As to the presentation of the RED/ delegate of DENR:

- Issuance of subpoena ad testificandum and duces tecum under rule 21 of the

Rules of Court

If the copy was objected due to alteration(s):

A. The document was submitted as evidence to prove the existence of the

agreement that the person in the name of Ramona Bermudez has indeed
transferred the lot contested to the defendants Edhel Tuico and Anicita De Leon.
(find jurisprudence)

B. Alteration did not change the meaning or language of the instrument S31 R132

If the copy was objected on the ground that the DOCUMENT was not the original one

A. Your Honor, may we make of record the fact that the copy thereof has already
been utilized by the plaintiff RSA as their evidence (specifically as noted as
exhibit___________) and considering that the defendant also utilized the same
as her evidence to prove the existence of agreement, contesting the same would
also be tantamount to contesting their own evidence.

B. Second point is that the Original document rule applies ONLY when the subject
of the inquiry is the contents of the document. Here the subject of the inquiry is
not the contents of the document but the existence of agreement wherein the
right of the defendant to hold in possession of the property arises (Air France v.
Carrascoso, 18 SCRA 155)

C. The objection that the introduction thereof would violate the Best Evidence Rule
does not lie since the Best Evidence Rule does not apply to object or real
evidence (People v. Tandoy, 192 SCRA 28)

D. Look for: admission pursuant to S8 R8 (failure to specifically deny)

E. Entries in Official records made in the performance of his duty by a public officer
of the Philippines, or by a person in the performance of a duty specially enjoined
by law are excepted from the hearsay rule (S46 R130)

Possessor in the concept of an owner

-one who, whether in good faith or bad faith claims to be and acts as if he is the owner.
He thus recognizes no title of ownership in another, with respect to the property
involved.

1
 - Adverse possession or acts of dominion in derogation of owner’s interest may
include the construction of permanent buildings and the collection of rentals,
harvesting of the fruits of fruit-bearing trees, the giving of advice as to the
boundaries of adjoining properties, the payment religiously of the taxes on the
property.

Possessor in good faith

- One who is not aware that there exists in his Title or Mode of acquisition any flaw
which invalidates it (DBP v CA, 316 SCRA 650 [1999]
- Before one purchases real property, he must make inquiries regarding the right if
any of those in possession thereof. (Republic v. CA 102 SCRA 331)
- Art. 527 Good faith is always presumed, and upon him who alleges bad faith on
the part of the possessor rests the burden of proof.
- Note art 538 (jurisprudence)