ANSWER

#15. no attached evidence of Merry P. Santa filing 12 different complaints against the defendant
between 2017 - 2020

PLAINTIFF:
Annex A - JA of Franq Lyn
B- Deed of Absolute Sale - witnessed (may 3, 2016), notarized 800k (June 5, 2016)
C- Sketch Plan - issued date -none
D- TCT - Date of Survey- June 22, 2016; TCT Entered June 5, 2016 (Sunday) @ 3:35 pm
E- Cert of Non- Delinquency - Oct 12, 2020
F- JA Merry Santa
G- Cert to File Action - Oct 14, 2020
H- Demand Letter to Vacate - Oct 15, 2020
I- Second Demand Letter - Oct 30, 2020

DEFENDANT:
Annex 1 - TCT - Date of Survey- January 4, 2016, TCT Entered: January 5, 2016 @ 1:01 pm
(wed)

Annex 2- DAS - 1.4 Million pesos ; January 4, 2016

Annex 3- sketch plan- inserted owners of Lot 1 (Kre Zel) & Lot 2 (Jo Hann) only and no names
of owners of Lot 1&2 on vicinity map

Annex 4- JA witness Kre Zel – witness in signing the Deed of Absolute Sale
Mrs. Baknang sold her Lot 1, moved there in 2010,

Annex 5- JA witness Jo Hann – owned a lot near lot 3 (unspecified); owned since 1970,
consideration – 1 Million pesos

Annex 6- Cert of Non-Delinquency - Changed Name Waisan - Nidobo and Date From Oct 12,
2020 to Nov 10,2020

Annex 7- Fencing Permit - issued January 12, 2016;

NO signature of Atty. MAC DAVE (Notary Public)

fence- 40 x 2 meters

Annex 8-
1st pic (Jan 15)- steel tower and T-shaped antenna upper left; green grass on soil
3rd pic (Jan 16) - no steel tower on upper left, instead a new antenna post; dry withered
grass and a cemented pathway

A major difference in the background can be seen between the 1st and 3rd pic
Annex 9-
July 27, 2016 pic - tall trees. No antenna or steel antenna or post was seen.
September 1, 2016 - banana leaves and palm leaves upper left. (banana trees grow &
mature around 9 months)

Annex 10- pic of finished Nidobo’s residence

Annex 11- JA of Sioni Storm – clerk of Register of Deed, B.C., since 2000
Name Siony was repeatedly spelled incorrectly
No. 13. “I am certain because June 5, 2020 is a Sunday and we definitely do not
have work on Sundays”