REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
SAN JUAN CITY, METRO-MANILA
BRANCH 264

IN RE: PETITION FOR CORRECTION

OF TECHNICAL DESCRIPTION IN
TRANSFER CERTIFICATE OF TITLE
NO. 14258-R OF THE OFFICE OF THE
REGISTRY OF DEEDS FOR SAN JUAN
CITY, METRO-MANILA.

Spouses WILSON G. LEDESMA and

DIANE C. LEDESMA, represented by
their Attorney-in-Fact, JOSE MARI D.
ABELEDA,
Petitioners,

- versus - LRC CASE NO. 8513-

SJ

LAND REGISTRATION AUTHORITY,

REGISTER OF DEEDS FOR SAN
JUAN CITY, METRO-MANILA, LAND
MANAGEMENT BUREAU, SERAFIN
MIRASOL, LUCILLE PUA UY, and
Atty. ERNESTO DELA PAZ,
Respondents.
x----------------------------------------------------------
x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

PETITIONER, through counsel, and to this Honorable Court, most

respectfully offer in evidence the following documentary exhibits:

EXHIBIT DESCRIPTION PURPOSE OF OFFER

“A” Amended Petition, dated To prove the filing of the

(Page 25 of June 7, 2018; instant petition before this
the Record) Honorable Court;

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EXHIBIT DESCRIPTION PURPOSE OF OFFER
(Cont’d.) (Cont’d.) (Cont’d.)

“B” Order, dated June 11, 2018; To prove that the Court set the
(Page 48 of petition for initial hearing on
the Record) August 10, 2018 at 8:30 o’clock in
the morning;

“B-1” Proof of service to the To prove that a copy of the

(Page 54 of Office of the Register of Order and the Petition were
the Record) Deeds of San Juan City, served to the office of the
Metro-Manila; Register of Deeds of San Juan
City, Metro-Manila;

“B-2” Proof of service to the To prove that a copy of the

(Page 54 of Bureau of Lands Order and the Petition were
the Record) Management; served to the Bureau of Lands
Management;

“B-3” Proof of service to the To prove that a copy of the

(Page 54 of Land Registration Order and the Petition were
the Record) Authority (LRA); served to the office of the
Register of Deeds of San Juan
City, Metro-Manila;

“B-4” Proof of service to the To prove that a copy of the

(Page 50 of DPWH; Order and the Petition were
the Record) served to the DPWH;

“B-5” Proof of Service to Mr. To prove that a copy of the

(Page 50 of Serafin Mirasol; Order and the Petition were
the Record) served to an adjoining owner,
Mr. Serafin Mirasol;

“B-6” Proof of service to Atty. To prove that a copy of the

(Page 53 of Ernesto Dela Paz; Order and the Petition were
the Record) served to an adjoining owner,
Atty. Ernesto Dela Paz;

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 EXHIBIT DESCRIPTION PURPOSE OF OFFER
(Cont’d.) (Cont’d.) (Cont’d.)

“C” Process Server’s Return; To prove that the Court process

(Page 52 of server attests to the service
the Record) copies of the Order and the
Petition to the persons and
offices concerned as directed by
the Court;

“D” Affidavit of Posting; To prove that a copy of the

(Page 53 of Order was served to, and
the Record) received by the Office of the
Solicitor General;

“E” Notice of Appearance of To prove that the Office of the

(Page 57 of the Office of the Solicitor Solicitor General entered its
the Record) General; appearance for the State in the
Petition;

“E-1” Delegation to the To prove that the Office of the

(Page 58 of Prosecutor’s Office of San Solicitor General delegated its
the Record) Juan City, Metro-Manila; representation to the
Prosecutor’s Office of San Juan
City, Metro-Manila;

“F” Affidavit of Publication; To prove that the Order was

(Page 61 published once a week for three
of the (3) consecutive weeks in
Record) People’s Tonight, on June 23, 30
and July 7, 2018;

“F-1” Clipping of the published To prove the facsimile of the

(Page 61 of Order published Order;
the Record)

“G” June 23, 2018 issue of To prove the date of first

(Page 62 of People’s Tonight publication of the Order;
the Record)

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EXHIBIT DESCRIPTION PURPOSE OF THE OFFER
(Cont’d.) (Cont’d.) (Cont’d.)

“G-1” The published Order To prove the page number of the

(Page 67 of found on Page 12 of the newspaper where the first
the Record) June 23, 2018 issue of publication of the Order can be
People’s Tonight found;

“H” June 30, 2018 issue of To prove the date of second

(Page 70 of People’s Tonight publication of the Order;
the Record)

“H-1” The published Order To prove the page number of the

(Page 76 of found on Page 13 of the newspaper where the second
the Record) June 30, 2018 issue of publication of the Order can be
People’s Tonight found;

“I” July 7, 2018 issue of To prove the date of third

(Page 78 of People’s Tonight publication of the Order;
the Record)

“I-1” The published Order To prove the page number of the

(Page 83 of found on Page 12 of the newspaper where the second
the Record) July 7, 2018 issue of publication of the Order can be
People’s Tonight found;

“J” and Process Server’s Return To prove that copies of the

“K” dated August 10, 2018, Order were served to adjoining
(Page 88 of attesting to the service of owner Mrs. Lucille Pua Uy and
the Record) the Order to Mrs. Lucille the DPWH;
Pua Uy and the DPWH

“L” Judicial Affidavit of Mr. To prove that Mr. Jose Mari

(Page 97 of Jose Mari D. Abeleda Abeleda executed a judicial
the Record) affidavit as his direct testimony;
also offered as part of his
testimony;

EXHIBIT DESCRIPTION PURPOSE OF THE OFFER

(Cont’d.) (Cont’d.) (Cont’d.)

