Republic of the Philippi cic epul ilippines is Sap eee a REGIONAL TRIAL COURT Y | Third Judicial Re THORLEY its iaean, ME MAY 08 2018 torena|corme M, Ldsiee My Abs Se ant service | IN RE: PETITION FOR CANCELLATION OF IENTRY PURSUANT TO SECTION 7 OF PUBLIC ACT NO. 26 ON TRANSFER ERTIFICATE OF TITLE NOS. 039- 1016000163 to 039-2016000180, ALL OF THE EGISTRY OF DEEDS FOR THE PROVINCE IF BULACAN (GUIGUINTO) PETITION NO. P-545-2016 JANDCO PACIFIC CORPORATION, Petitioner, ~versus- re REGISTRY OF DEEDS FOR THE OVINCE OF BULACAN (GUIGUINTO), Respondent. FORMAL OFFER OF DOCUMENTARY EXHIBITS | PETITIONER, through the undersigned counsel, to this Honorable Court, pectfully offers in evidence its documentary exhibits as follows: 3 1. Exhibit “A"-is a copy of the Petition dated August 30, 2016 with sub- marking as Exhibit “A-1”, the signature of MARVES A. FLORENDO, the Aibrney-in-Fact and legal representative of the petitioner appearing on page 5 of the Petition below the portion relating to Verification and Certification on Non- Fojum Shopping; S 2. Exhibit “B”-is the Order of the Honorable Court dated March 6, 2017 wit} sub-markings as Exhibit “B”-1 to Exhibit “B-3”, respectively the Registry RetLirn Receipt by the Registry of Deeds for the Province of Bulacan, Guiguinto Brahh, the Registry Return Receipt by the Office of the Solicitor General and the fksg | Registry Return Receipt by the Land Registration Authority, Quezon City and attesting the fact of receipt of the said Order dated March 6, 2017; 3. Exhibit “C”-is the Certificate of Posting showing compliance on the Fequired posting of the Order dated March 6, 2017; 4. Exhibit “D”-is a copy of the Notice of Appearance from the Office of the jolicitor General, Exhibi Qffered to prove compliance on the jurisdictional requirements of the petition; ‘A” to “D”, inclusive of their respective sub-markings are being 5. Exhibit “E”, is the Secretary's Certificate (Annex “A” of the Petition) ecuted by ANTONIO A. PICAZO on July 28, 2016 of LANDCO PACIFIC RPORATION and it is being offered as proof of the legal authority of RVES A. FLORENDO to file the Petition and to represent the petitioner in this tition and to form part of his testimony; 6. Exhibit “F” to Exhibit “W”, respectively are the certified copies of Tipnsfer Certificate of Title Nos. 039-2016000163 to 039-2016000180 (Annexes “B} to “S" of the Petition) with sub-markings as Exhibit “F-1” and Exhibit “W-1”, re$pectively the annotation of encumbrance pursuant to Section 7 of Republic Act No. 26 and they are being offered to prove the fact of ownership of the petitioner over the lot covered by the certificates of title subject matter of the petition and to prove the existence of the said certificates of title and the anjjotation of encumbrance pursuant to Section 7 of Republic Act No. 26 and to forth part of the testimony of MARVES A. FLORENDO; | 7. Exhibit “X”, is the certified copy of Transfer Certificate of Title No. RT- 66453 (Annex “T” of the Petition) and it is being offered to prove that the annptation of encumbrance pursuant to Section 7 of Republic Act No. 26 was first annotated on the reconstituted certificate of title with Transfer Certificate of Title No. RT-66453 of the Registry of Deeds for the Province of Bulacan (Guiguinto) was administratively reconstituted on July 29, 1998 and the said lbrance was not cancelled after the subdivision of the parcel of land coveted by the said certificate of title; hence, it was carried over on the resultant certifjcates of title which are now subject matter of the petition or the foregoing 4, whi enctag Transfer Certificate of Title Nos. 039-2016000163 to 039-2016000180; further, it is being offered to form part of the testimony of MARVES A. FLORENDO; 8. Exhibit “Y”, is the certified copy of Transfer Certificate of Title No. 039- prnsoossed which was originated from RT-66453; it is being offered to prove the fact that the subject Transfer Certificate of Title Nos. 039-2016000163 to 039- pied were originated from the reconstituted Transfer Certificate of Title (0. RT-66453, wherein