Republic of the Philippines

Fourth Judicial Region

REGIONAL TRIAL COURT
Branch 15, Naic

RE: IN THE MATTER OF

SURRENDER OF WITHHELD
OWNER’S DUPLICATE OF
TRANSFER CERTIFICATE
OF TITLE NO. T-444458 OF
THE REGISTRY OF DEEDS
OF CAVITE PROVINCE,

EMELITA N. STO. TOMAS,

Petitioner,
LRC Case No. NC-8340-688
-versus-

WINNIE C. NAZARENO and

REGISTRY OF DEEDS OF
THE PROVINCE OF CAVITE,
Respondents.
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FORMAL OFFER OF EVIDENCE

Respondent Winnie C. Nazareno, through undersigned

counsel, unto this Honorable Court, respectfully offer the
following documentary and object evidence:

Exhibits Description Purpose/s

1 A copy of the Transfer To prove that the
Certificate of Title No. T- subject property came
444458 from respondent’s
predecessors-in-
interest: Lorenza
Nazareno, Arturo
Nazareno, and Melita
Nazareno;

To further prove that

petitioner is not the sole
 owner of the subject
property;

2 Tax Declaration No. 15- To prove that Loreta

0007-00161 Nazareno paid the taxes
3 Tax Declaration No. 15- due on the subject
0007-00164 property;
4 Official Receipt No. CAV
4047974
5 Real Property Tax
Clearance dated 22
November 2019
5-A Official Receipt No.
3122535 for payment of
Tax Clearance
5-B Official Receipt No.
3122474 for payment of
Documentary Stamp Tax
6 A copy of the Deed of To prove that Loreta
Absolute Sale dated 06 Nazareno sold the
February 2015, executed subject property for
by Loreta Nazareno valuable consideration
to Divinia Nazareno
Roman;
7 Judicial Affidavit of To support the
Divinia Roman averments of
Respondent in her
Answer and Judicial
Affidavit;

To prove that Divinia

Roman is the actual
occupant since 1965 of
the subject property;

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed unto this Honorable Court that the foregoing documentary
exhibits be admitted for all purposes for which each and all said
exhibits were being offered in proving the material allegations in
the present petition.

Other reliefs and remedies that are just and equitable are
likewise prayed for.

City of Bacoor, 07 October 2020.

 ATTY. DOROTHY DALE D. ORIAL
Counsel for the Defendant,
In collaboration with Atty. Antonio
Nicolas
25 Pagtakhan St., Poblacion,
Bacoor, Cavite
PTR No. 8427325| 25-Aug-20 | Makati
IBP No. 126815 | 06-Aug-2020 | PPLM
Attorney’s Roll No. 75669
MCLE Compliance No. N/A
(Admitted to the Bar 2020)
dorothy.orial@gmail.com | 09175046729

Copy furnished:

THE BRANCH CLERK OF COURT

Regional Trial Court Branch 15
Naic, Cavite

ATTY. MANUELITO C. DIOSOMITO

Counsel for the Petitioner
Naic, Cavite, 4110