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Republic of the Philippines

DEPARTMENT OF AGRARIAN REFORM


REGIONAL OFFICE III
Pedmar Building, Dolores,
San Fernando, Pampanga

YOLY R. ABOGADO, and


CORAZON D. LAMBANICIO, Docket No. APO – 0306-0574-
Petitioners 2022 to APO – 0306 – 0575 - 2022

-versus- For: Petition for disqualification of


Agrarian Reform Beneficiaries
RONALD E. DIZON, RICOBERT
E. DIZON, ERLY MAY E. DIZON,
RICARDO ANGELO E. DIZON III, and
DEPARTMENT OF AGRARIAN REFORM
PROVINCIAL OFFICE – TARLAC (DARPO
- TARLAC),
Respondents
x----------------------------------------------------------x

MOTION TO WITHDRAW AS PETITIONER WITH MANIFESTATION

Petitioner YOLY R. ABOGADO, thru the undersigned counsel, unto


this Honorable Office, most respectfully aver – that:

1. On 22 April 2021, petitioner Yoly R. Abogado together with


Corazon D. Lambanicio filed with the Honorable Office a
Petition for Disqualification of Agrarian Reform Beneficiaries
(ARBs), specifically against respondents Ronald E. Dizon,
Robert E. Dizon, Erly May E. Dizon III, with the Department of
Agrarian Reform Provincial Office – Tarlac (DARPO-TARLAC)
as a nominal party;

2. The said petition involves as parcel of land covered by Transfer


Certificate of Title (TCT) No. 20760/Certificate of Land
Ownership Award (CLOA) No. 0084155, of the Registry of
Deeds of the Province of Tarlac;

3. During the conduct of the ocular inspection of the Municipal


Agrarian Reform Office, it was required of the petitioners

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Corazon D. Lambanicio and Yoly R. Abogado that they secure
additional documents, i.e., relocation plan of TCT No.
20760/CLOA No. 0084155 as well as a certificate of non-
residency of the registered owners.

4. Hence, petitioners caused the relocation of their respective


cultivations within the subject property as per instruction.
However, it was later found out that the cultivations of each
petitioners belong to different properties, Corazon D.
Lambanicio was found to be within Lot 6934-B (TCT No.
20760/CLOA No. 0084155) and Yoly R. Abogado on Lot 6934-C
(TCT No. 20759/CLOA No. 0084154).

5. Thereafter, an Amended Petition was filed by both petitioners


before the Department of Agrarian Reform Provincial Office –
Tarlac, reflecting the actual occupation of both petitioners.

6. However, upon checking after filing a Motion to Admit


Supplemental Evidence, it was found out that the registered
owners for TCT No. 20759/CLOA No. 0084154 were not
properly impleaded.

7. Thus, petitioner YOLY R. ABOGADO prays that her


participation in the Petition for Disqualification be withdrawn.

8. Petitioner YOLY R. ABOGADO likewise manifests her


intention to file a separate Petition for Disqualification against
the registered owners of Transfer Certificate of Title (TCT) No.
20759/ Certificate of Land Ownership Award (CLOA) No.
00841154.
PRAYER

WHEREFORE, premises considered, Petitioner YOLY R. ABOGADO


is respectfully asking this Honorable Office to:

1. GRANT the withdrawal of her participation in the Petition


for Disqualification; and,

2. NOTE her manifestation that a separate Petition for


Disqualification will be filed by her involving the property covered
by Transfer Certificate of Title (TCT) No. 20759/ Certificate of Land
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Ownership Award (CLOA) No. 00841154 against Ramon C. Dizon
et.al.

Petitioner likewise prays for such further or other reliefs as may be


deemed just or equitable.

Respectfully submitted.
Tarlac City, 06 October 2022.

ATTY. RONILO U. BORJA


Roll of Attorneys No. 77835
IBP receipt No. 234487; 18 July 2022; Tarlac
PTR no. 5223857; 19 September 2022; Tarlac City
MCLE 8th COMPLIANCE / Admitted to Bar May 11, 2022
roniloborja.tsulaw@gmail.com

Copy Furnish:

Ronald E. Dizon
Ricobert E. Dizon
Erly Mae E. Dizon
Ricardo Angelo E. Dizon III
Brgy. Burgos, San Jose, Tarlac

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