REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 98
Quezon City

IN THE MATTER OF
CANCELLATION OF THE
ENCUMBRANCE ON
RECONSTITUTED TCT NO. 004-
2022000133 OF DEEDS OF
QUEZON CITY

LRC Case No. R-QZN-22-04288-

LR

SPS. DARIUS MADLANSACAY

MERCADO and MARY ANGELIE
DE LEON MERCADO,
Petitioners.
X---------------------------------------------X

FORMAL OFFER OF EXHIBITS

PETITIONERS, by counsel and unto this Honorable Court,

most respectfully submit the following documentary evidence along
with the testimony of petitioner’s witness/ authorized representative,
LOLITA Y. GERONIMO, and offer the following exhibits:

Exhibit Description Purpose

Exhibit “A” Petition dated April 19, To prove that the proper
2022 Petition was filed before
this Honorable Court.

Exhibit “B” Order dated May 12, 2022
setting the case for initial
hearing on November 4,
2022 with fallback date on
December 5, 2022
To prove that the said
case was set for hearing
and that the said copies
of the same were duly
served to the concerned
government agencies.

Exhibit “C” Manifestation and Motion To show that petitioners

filed by the petitioners through counsel
 through counsel on June 6, respectfully prayed for
2022 the continuation of
presentation of
jurisdictional
requirements without
need of publication in
Official Gazette.

Exhibit “D” Order dated June 29, 2022 To show this Honorable
Court’s Resolution
pertaining to the
Manifestation and
Motion filed by the
petitioners through
counsel on June 6, 2022.

Exhibit “E” Notice of Appearance To show that the Office

from the Office of the of the Solicitor General,
Solicitor General (OSG) Makati City was duly
dated June 13, 2022 notified of this case.

Exhibit “E-1 ” Deputization letter of the To show that the Office

Office of the Solicitor
General to the Office of the
City Prosecutor dated June
13, 2022
of the City Prosecutor of
Quezon City was
deputized to assist the
Office of the Solicitor
General in this case.

Exhibit “F” Comment/Opposition To show that the Office

(On Petitioners’
Manifestation and Motion
dated 06 June 2022) filed
by the OSG on June 23,
2022;
of the Solicitor General
filed their
comment/opposition to
the Manifestation and
Motion.

Exhibit “G” Sheriff’s Return dated July To prove that copies of

28, 2022; the Order and Petition
were duly served to the
concerned government
agencies.

Exhibit “H ” Certificate of Posting To prove that proper

dated July 28, 2022 compliance was made as
to the posting

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 requirement.

Exhibit “I” Compliance filed by the To show and prove that

petitioners through the Petitioners have
counsel on September 13, complied with all the
2022 jurisdictional
requirements of
publication, notice and
posting of subject
Petition.

Exhibit “J” Order dated September 19, To prove that the

2022 Petitioner’s compliance
was noted by this
Honorable Court.
Exhibit “K” Order dated October 7 To prove that the said
2022 case was set for hearing
and that the said copies
of the same were duly
served to the concerned
government agencies.

Exhibit “L” Order dated October 14, To prove that the

2022 hearing set on 04
November 2022 was
transferred to December
05, 2022 at 9:30 in the
morning.

Exhibit “M” Sheriff’s Return dated Same purposes as that of

October 24, 2022; Exhibit “G”.

Exhibit “N” Certification of Publication To show and prove that

dated September 5, 2022; the Petitioners have
complied with all the
Exhibit “O” Copy of Official Gazette jurisdictional
vol. 118 no. 35 dated requirements of
August 29, 2022; publication, notice and
posting of subject
Exhibit “O-1” Pages 9928 to 9929 of said Petition.
and “O-2” OG;
Exhibit “P” Copy of Official Gazette
vol. 118 no. 36 dated
September 5, 2022;

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Exhibit “P-1” Pages 10245 to 10246 of
and “P-2” said OG;
Exhibit “Q” Special Power of Attorney To show that Lolita Y.
dated 20 April 2022, Geronimo was
consisting of two (2) pages designated as the duly
authorized
representative of the
petitioners.