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 “L-1” Signature of Mr. Jose Mari To prove that Mr. Abeleda
(Page 102 D. Abeleda; signed his judicial affidavit; also
of the offered as part of his testimony;
Record)

“M” Special Power of Attorney, To prove that Petitioners

(Page 103 dated March 1, 2018 authorized Mr. Jose Mari
of the Abeleda to represent them for
Record) purposes of the instant Petition;
also offered as part of Mr.
Abeleda’s testimony;

“N” Certified copy of TCT No. To prove the existence and

(Page 105 14258-R; authenticity of the subject TCT
of the No. 14258-R; also offered as part
Record) of Mr. Abeleda’s testimony;

“N-1” Specification statement of To prove the particular

(Page 105 line/points 2-3 in the statement in the technical
of the technical description; description containing the error;
Record)

“O” and Tax Declarations of the To prove that the subject

“O-1” subject property, for the property, both the land and the
(Pages 110 land and the improvement thereon, have been
and 111 of improvements thereon; registered for real estate
the Record) taxation; also offered as part of
Mr. Abeleda’s testimony;

“P” Realty Tax Clearance To prove that the realty taxes on

(Page 112 the subject property have been
of the duly paid up to date; also
Record) offered as part of Mr. Abeleda’s
testimony;

“Q” Certified copy of TCT No. To prove the source of the

(Page 113 9957-R; erroneous information in the
of the technical description of the

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 Record) subject land; also offered as part
of Mr. Abeleda’s testimony;

“R” Certified copy of TCT No. To prove the original and correct
(Page 117 1163-R; technical description of the
of the subject land; also offered as part
Record) of Mr. Abeleda’s testimony;

With the admission of the above documentary exhibits, namely, Exhibits “A” to
“K” and submarkings already forming part of the Court’s record, and Exhibits
“M” to “R” and submarkings, whose true copies are attached hereto, and the
testimony of the witness, Petitioner’s Attorney-in-fact, Mr. Jose Mari Abeleda,
herein Petitioners respectfully rest their case.

WHEREFORE, Petitioners most respectfully pray to this Honorable Court

that the foregoing documentary exhibits be ADMITTED into the record for the
purposes for which they are being offered, and on the basis thereof, and the
testimony of Petitioners’ Attorney-in-fact, Mr. Jose Mari D. Abeleda, that the
instant Petition be GRANTED.

RESPECTFULLY SUBMITTED.

City of San Juan, M.M., Philippines.

October 31, 2018.

GERARDO I. PAYNO, JR.

Counsel for the Petitioners
No. 120-B R. Lagmay St., Brgy. Balong Bato
San Juan City, Metro-Manila
Landline No. (632) 750-5098
Mobile No. (63) 906-2887048
Email Address : gerrlaw52@gmail.com
Roll of Attorneys No. 54184
PTR No. 1128771 | San Juan City, M.M. | 01-03-18
IBP O.R. No. 021033| Pasig City | 01-04-18
MCLE Cert. No. VI-0002214 | Issued May 10, 2017

Copy Furnished:

Prosecutor’s Office (San Juan City, MM)

P. Guevarra cor. Santolan Road ______________________________
San Juan City, M.M. (By personal service)

Office of the Solicitor General Per Registry Receipt No. _________

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134 Amorsolo Street Date : ___________________, 20__
Legaspi Village, Makati City

Mr. Serafin Mirasol Per Registry Receipt No. _________

98 Jose Abad Santos St., Date : ___________________, 20__
Brgy. Little Baguio
San Juan City, M.M. 1500

(Mrs.) Lucille Pua Uy Per Registry Receipt No. _________

102 Mascardo St., Date : ___________________, 20__
Brgy. Little Baguio
San Juan City, M.M. 1500

Atty. Ernesto Dela Paz Per Registry Receipt No. _________

3 Gen. Lim St., Date : ___________________, 20__
Brgy. Little Baguio
San Juan City, M.M. 1500

DPWH Per Registry Receipt No. _________

790 EDSA Diliman, Quezon City Date : ___________________, 20__

CERTIFICATION

This is to certify that a copy of the foregoing pleading has been furnished to
five (5) of the above-named addressees by way of registered mail (with return
card), personal service thereof being impracticable due to time constraint.

GERARDO I. PAYNO, JR.

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 OFFICE OF THE CITY ATTORNEY
Quezon City Hall
Quezon City, Metro-Manila

OFFICE OF THE CITY ATTORNEY

Quezon City Hall
Quezon City, Metro-Manila

PAYNO LAW OFFICE

52 R. Lagmay St., Brgy. Balong Bato
San Juan City, M.M. 1500

PAYNO LAW OFFICE

52 R. Lagmay St., Brgy. Balong Bato
San Juan City, M.M. 1500