Republic of the Philippines

Supreme Court
REGIONAL TRIAL COURT
THRID JUDICIAL REGION
Branch 23
Cabanatuan City, Nueva Ecija
-o0o-

PADRE CRISOSTOMO MABINI

EXTENSION NEIGHBORHOOD
ASSOSCIATION INC., (PCMENAI).
Represented by
JOSE M. PETALINO JR.
Petitioners,

-versus- CIVIL CASE NO. 8929-AF

For: Declaratory Relief
under Rule 63 of the Rules
of Court

CONRADO ESTRELLA III, in his

capacity as the Secretary of the
Department of Agrarian Reform
(DAR), MARPO GENOVEVA U.
TALPLACIDO member of TASK
FORCE on FR. CRISOSTOMO
ESTATE,
Public Respondents.
x-----------------------------------------------------------x

REPLY TO THE COMMENT DATED 13th MARCH 2023

COMES NOW, Public-Respondent MARPO Genoveva U.

Talplacido, through the Bureau of Agrarian legal Assistance (BALA) of the
Department of Agrarian Reform-Provincial Office of Nueva Ecija (DARPO-
Nueva Ecija) and through the undersigned counsel to this Honorable Board,
most respectfully avers:

1. That the herein petitioner through counsel filed a Comment on the

Special and Affirmative Defense and Motion to Dismiss;

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 2. In the said Comment the petitioner maintained that the
organization, together with its members are entitled to the relief
sought in the instant petition;

3. In reiteration to the of the argument of the herein Public

Respondent, the petitioner is a juridical entity and it is elementary
that a juridical entity such as the petitioner herein has a separate
juridical personality from its incorporators/trustee and members;

4. It does not follow that even if the relief sought by the herein
petitioner and its members are the same will necessarily be
beneficial to the members of the organization or the same will
logically be granted among its members also, it is by the fact of the
existence of this legal fiction of separate juridical personality of the
corporation that the grant of the relief sought by the petitioner will
not automatically be granted unto its members without first
impleading specifically the actual members of the corporation.

WHEREFORE, premises considered, it is most respectfully prayed

unto this Honorable Court that this Reply to the Comment dated 13 th March
2023 be considered in the determination and resolution of the petition for
Declaratory Relief filed by the herein.

Other reliefs just and equitable are likewise prayed for.

April 4, 2023 Cabanatuan City.

By:

BUREAU OF AGRARIAN LEGAL ASSISTANCE

Department of Agrarian Reform
Mabini Ext., Cabanatuan City, Nueva Ecija

ATTY. ALVIN B. SORIANO

Chief, Legal Division
IBP Lifetime Member No. 08883
Issued on January 8, 2010
PTR No. 4497290 L -01/03/23 at Tarlac City
Roll No. 53674
MCLE Compliance No. VII-0001628
Valid until April 14, 2025
Email Address: atty_alvin@rocketmail.com

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The Clerk of Court
RTC, Branch 23
Cabanatuan City, Nueva Ecija

GREETINGS:

Kindly submit the foregoing Reply to the Comment for the consideration
and approval of the Honorable Court upon receipt hereof.

ATTY. ALVIN B. SORIANO

EXPLANATION
The Petitioner is served with a copy of this Reply by registered mail
considering the fact that the office of the undersigned lacks personnel to effect
personal service of the same.

ATTY. ALVIN B. SORIANO

Copy furnished:
ATTY. JOSEPH NIKOLAI B. CHIOCO
#20 Melencio Street, Cabanaruan City,
3100 Nueva Ecija

PADRE CRISOSTOMO MABINI EXTENSION

NEIGHBORHOOD ASSOCIATION, INC.
(PCMENAI) represented by
JOSE M. PETALINO
#018 Papaya Road, Mabini Extension,
Cabanatuan City
3100 Nueva Ecija

SEC. CONRADO ESTRELLA III

SECRETARY OF DEPARTMENT
OF AGRARIAN REFORM
Office of the Secretary, DAR Compound,
Elliptical Road, Diliman,
Quezon City

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MARPO GENOVEVA U. TALPLACIDO
General Tinio Street, corner Maharlika Highway,
Cabanatuan City
3100 Nueva Ecija

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