Professional Documents
Culture Documents
Republic of The Philippines Manila
Republic of The Philippines Manila
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ANTONIO P. AVANTE
Plaintiff-Appellee ,
-versus-
Pages
COVER PAGE 1
INDEX 2
PARTIES 4
ISSUES 6
ARGUMENTS 7-11
RELIEF 11-12
Cases cited:
ANTONIO P. AVANTE,
Plaintiff-Appellee ,
Please take notice that the undersigned counsel for the Accused-
Appellants has transferred his office to a new address, to wit:
THE PARTIES
The instant appealed case arose from the decision of the Regional
Trial Court Branch 218, Quezon City, dated May 06, 2014 to wit:
3.1. That the letter from the Land Management Bureau dated
October 23, 2013 (Exhibit “4” for Defendants) was not property
identified and authenticated by the persons who issued the same.
IV. ISSUES
V. DISCUSSION
“Q17 – will you remember Mr. Witness, the reason for you to
construct on the lot which is located inside T.C.T. No. RT-
127108 (140252)?
9
Zosa vs. Estrella, 572 SCRA 428
10
Page 2 Judicial Affidavit of Leonito Comiso
11
Tio vs. Abayata, 556 SCRA 175
before I constructed my house on it”.12
5.15 For public good and to deter others from committing the
same acts of the defendants, the plaintiff should be awarded no less than
Php 50,000 as exemplary damages. Considering that the award of moral
damages is legal and proper, it follows that the award of exemplary
damages is likewise appropriate. “Exemplary damages may be awarded
in addition to moral and compensatory damages and are imposed not to
enriched one party or impoverished another but to serve as a deterrent
against or as a negative to curb socially deleterious actions.”14
11. In any other case where the court deems it just and
equitable that attorney’s fees and expenses of
litigation should be recovered.”
RELIEF
RESPECTFULLY SUBMITTED.
30 December 2014, Quezon City for Manila.
ALFEROS ARMAS & ASSOCIATES
Law Office
Unit K, No. 1143 San Francisco Del Monte Avenue
Barangay Paltok 1105, Quezon City
By:
Copy Furnished:
EXPLANATION
(Pursuant to Rule 13 Section 11 of the 1997 Rules of Civil Procedure)
AFFIDAVIT OF SERVICE
I, CHARMAINE LYN ANNE C. NICOL, of legal age, Filipino and with postal
address at Unit K, 1143 San Francisco Del Monte Avenue, Barangay Paltok 1105,
Quezon City, after having been sworn to in accordance with law, do hereby depose
and state: That……..
I am the personnel of Alferos Armas and Associate Law Office and I have
today furnished a copy through registered mail with return card of the Appellees
Brief in the case entitled ANTONIO P. AVANTE vs LEONITO COMISO ET.
AL. docketed as CA G.R. No. CV- 103117 pending before the Court of Appeals to: