Legal Forms SCRIPT

Scene: After the counsel for the plaintiff presented all the documents necessary for
trial that includes demand letter to the respondents as the primary requirements to
pursue the case. . The court hearing will be conducted as skeduled.

In the court room during trial on civil case No. AB-1234, FOR: Unlawful
Detainer, a case filed by the palintiff Dante Denubo to the defendants Janmar
tresspares.

The Defendant questionning the legality of plaintiff’s ownership to the Land he

has tilled.
The counsel for the plaintiff will present the evidences showing the proof of
ownership as stated in exhibit A, B, and C.

COUNSEL FOR THE COMPLAINANT. Good morning your honor, I am atty Eduardo C.
Delgado jr. Appearing for the plaintiff Dante Dinubo in a civil case 1234 for unlawful detainer.
I will present the prof of ownership of the plaintiff to his 10,000 square meter property in
Hagkol Poblacion Valencia City.as attached in ANNEXES A, B and C your honor. Annex A
is the Deed of Sale , Annex B is the released of real estate mortgage and Annex C. is the
Contract to Sale your honor…..( elaborate the content of the attached documents )

COUNSEL FOR THE DEFENDANT: Good Day your honor, counsel. I am Atty Nicole Cajes
representing herein Mr. Janmar Trespares. The evidence presented by the Atty. Delgado
failed to prove that his client is the real owner of the 10,000 square meter property in Hagkol
Poblacion Valencia City. To prove that my client is the real owner of the property, here are
the following evidence.
Exhibit D here your honor shows that in the year 2000, Mr. Gabrielle Delgado, the late
father of Mr. Danilo Delgado, executed a Deed of Absolute Sale in favor of Mr. Jun
Trespares, the late father of my client. The document clearly shows that my clients late
father bought the disputed land that is being claimed by the plaintiff.
Exhibit E then here your honor, shows the Extrajudicial Settlement that was executed
by my client since his late father was unable to execute a last will and testament or transfer
the said land on my clients name since his father died on an accident.
Lastly, Exhibit F is the Tax Declaration of my client Mr. Janmar, which clearly proves
that my client is the real owner of the disputed property.

(CIVIL CASE) Republic of the Philippines

METROPOLITAN TRIAL COURT
City Of Valencia
Branch 10
DANTE DENUBO
Plaintiff,
CIVIL CASE No. AB-1234
-versus- FOR: Unlawful Detainer

JANMAR TRESPARES
Defendant
Exhibit A. DEED OF ABSOLUTE SALE

KNOW ALL MEN BY THESE PRESENTS:

This DEED made and executed by and between:

DANILO C. DELGADO, single, Filipino and a resident of P5 kalasungay valencia City;

hereto referred as the vendor;

In favor of

DANTE DINUBO , of legal age, Filipino, single and a resident of P1, Aglayan Malaybalay
City, hereunto referred as the vendee.

WITNESSETH

That the Vendor is the owner of a parcel of land located at P10 Hagkol Poblacion
Valencia City, and more particularly described and bounded as follows:

“A parcel of land designated as Lot No. 123 covered by Tax Declaration No. 4567; bounded
on the North by Robinson building, property on the south by school site; on the west by Jane
Doe property and on the east by John Doe property containing an area of ten thousand
square meters (10,000) more or less.” of which I am the registered owner in fee simple, my
title thereto being evidenced by Transfer (or Original) Certificate of Title No.234-56, issued
by the Register of Deeds of Valencia City.

That the Vendors by these presents do hereby SELL, TRANSFER and

CONVEY, the above described property unto the Vendee, DANTE DINUBO , in the
amount of ONE MILLION PESOS (P1,000, 000. 00), Philippine Currency to the full
satisfaction to the Vendee.

It is hereby mutually agreed that the vendee shall bear all the expenses for the execution
and registration of this deed of sale.

IN WITNESSS WHEREOF, I have hereunto signed this deed of sale, this 20 th day of
March, 2010 at City of Malaybalay, Bukidnon Philippines.

DANILO DELGADO DANTE DELGADO

Vendor Vendee

SIGNED IN THE PRESENCE OF:

MARISSA DELGADO EDITHA NALDO

ACKNOWLEDGMENT
Republic of the Philippines)
City of Valencia) S.S.

BEFORE ME, a Notary Public, for and in Valencia City Bukidnoon, this 20th day of March
personally appeared:

Name TIN Number Issued On/At

DANILO DELGADO 987-836-789 March 10, 2010/ Malaybalay City

DANTE DENUBO 765-261-789 March 11, 2010/ Malaybalay City

all known to me to be the same persons who executed the foregoing instrument and hereby
acknowledged to me that the same is their free and voluntary act and deed.

This instrument consisting of two (2) pages, including this page on which this
acknowledgment is written refers to a DEED OF SALE and has been signed by the parties
and their witnesses and sealed with my notarial seal.

WITNESS MY HAND AND NOTARIAL SEAL.

Doc No. 41 ATTY EDUARDO C. DELGADO JR

Book No.1 Notary Public
Page no. 10 Until December 31, 2010
Series of 2010 ROLL OF ATTY NO. 123123
IBP O.R.12345-01-03,2022 BUKIODNON
PTR NO.12345-01-03-22 MALAYBALAY CITY
TIN 123-445-556
MCLE COMPLIANCE NO.123445
Exhibit B. RELEASE OF REAL ESTATE MORTGAGE

KNOW ALL MEN BY THESE PRESENTS:

I, REY NALDO , of legal age, Filipino, single, and a resident of Aglayan Malaybalay
City Bukidnon,

WITNESSETH:

That I am the Mortgagee in that Deed of Real Estate Mortgage executed by DANTE
DINUBO on January 1, 2019;

That having this date received the full amount of Five Million Pesos (P 500,000.00), in
Philippine Currency, from the Mortgagor, which is in full and complete settlement of the
obligation secured by the said mortgage, I do hereby forever RELEASE, DISCHARGE, AND
CANCEL the aforementioned Mortgage, covering the parcel of land covered by Transfer
Certificate of Title No. 007125 of the Registry of Deeds of Pampanga, situated in P10
Hagkol Poblacion Valencia City with an area of 10,000 square meters, more or less.

IN WITNESS WHEREOF, I have hereunto set my hand, this 18th day of March 2015 at
Valemcia City Bukidnon, Philippines.

REY NALDO
Mortgagee

ACKNOWLEDGMENT BEFORE ME personally appeared:

PERSONS ID NO
REY NALDO Driver’s License No.9219211
DANTE DINUBO Driver’s License No.6000001

all known to me to be the same persons who executed the foregoing instrument and
hereby acknowledged to me that the same is their free and voluntary act and deed.

WITNESS MY HAND AND SEAL, on this 18th day of March 2022

Doc No. 41 ATTY EDUARDO C. DELGADO JR

Book No.5 Notary Public
Page no. 11 Until December 31, 2015
Series of 2022 ROLL OF ATTY NO. 123123
IBP O.R.12345-01-03,2022 BUKIODNON
PTR NO.12345-01-03-22 MALAYBALAY CITY
TIN 123-445-556
MCLE COMPLIANCE NO.123445
Exibit C. CONTRACT TO SELL

KNOW ALL MEN BY THESE PRESENTS:

This CONTRACT TO SELL, made and executed this 5th day of March, 2021 by and
between:

DANTE DINUBO, of legal age, single, Filipino, and with residence of P1, Aglayan
Malaybalay City, hereinafter referred to as the SELLER;
-AND-

MELVIN FERRERA , of legal age, single, Filipino, and with residence and postal address at
Anlugan Kabanglasn Bukidnon, hereinafter referred to as the BUYER;

WITNESSETH;

WHEREAS, the SELLER is the absolute and registered owner of a parcel of land consisting
of Ten Thousand (10,000) square meters, more or less, located at P10 hagkol poblacion
valencia city covered by Transfer Certificate of Title No. 234-56, issued by the Register of
Deeds of Valencia City;

WHEREAS, the BUYER has offered to buy and the SELLER has agreed to sell the above-
mentioned property under the terms and conditions herein below set forth;

NOW THEREFORE, for and in consideration of the total sum of One Million Pesos (Php
1,000,000.00) Philippine Currency, and of the covenants herein after set forth the SELLER
agrees to sell and the BUYER agrees to buy the aforesaid property subject to the following
terms and conditions:

1. Possession to the subject property shall be delivered by the SELLER to the BUYER upon
full payment of the total consideration;

2. Upon full payment of the total price, the SELLER shall sign and execute a DEED OF
ABSOLUTE SALE in favor of the BUYER. The SELLER shall likewise execute and/or
deliver any and all documents, including but not limited to the original copy of Transfer
Certificate of Title, Tax Declaration and all other documents necessary for the transfer of
ownership from SELLER to the BUYER.

IN WITNESS WHEREOF, the parties have hereunto affixed their signatures, this 5 th day of
March, 2021 at Baguio City, Philippines.

DANTE DENUBO MELVEN FERRERA

ACKNOWLEDGMENT

BEFORE ME, a Notary Public, for and in the City of Pasay, this 16th day of March 2021
personally appeared:

Name CTC Number Date/Place Issued

DANTE DENUBO 22823900 February 1, 2021 / Malaybalay City
MELVEN FERRERA 60129371 January 1, 2021 / Malaybalay City

This instrument, consisting of two (2) pages, including the page on which this
acknowledgment is written, has been signed on the left margin of each and every page
thereof by the concerned parties and their witnesses, and sealed with my notarial seal.

WITNESS MY HAND AND SEAL, on this 16th day of March 2021

Doc No. 23 ATTY EDUARDO C. DELGADO JR

Book No.3 Notary Public
Page no. 10 Until December 31, 2021
Series of 2021 ROLL OF ATTY NO. 123123
IBP O.R.12345-01-03,2022 BUKIODNON
PTR NO.12345-01-03-22 MALAYBALAY CITY
TIN 123-445-556
MCLE COMPLIANCE NO.123445

Exibit C. DEED OF ABSOLUTE SALE

KNOW ALL MEN BY THESE PRESENTS:

This DEED made and executed by and between:

GABRIELLE DELGADO, single, Filipino and a resident of P5 kalasungay valencia City;

hereto referred as the vendor;

In favor of

JUN TRESPARES , of legal age, Filipino, single and a resident of P1 NHA Malaybalay City,
hereunto referred as the vendee.

WITNESSETH

That the Vendor is the owner of a parcel of land located at P10 Hagkol Poblacion
Valencia City, and more particularly described and bounded as follows:

“A parcel of land designated as Lot No. 123 covered by Tax Declaration No. 4567; bounded
on the North by Robinson building, property on the south by school site; on the west by Jane
Doe property and on the east by John Doe property containing an area of ten thousand
square meters (10,000) more or less.” of which I am the registered owner in fee simple, my
title thereto being evidenced by Transfer Certificate of Title No.123-45, issued by the
Register of Deeds of Malaybalay City.

That the Vendors by these presents do hereby SELL, TRANSFER and CONVEY, the above
described property unto the Vendee, JUN TRESPARES, in the amount of TWO MILLION
ONE HUNDRED FIFTY THOUSAND PESOS (P2,150, 000. 00), Philippine Currency to the
full satisfaction to the Vendee.

It is hereby mutually agreed that the vendee shall bear all the expenses for the execution
and registration of this deed of sale.

IN WITNESSS WHEREOF, I have hereunto signed this deed of sale, this 22 ND day of
June, 2000 at City of Malaybalay, Bukidnon Philippines.

GABRIELLE DELGADO JUN TRESPARES

Vendor Vendee

SIGNED IN THE PRESENCE OF:

AGATHA DELGADO GEMMA TRESPARES

ACKNOWLEDGMENT
Republic of the Philippines)
City of Malaybalay) S.S.

BEFORE ME, a Notary Public, for and in Valencia City Bukidnoon, this 22 nd day of June,
2000 personally appeared:

Name TIN Number Issued On/At

GABRIELLE DELGADO 123-456-789 March 10, 1999/ Malaybalay City

JUN TRESPARES 987-654-321 March 11, 1998/ Malaybalay City

all known to me to be the same persons who executed the foregoing instrument and hereby
acknowledged to me that the same is their free and voluntary act and deed.

This instrument consisting of two (2) pages, including this page on which this
acknowledgment is written refers to a DEED OF SALE and has been signed by the parties
and their witnesses and sealed with my notarial seal.

WITNESS MY HAND AND NOTARIAL SEAL.

Doc No. 22 NICOLE RAYNE R. CAJES

Book No.3 Notary Public
Page no. 5 Until December 31, 2001
Series of 2000 ROLL OF ATTY NO. 45678
IBP O.R.09876-01-03,01 BUKIODNON
PTR NO.12345-01-03-01 MALAYBALAY CITY
TIN 123-445-556
MCLE COMPLIANCE NO.123445

Exibit C. EXTRAJUDICIAL SETTLEMENT AMONG HEIRS OF A DECEASED

PERSON
KNOW ALL MEN BY THESE PRESENTS:

This EXTRAJUDICIAL SETTLEMENT, made and entered into by and among:

JANMAR TRESPARES, Filipino, of legal age, and residents of P1 NHA Malaybalay

City,Bukidnon, hereby voluntary state:

WITNESSETH:

That the above-named party is the legal compulsory heirs of JUN TRESPARES, who
died last November 3, 2004, without any last will and testament;

That the above-named parties have agreed to divide EQUALLY among themselves,
whatever properties, assets, claims, receivables, etc., that their parents may have left and/or
shall receive, including their parents’ claim from GSIS, PAG-IBIG, and/or SSS;

That at the time of his death, JUN TRESPARES was the absolute owner of a certain
property which was duly registered as per Transfer Certificate of Title No.123-45 issued by
issued by the Register of Deeds of Malaybalay City.

That to the best knowledge and information of the parties hereto, the said deceased
persons left no debts.

IN WITNESS WHEREOF, the parties hereto have hereunto set their hands this 21 st
day of July 2005 at Malaybalay City Philippines.

JANMAR TRESPARES

SIGNED IN THE PRESENCE OF:

ANDREA TRESPARES ALEX TRESPARES

ACKNOWLEDGMENT
 BEFORE ME, 21st day of July 2005 at Malaybalay City, Philippines, personally
appeared Janmar Trespares, known to me to be the same persons who executed the
foregoing instrument and acknowledged to me that the same is done voluntarily and freely.

This instrument, consisting of two (2) pages, including the page on which this
acknowledgement is written, has been signed on the left margin of each and every page by
the parties and their witnesses, and sealed with my notarial seal.

IN WITNESS WHEREOF, I have hereunto set my hand and seal in the day and place
above written.

Doc No. 21 NICOLE RAYNE R. CAJES

Book No. 8 Notary Public
Page no. 5 Until December 31, 2006
Series of 2005 ROLL OF ATTY NO. 45678
IBP O.R.09876-01-03,06 BUKIODNON
PTR NO.12345-01-03-06 MALAYBALAY CITY
TIN 123-445-556
MCLE COMPLIANCE NO.123445

Exibit C.