Republic of the Philippines

REGIONAL TRIAL COURT

First Judicial Region
Branch 50
Villasis, Pangasinan

BONIFACIO I. NOCES SR.,

Plaintiff,

- versus - CIVIL CASE NO.V-0846

FOR: Specific Performance

CRISTETA NOCES and

CHRISTOPHER NOCES,
Defendants.
x--------------------------x

REPLY
COMES NOW plaintiff, through counsel and unto this Honorable Court, most
respectfully states that:

1. Plaintiff denies the allegations contained under paragraph 8 and 9 of defendant’s

answer the truth of the matter is that the money paid for the redemption of the title was through
the pocket of plaintiff;

2. Plaintiff denies the allegations contained under paragraph 10 of the answer the truth of
the matter is that the land was mortgaged for the benefit of his son and the latter’s family, for they
used the proceeds of the loan for their personal use. In fact, plaintiff has been benevolent to the
defendants by giving them monies to live by, he being a pensioner and the defendants are being
indigent at that time, and assuming plaintiff will mortgage his property later on, the defendant or
any other person has no right to prevent him prom mortgaging his property;

3. Plaintiff denies the allegations contained under paragraph 11 of the answer, the truth of
the matter is that Prescila Dichoso has no valid claim over any portion of land over the land of
the plaintiff and subject of this case, and in fact, upon realization of said Precila Dichoso of her
mistaken claim over a portion over the land of the plaintiff, she readily executed an affidavit
cancelling her adverse claim over the property in question as entered on the said title;

4. Plaintiff denies paragraph 12 of the answer the truth of the matter is that defendant has
no valid claim over the 300-square meters portion over the property of the plaintiff, defendants
has no basis and their claim is misplaced;

5. Plaintiff admits paragraph 13 of the answer;

6. Plaintiff denies paragraph 14 of the answer for if ever defendants suffered damages, it
is because of their own wrongdoing;

7. Plaintiff will not accede to the condition contained under paragraph 15 of the answer
for the reasons above already cited;

Respectfully submitted.

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 Rosales, Pangasinan, May 20, 2016.

ROGER G. PERALTA IV
Counsel for the Plaintiff
PTR No. 0821150 –01/05/16, Rosales
IBP L. No.618530 – 1/10/11, Pangasinan
Roll of Attorney No. 48271
MCLE Compliance No. IV-0022363-10/29/2013
#82 Zamora St., Zone I V, Rosales, Pang.
C.P.No. 09989580644/09175348050

Copy furnished:

ATTY. ALEJANDRO V. PERIGRINO

Counsel for the Defendants
Alcala, Pangasinan

/ by Personal Service

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