herein are moving for the deferment of the issuance of
Demolition Order in order to effectuate said settlement and submit
the same for approval of this Honorable Court.

PRAYER

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 WHEREFORE, premises considered, it is most respectfully
prayed that this Manifestation with Motion for Deferment of the
Issuance of the Writ of Demolition be duly noted and the issuance of
a Demolition Order be deferred and thereafter be set aside upon
proper submission of the compromise agreement of the Plaintiffs and
Blandino Bantog represented by his son Marlon Bantog with
approval of this Honorable Court.

Other relief just and equitable are likewise prayed for.

Naga City for San Jose, Camarines Sur, Philippines,

______________.

BY:

LEO ARCHIVAL I. IMPERIAL

Counsel for the Plaintiffs
Unit 2D, Prifel Bldg. J. MirandaAve., Naga City
ROLL NO. 60619-March 23, 2012
IBP No. 0294- CY-2019
PTR No. 0418426- January 7, 2019
MCLE Compliance No. VI-0003390, October 12, 2017
Tel No: 472-82-61/C.P. No: 09175126032

NOTICE OF HEARING

ATTY. ERNESTO M. ALARCON

Counsel for the Defendants

Greetings: Please take notice that the foregoing motion shall be submitted for the
consideration and approval of the Honorable Court as soon as counsel and matter may be
heard.

ATTY. LEO ARCHIVAL I. IMPERIAL

Copy Furnished:

ATTY. ERNESTO M. ALARCON

Bag Grande St., Goa, Camarines Sur

Explanation: On account of the distance, time and personnel constraints in effecting

personal service, counsel for the Plaintiffs is constrained to serve a copy of the foregoing
motion to Atty. Ernesto M. Alarcon at his address above through registered mail as
evidenced by hereto attached Registry Receipt No:__________. Please disregard this
explanation if personal service had been effected.

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ATTY. LEO ARCHIVAL I. IMPERIAL