Complaint

1. Owner of parcel of land TCT-70382 (Annex A)

(99,602 sqm) under TXCT T-
70382 issued by Registry of
Deeds of Quezon on August
23, 1996 under the name of
Crispin Noriel
2. From the time they NONE
acquired property, they
hired workers to cultivate
land
3. April 1, 2005, found out Annex B - TCT 179969 SPA SIMULATED 5 parcel of land was mortgage (Annex B to F) to secure Annex 1 – REM
that their property was Annex C - TCT 179970 REM executed by credit accommodation from Petron (P500,000) Annex 2 – SPA
subdivided and a new titles Annex D - TCT 179971 Rosenda NOT VALID Annex 3 – REM of Rosendo
and tax declaration were Annex E - TCT 179972 as her SPA was over 2 parcel of land (TCT
issued by virtue of a special Annex F - TCT 179973 fictitious Spouses venales defaulted in the performance in their 181920 and 921) for P180k
power of attorney, REM Annex G - SPA duty under the two REM thus the properties were Annex 4 – Certificate of Sale
and extrajudicial Annex H – Notice of Auction Sale foreclosed Annex 5 – Deed of
foreclosure. Annex I – Certificate of Sale Assignment
Annex J – Consolidation of Sps. Venales and Crispin never redeemed the
Ownership properties

Petron assign its rights to New venture Realty

Corporation Annex G – Same as Annex 2
of defendant
March 2006 - plaintiff’s counsel made an offer to Annex H – Admitted
redeem after a group of local residents come to Petron Annex I – Admitted
to redeem on installment basis Annex J – Admitted

Laches -after two decases only nag reklamo despite the

fact the the foreclose is an action in rem

REPLY
- Negotiated with PETRON o Annex K – SPA of Nilda Villarama,
repurchase the proert and Edeise Noriel and Neia Noriel to file
for possible compromise action
 hoping to avoid litigation
but not necessarily to
recognize Petrons title over
the property
- Cerdit accommodation was
not for Crispin but for
Rosendo
Annex L – faxed a letter proposal
dated January 30, 2006 that they
did not sign the SPA to Rosendo.
And the Signature of her husband
Crispin is not his signature

- Credit accommodation was

for P680k (500 + 180) but
per certificate of Sale, Rem
is for P1,001,884

- Pambansang Sinupan has

no notarial record of

SPA Annex M – Cert of no notarial

REM records
Deed of Sale Annex N – same
REM Annex O – same
Annex P – same
- Public sale in Lucena is fatal
as it deprive the locals of
Sta. Elena and Gumaca the
opportunity to participate
in the auction sale (Sec 2 of
Act 3135) – auction cannot
bee made outside the
municipality of the party

- Why is real property tax

paid by plaintiff, did no
exercise dominion over
property fr a very long time

Amended Complaint

New titles were issued to New K - 488342

venures while case is pending L - 488343
M - 48834
N - 48835
O - 48836
P - 48837
Q – 48838
R – Section 1 of RA 5480

New ventures cancelled the Tax S

Declaration in the name of Crispin T
( tax dec) because Mr. Barbasa
misrepresented himself as the
deceased Crispin.

Thay also cancelled 5 Tax claration U

in the name of Rosendo V
W
X
Y

Paquito Noveno step son of

plaintiff’s tenant who was allowed
to stay in the property refused to
give the produce

Noveno, withheld land owners

share to the produce and opened a
bank account. Gross income for 5
years is P155,843.15