Republic of the Philippines

Plaintiff,
CIVIL CASE NO._______
-versus- RECOVERY OF POSSESSION &
OWNERSHIP

Defendants,

x------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

DEFENDANTS by the undersigned counsel and unto this Honorable Court, most
respectfully offers the following documentary and exhibits for the above titled case, to
wit:

EXHIBITS DESCRIPTION PURPOSE/S

To prove and show lawful

possession and have been
Deed of Possession and inpeaceful,continuous,open
Ownership of a Foreshore exclusive and notrorious
Land dated on May 28, occupation of the subject
“1” 2014. property.

To show that the

defendants has a better
right over the subject
Agricultural Foreshore property by virtue of the
reclaimed land or Foreshore Lease
Miscellaneous Lease Application granted unto
Application FLA-054101- them by the Office of,.
“2” 146.
Official Receipts issued in
the name of from the
“3-series” Office CENRO. with OR
“3-1” NO.8911894E dated on To prove and show that
“3-2” 5/22/200, the defendants was the
“3-3” OR NO.2353643 dated lawful possessor of the
on 5/11/08 OR subject property,
NO.9920202 dated religiously paid fees for
4/2/2002 and OR their occupation of the
NO.6625659 dated on same before the office of,
3/30/2011.

To prove that the

Barangay Council of on
April 19, 1995 approved
 the Resolution No.10
Minutes of the Regular s.1995 titled“Resolution
Session of Barangay Applying for a Barrio Site
Council of held on April 19, as applied in the DENR”.
1995
“4”
To show and prove the
Sangguniang Bayan
Members of Municipality of
has passed and duly
approved Resolution
No.028-95 “A Resolution
Approving Barangay
Resolution No.028-95 Resolution No.9 s.1995 of
“Approving the Barangay the Sangguniang Barangay
Resolution No.9 series of of. RE: A Resolution to
1995 titled A Resolution to apply for Barangay Site
apply for a Barangay Site from the DENR,”
from DENR,”
“5”
To show and prove that
based on the records there
was no Foreshore Lease
application in the name of,
the parents and relatives
Certification issued by of the herein plaintiffs.
DENR-CENRO dated on
October 17,2013.
“6”
To prove further that the
Certification issued by Plaintiffs has no subsisting
Bureau of Fisheries and FLA/Fishpond Application
Aquatic Resources (BFAR) covered by BFAR
dated on October 17, 2013 Provincial Fisheries Office,
“7”

Certification issued by
Bureau of Fisheries andTo show and prove that
Aquatic Resources (BFAR)
Ethel B. Corpin has no FLA
Regional Office No.5 dated
application filed with DA-
“8” on July 20, 2017 BFAR.
To show and prove that
CENRO- has no existing
records of the approved
FLA application issued to
Letter from the CENRO, To further prove that the
“9” dated on September 11, subject area is classified as
2017 to Hon.. Timberland and hence
inalienable.
 To show and prove that
Letter to Plaintiff Ethel the subject property is part
Corpin from the Office of of the mangrove forest
CENRO- dated on May 19, reserves of Mainland.
“10” 2014.
To show and prove that
the defendants and their
predecessor in interest is
in
peaceful,continuous,open
Deed of Possession and exclusive and notorious
Ownership of a Foreshore occupation and to further
Land dated on August 8, prove that the lawful
“11” 2012. possessor therein is the
defendants in this case.

To show and prove that

the defendants have been
in open, peaceful,
continuous, exclusive and
Photos taken of the notorious occupation of the
subject property presently subject property for more
“12-series” occupied by the than 20 years since 1994.
defendants
To prove the allegations
contained in their answer
and to testify, prove other
matters and identify
authentic documents
Judicial Affidavit of material to recovery of
“13” and 13-series” possession and ownership.

Judicial Affidavit of To further prove due

“14” and 14-series” execution thereof.

Aforesaid exhibits are being offered to prove the allegations of the defendants in
their Answer.

WHEREFORE, premises considered, it is most respectfully prayed to this

Honorable Court that the documentary exhibits be admitted.

NOTICE OF HEARING
The Branch Clerk of Court
First Municipal Circuit Trial Court of Aroroy-Baleno
 GREETINGS:
Please submit the foregoing Formal Offer for the consideration and approval of
the Honorable Court immediately upon receipt thereof.

Copy furnished: