Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
Branch 17
Cebu City

CLARITA ESTRADA Civil Case no. CEB-23101

Plaintiff
For:
-versus-

“SUM OF MONEY WITH

WITH ATTACHMENT”
MARIO SUSON
Defendant
/-----------------------------------------------------/

EX-PARTE
MOTION TO REDEEM

The above-named Defendant by undersigned counsel unto this Most Honorable

Court most respectfully states-

That by reason of the writ of execution dated June 2, 2003 issued in favor of the
Plaintiff and against Defendant, the property of latter, more particularly described as
follows :

TCT No. RT-33648

(Registry of Deeds of Butuan City)
Lot 1-A, psd-13-001091
302 sq. meters
Located in Ampayon, Butuan City

were levied and sold at public auction on July 30, 2003 to the highest bidder in the amount
of Php. 80,000.00. (attached hereto is a copy of the Certificate of Sale marked as ANNEX
“A”)

That the redemption period for the above-mentioned property has not expired
considering that Certificate of Sale issued by the sheriff has not been registered. Defendant
still has 12 months to redeem the said property.

Attached hereto is a certified copy of TCT No. RT-33648 issued by the Registry of
Deeds for Butuan City on August 3, 2018, marked as ANNEX “B” ;

WHEREFORE, it is most respectfully prayed of the Honorable Court to allow

Defendant to redeem that property embraced by TCT No. RT-33648 from the successful
bidder.

Most respectfully submitted.

September 17, 2018, Butuan City for Cebu City, Philippines.

 THE LAW FIRM OF
SALISE & SULLANO
RGCS Bldg., Narra Road cor. Molave Street
8600 Butuan City
For Defendant

By:

ATTY. ROLANDO G.C. SALISE

Roll No. 48977
MCLE Compliance V-0019414 issued on April 4, 2016
IBP no. 1061873 1/3/2018
PTR No. 1446967 1/3/2018
TIN No. 908-310-719
e-mail add: boboysalise@yahoo.com
Cellphone no. 09485939047

Notice of Hearing

The Branch Clerk of Court

REGIONAL TRIAL COURT
7th Judicial Region
Branch 17
Cebu City

FLORIDO & ASSOCIATES

Counsel for Plaintiffs
Rm. 310, WDC Bldg.,
Osmeña Blvd., cor. P. Burgos St.,
Cebu City

Please take notice that I am submitting the foregoing Motion for the consideration and
approval of the Honorable Court immediately upon receipt thereof or on September 28,
2018 at 8:30 AM sans further argument and appearance.

ATTY. ROLANDO G.C. SALISE

For Defenadant

EXPLANATION

The filing and service of this Motion was made thru registry mail/fast courier due to
distance consideration and lack of personnel to effect personal filing and service.

ATTY. ROLANDO G.C. SALISE

CC:

FLORIDO & ASSOCIATES

Counsel for Plaintiffs
Rm. 310, WDC Bldg.,
Osmeña Blvd., cor. P. Burgos St.,Cebu City
Reg, mail no. ___________________________