the annotation of encumbrance pursuant to Section 7 of ‘epublic Act No. 26 was first annotated and to form part of the testimony of Tanves a FLORENDO; 9. Exhibit “2”, is the copy of Certification (Annex “U” of the Petition) ipsued by the Registry of Deeds for the Province of Bulacan (Guiguinto) and Heing offered to prove the fact that the two (2)-year lien provided under Section 7 of Republic Act No. 26 which was carried over on the subject certificates of title 's already expired on July 29, 2000 without anybody laying claim or interest Jereon and to form part of the testimony of MARVES A. FLORENDO; 10. Exhibit “AA” to Exhibit “RR”, are copies of the Tax Declarations vering the properties subject matter of this petition and they arg being offered to prove the fact that the lot covered by the subject certificates of title were dgclared for tax purposes and to form part of the testimony of MARVES A. FIORENDO; 11. Exhibit “SS”, the Certified Machine Copy of the Consolidation- Subdivision Plan as Surveyed for LANDCO PACIFIC CORPORATION, under Pqs-03-204214 and it is being offered to prove the fact that all the lots covered by thq subject certificates of title were the result of the subdivision of the parcel of wok originally covered by the reconstituted certificate of title with Transfer Ceftificate of Title No. RT-66453, which was administratively reconstituted on July 29, 1998 and wherein the encumbrance pursuant to Section 7 of Republic Act No. 26 was annotated and was carried over on the resultant Certificates of titlq which are now subject matter of the petition or the foregoing Transfer Cettificate of Title Nos. 039-2016000163 to 039-2016000180; further, it is being offgred to prove the relative location of the lots covered by the subject certificates of title which are adjacent to each other and bounded on the properties owned by the petitioner and to form part of the testimony of MARVES A. FLORENDO. A4 Note: (All the documentary exhibits are attached to the records of the case pee copies were already furnished to the Office of the Solicitor General and fice of the Provincial Prosecutor, Malolos, Bulacan as annexed documents of he Petition and Judicial Affidavit of MARVES A. FLORENDO. The machine fopies which were marked in evidence were already compared with the original Gopies and the photocopies are faithful reproduction thereof.) -PRAYER- WHEREFORE, to this Honorable Court, it is most respectfully prayed that those exhibits inclusive of their respective sub-markings be admitted as being eee and upon admission, the petitioners be considered to have rested its case ahd judgment be rendered by allowing the reliefs prayed for in the petition. Other reliefs that are just and equitable under the premises are also prpyed for. Candelaria Quezon for the City of Malolos, Bulacan, May 2, 2018. a7 aN submitted, NOEL |. MALALUAN Roll No. 43651, May 6, 1999 IBP Life Roll No. 05094, February 17, 2005 PTR No. 5829921, January 3, 2018 MCLE Compliance No. V-0012849/1-8-2016 Ona Street, Candelaria, Quezon Counsel for the Petitioner5. NOTICE OF HEARING AND EXPLANATION OF SERVICE AND FILING Office of the Solicitor General 134 Amorsolo Street Legaspi Village, Makati City Office of the Provincial Prosecutor City of Malolos, Bulacan The Clerk of Court Regional Trial Court Branch 82, City of Malolos, Bulacan Kindly take notice that the undersigned is submitting the foregoing Formal Dffer of Documentary Exhibits to the Honorable Court immediately upon receipt iereof for its consideration and approval. | cum at Pe of explanation, copy of the foregoing Formal Offer of cumentary Exhibits was served to the Office of the Solicitor General and Office f the Provincial Prosecutor, Malolos, Bulacan and filed the Honorable Court frrough registered mail in lieu of personal service due to the great distance of the id office from the office of the undersigned. A NOEL I. MALALUANa ATTY. NOEL |. MALALUAN __ ‘Ona Street ’ 4323 Candelaria. Quezon Ofpice oF tee Souerfor Genera / PY fmereolo SIrvet, Legacpi Villoge Mehot Ciby. ee c eS Re DOMESTIC, ee RESSTERED