Republic of the Philippines

REGIONAL TRIAL COURT OF MISAMIS ORIENTAL

10th Judicial Region
Branch 38
Cagayan de Oro City

SPOUSES FLORIDO AND CIVIL CASE no. R-CDO-20-00500-CV

CHED ROSEL
Plaintiffs : For:

SPECIFIC PERFORMANCE WITH

PRAYER FOR PROVISIONAL REMEDY
OF PRELIMINARY INJUNCTION AND
TRO

-versus-
ROSALINDA ACAIN, GIL
BATIANCILA AND JUNIE COTEJO
Defendants

COMMENT AND OBJECTION

TO FORMAL OFFER OF EVIDENCE

The Defendants, thru undersigned counsel, unto this Honorable Court

most respectfully manifests its comments and objections to the Plaintiff’s
Formal Offer of Evidence for the following reasons:

1. Exhibit “A”; is admitted as to its existence but denies as to the

purpose being offered. The best evidence to prove sale of the
subject land is a Deed of Sale which Plaintiff failed to present;

2. Exhibit “B” is objected for being irrelevant and immaterial. The issue
in this case whether Plaintiff full paid the price of the land so as to
compel Defendants from executing the necessary deed.

3. Exhibit “C” is objected for Plaintiff’s failure to present proof of

genuineness and authenticity of the document. The “Kasulatan”
cannot be admitted as evidence in lieu of the original document.

4. Exhibit “D” is objected since the pictures were not properly

authenticated as required by the Rules.

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 5. Exhibit “E” is objected for failure to prove its authenticity. The person
who made the sketch plan and identified the 50 square meters were
not presented in court and thus, can be treated as hearsay. Same
evidence is likewise irrelevant and immaterial because the issue is
the compliance of full payment of the consideration of the subject
property.

6. Exhibit “F” is objected for failure to prove its authenticity or due

execution. Mere xerox is inadmissible as evidence. It did not prove
full payment of the price of the land as well;

7. Exhibit “G” is admitted.

PRAYER
WHEREFOR, it is respectfully prayed that the foregoing
comments/objections be considered by the Court in resolving the Plaintiff’s
Formal Offer of Exhibits. Other reliefs deemed just and equitable are
likewise prayed for.

Respectfully submitted this July 21, 2022 in the City of Iligan,

Philippines.

SULOG LAW OFFICE

2F, RM 202 Monsanto Bldg.
2nd East Tubod Rosario Heights
Iligan City

By:
ALYASSAR SAUDI S. SULOG
Roll no: 60400 /March 22, 2012-LDN
PTR no: 0447488-1/3/2022- Iligan City
IBP Lifetime no: 013760
MCLE compliance no: 0000418 (6th) until April 2022
Mobile no: 09454654671
Email: attysausulog@gmail.com

Copy furnished:

ATTY. FELIX LACUBTAN

Counsel for Plaintiffs
Door 4, G/G., Avila Bldg.
Capistrano/Nacalaban Sts.,
Cagayan de Oro City
Registered receipt/date: ____________
Email: felix.lacubtan@gmail.com

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 EXPLANATION

Copies hereof are furnished via and electronic mail registered mail
due to the lack of messengerial staff and geographical distance to effect
personal service.

ATTY. ALYASSAR SAUDI S. SULOG