To form part of the

testimony of petitioners’
witness/authorized
representative, Lolita Y.
Geronimo.

Exhibit “R” Certification dated April 6 Exhibit “Q” is offered to

2022 issued by the show that the two-year
Registry of Deeds, Quezon lien period annotated at
City. the back of TCT No. 004-
2022000133 has already
expired on September
08, 1996, without
anybody laying claim or
interest thereon.

To form part of the

testimony of petitioners’
witness/authorized
representative, Lolita Y.
Geronimo.

Exhibit “S” True electronic copy of To prove that petitioners

Transfer Certificate of Title are the registered
No. 004-2022000133, owners of subject
registered in the name of property in this case.
petitioners, Sps. Darius
Madlansacay Mercado
To form part of the
and Mary Angelie De testimony of petitioners’
Leon Mercado. witness/authorized
representative, Lolita Y.
Exhibit “S-1” The portion wherein the Geronimo.
encumbrance of Sec. 7 of
Rep. Act No. 26 is

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 annotated, as found in
page 3 of the said title.
Exhibit “T” Tax Declaration No. F- Same purposes as that of
011-10183, registered in Exhibit “S”.
the name of petitioners,
Sps. Darius Madlansacay
Mercado and Mary
Angelie De Leon Mercado.

Exhibit “U” Tax Declaration No. G- Same purposes as that of

011-01218, registered in Exhibit “S”.
the name of petitioners

Exhibit “V” Real Property Tax To prove that petitioners

Certification dated April 07 have fully paid the real
2022 from the Office of the estate taxes for the land
City Treasurer of Quezon on subject property up
City. to 4th quarter of 2022.

To form part of the

testimony of petitioners’
witness/authorized
representative, Lolita Y.
Geronimo.

Exhibit “W” Real Property Tax To prove that petitioners

Certification dated April
07, 2022 from the Office of
the City Treasurer of
Quezon City.
have fully paid the real
estate taxes for the
improvement on subject
property up to 4th
quarter of 2022.

To form part of the

testimony of petitioners’
witness/authorized
representative, Lolita Y.
Geronimo.

PRAYER

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 WHEREFORE, premises considered, it is respectfully prayed
that all the documentary evidence, together with the testimony of
petitioners’ witness, LOLITA Y. GERONIMO, be ADMITTED for
the purposes for which they are being offered. After their admission,
petitioners respectfully rest their case.

Other just and equitable reliefs are likewise prayed for.

Quezon City for Manila City, 23 February 2023.

FERRER & ASSOCIATES LAW OFFICES

Counsel for the Petitioners
Suite 805 Union Square Condominium
No. 145 15th Avenue, Cubao, 1109 Quezon City
Tel. Nos. 8911-3370/8911-3375
Email address: info@ferrerlaw.com.ph

For the Firm:

PEDRO M. FERRER
MCLE Compliance No. VII-0007458, valid until 04-14-2025
PTR No. _____________, ___________, Quezon City, M.M.
IBP Lifetime Member No. 04238, 01-02-2003, Pasig City
Roll of Attorneys No. 24394
Mobile #0917-8343160

JON PETER B. FERRER

MCLE Compliance No. VII-0007457, valid until 04-14-2025
PTR No. _____________,__________ Quezon City, M.M.
IBP Lifetime Member No. 06011, 29 June 2006
Roll of Attorneys No. 52013
Mobile #0917-8000178

EVECAR B. CRUZ
MCLE Compliance No. VII-0015388, valid until 04-14-2025
PTR No. _____________,__________ Quezon City, M.M.
IBP Lifetime Member No. 08120, Pasig City
Roll of Attorneys No. 52684
Mobile #0917-8383227

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 TOMAS T. RICALDE, JR.
MCLE Compliance No. VII-0007483, valid until 04-14-2025
PTR No. ______________, ____________ Quezon City, M.M.
IBP O.R. Member No. ____________, Pasig City
Roll of Attorneys No. 32645
Mobile #0917-4659011