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Republic of the Philippines

MUNICIPAL TRIAL COURTS IN CITIES


Sixth Judicial Region
Cadiz City
-oOo-

MARISCO INVESTMENT DEV. CORP.,


Plaintiff,

-versus- CIVIL CASE NO. 1143


For: UNLAWFUL DETAINER

VICTOR AMOROSO, JED OPLAS


SHERWIN PENISA, EROL PENISA
And GUALBERTO DELOTINA,
Defendants.
X-------------------------------------X

URGENT MANIFESTATION

COMES NOW, Plaintiff, Marisco Investment Dev. Corp. is duly


represented in this instance by NOVA DELOTINA, of legal age, Filipino,
and a resident of Cadiz City, Philippines, by the counsel, and unto this
Honorable Court, most respectfully states that:

1. That the land covered by the Notice of Coverage issued by the


office of the Department of Agrarian Reform (DAR) does not
correlate with the title of the subject parcel of land in question.

2. Hereto attached as Annex “A” is a copy of the Notice of


Coverage issued by DAR, wherein the portion named Marisco
Investment Dev. Corp. is blurred and the coverage and land
area of the parcel of land in question is illegible thus, the exact
and proper numbers of the land area cannot be determined.

3. Having taken closer scrutiny in the Notice of Coverage


published, it does not coincide with the land area described in
the title of the subject parcel of land. Attached herewith as
Annex “B” is the copy of the title which is under the name of
the herein Plaintiff, Marisco Investment Dev. Corp.

4. The title herein reads and is described as, Transfer Certificate


of Tile No. T-13569, with the total area of TWO HUNDRED
SIXTY FOUR THOUSAND THREE HUNDRED FIFTY NINE
(264, 359) square meters more or less. Wherein, the land
area written on the notice of coverage published by DAR does
not correlate with that on the respective title of the herein
Plaintiffs and that the area written on the said Notice of
Coverage is unclear and illegible.
5. To be able to truly identify if the areas described on the Notice
of Coverage and the Title match, the undersigned counsel is
manifesting that a Certified True Copy of the Notice of
Coverage published by DAR is to be issued, so that such should
be the basis to be used by this Honorable Court to render
judgement.

PRAYER
WHEREFORE, premises considered, it is respectfully prayed that a
Certified True Copy of the Notice of Coverage be issued by this
Honorable Court as to be the basis for this Honorable Court’s decision in
the case at bar. Other remedies and relief just and equitable under the
circumstances are also prayed for.

Most Respectfully Submitted.


Bacolod City for Cadiz City, Philippines. December 6, 2019.

JULIE ANN A. BEDRIO


Counsel for the Plaintiff
AMEGO & Associates Law Office
C.I.T Bldg., Lacson-Luzuriaga Sts., Bacolod City
PTR No. 2007839 – Jan. 3, 2019 – Talisay City
IBP No. 015184 Lifetime Member
MCLE Compliance No. VI - 0008651 valid until April 14, 2022
Roll No. 65241
Tel. No. (034) 4356039

COPY FURNISHED:

HANNAH JANE T. BANGHE


Counsel for the Defendants
Public Attorney’s Office
Cadiz City District Office
2nd Floor East II Elem. Bldg.
Cabahug St., Cadiz City, Neg. Occ.

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