Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
Branch II
Province of Davao del Norte
City of Tagum

CECILIA C. AMOGUIS, Civil Case No.: 4398

Plaintiff,
For: ACTION FOR
- versus – RECOVERY OF
POSSESSION OF
SPOUSES NESTOR MAGBANUA PROPERTY,
AND PHOEBE MAGBANUA, ATTORNEY’S FEES
SPOUSES APOLINARIO ENCIO AND DAMAGES
AND NEMIA ENCIO
Defendants.

FORMAL OFFER OF DOCUMENTARY EVIDENCE

COMES NOW, Plaintiff, by the undersigned counsel and unto

this Honorable Court, most respectfully offers in evidence the
following exhibits:

1. Exhibit : “A”, “A-2” and “A-2”

Description : Original Duplicate Copy of Katibayan ng
Orihinal na Titulo Blg. P-44662; name of the
registered owner Leonilo M. Amoguis
married to Cecilia C. Amoguis; and date of
registration of the said title;
Purpose : To prove that the original duplicate copy of the
said title is issued by the Office of the Register
of Deeds, Tagum City; to prove that the title is
registered under the name of LEONILO M.
AMOGUIS along with his spouse, CECILIA C.
AMOGUIS the Plaintiff in the herein case; to
prove that an annotation was made on
Transfer Certificate of Title No. T-184631 in its
Memorandum of Encumbrances as regards the
affidavit of loss of said title executed by
Petitioner;

2. Exhibit : “B”
Description : Certification dated May 5, 2014 issued by the
Register of Deeds certifying that the
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 Katibayan ng Orihinal na Titulo Blg. P-44662
is intact;
Purpose : To prove that as per records of the Registry of
Deeds, Katibayan ng Orihinal na Titulo Blg. P-
44662 covering Lot No. 809-D, Csd-11-016506
with an area of Twelve Thousand One
Hundred Fifty Four (12, 154) square meters,
more or less located at Cabaywa, Asuncion,
Davao is intact.

3. Exhibit : “C”
Description : Tax Declaration dated February 14, 2014
issued by the Office of the Municipal
Treasurer of the Municipality of Asuncion,
Davao del Norte;
Purpose : To prove that the real property for the year
2014 involving Katibayan ng Orihinal na
Titulo Blg. P-44662 had been paid by the
Plaintiff;

4. Exhibit : “D”
Description : Official Receipt dated February 14, 2014
issued by the Office of the Municipal
Treasurer of the Municipality of Asuncion,
Davao del Norte;
Purpose : To prove that the Plaintiff paid Four Hundred
Ninety Five Pesos and 54/100 (P495.54) as
payment for the real property tax for the year
2014 involving Lot No. 809-D situated at
Cabaywa, Asuncion, Davao del Norte;

5. Exhibit : “E” and “E-1”

Description : July 29 to August 4, 2013 issue of Goldstar
news; and page 6 in the lower right portion
where the Order was published;
Purpose : To prove that the order of the Honorable Court
dated June 26, 2013 has been published on the
July 29, 2013 to August 4, 2013 issue by Gold
Star News, a newspaper of general circulation,
which can be verified on page 6 of said issue;
to prove compliance of jurisdictional
requirements;

6. Exhibit : “F”
Description : Affidavit of Publication of Allan R. Basong,
Publisher of Goldstar News;
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 Purpose : To prove that Gold Star News, a newspaper of
general circulation, has published in three
consecutive weeks the Order of the Regional
Trial Court, Branch 2, in relation to the instant
petition; To prove compliance of jurisdictional
requirements;

7. Exhibit : “G”, “G-1” and “G-2”

Description : Certificate of Live Birth of Rovie Gin R.
Genobia; Entry No. 1 – name of the child; and
Entry No. 3 – date of birth;
Purpose : To prove that the date of birth of petitioner
was entered on April 13, 1992 in her Certificate
of Live Birth;

8. Exhibit : “H”, “H-1” and “H-2”

Description : Certificate of Baptism; name of the petitioner;
and date of birth;
Purpose : To and prove that Petitioner was born on April
13, 1986; to prove further that April 13, 1986 is
the true and correct date of birth of the
Petitioner; to prove that petitioner was not
born in the year 1992;

9. Exhibit : “I”, “I-1” and “I-2”

Description : Form 137-A; the name of the petitioner; and
date of birth;
Purpose : To corroborate and prove that petitioner was
born on April 13, 1986 as shown in her
permanent school record form 137-A; To
prove that April 13, 1986 is the true and
correct date of birth of the petitioner; to prove
that petitioner was not born in the year 1992;

10. Exhibit : “J”, “J-1” and “J-2”

Description : Cover page of the High School Year Book for
SY 2003; inside page of High School Year
Book reflecting the name of the petitioner; and
high school picture, name and date;
Purpose : To corroborate and prove that petitioner was
born on April 13, 1986 as shown in her High
School Year Book issued by Tagum National
High School; to prove that April 13, 1986 is
the true and correct date of birth of the
petitioner; to prove that petitioner was not
born in the year 1992;
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11. Exhibit : “K”, “K-1” and “K-2”
Description : Postal Identification Card; the name of the
petitioner; and the date of birth;
Purpose : To corroborate and prove that Petitioner is a
holder of Postal Identification Card (ID); to
prove that the date of birth of petitioner as
indicated in said identification card is April
13, 1986; to prove further that April 13, 1986 is
the true and correct date of birth of the
petitioner; to prove that petitioner was not
born in the year 1992;

12.Exhibit : “L”, “L-1 to L-8” and “L-9”

Description : Judicial Affidavit; the signatures appearing on
the left margins of each page; and the name
and signature of the affiant on the last page;
Purpose : To prove that petitioner executed a Judicial
Affidavit to take place of her testimony in the
above-entitled petition; to prove that
petitioner has affirmed and confirmed the
truth and veracity of the contents of her
judicial affidavit and the documents attached
thereto; to prove that petitioner was born in
the year 1986 and not in the year 1992; to
prove that an erroneous entry was made in
the certificate of live birth of petitioner as
regards her year of birth; to prove that
petitioner affixed her signature on the left
margins of each page and on the last page of
the judicial affidavit;

13.Exhibit : “M”, “M-1 to M-3” and “M-4”

Description : Judicial Affidavit of Rolando C. Genobia; the
signatures appearing on the left margins of
each page; and the name and signature of the
affiant on the last page;
Purpose : To prove that the father of petitioner, Rolando
C. Genobia, executed a Judicial Affidavit to
take place of his testimony as witness in the
above-entitled petition; to prove that Rolando
C. Genobia has affirmed and confirmed the
truth and veracity of the contents of his
judicial affidavit; to corroborate and prove
that petitioner, Rovie Gin R. Genobia, was
born in the year 1986 and not in 1992; to
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 corroborate and prove that an erroneous entry
was made in the certificate of live birth of
Rovie Gin R. Genobia as regards her year of
birth; to prove that the Rolando C. Genobia
affixed his signature on the left margins of
each page and on the last page of the judicial
affidavit;

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed of this Honorable Court that the above documentary evidence
for the petitioner be admitted for the purposes for which they are
being offered.

The foregoing documentary evidence for the petitioner are

either original or faithful reproduction of the original copies.

With the admission of the forgoing documentary evidence and

testimonial evidence, petitioner is hereby submitting her case for
decision.

Other reliefs and remedies as may be deemed just and

equitable under the premises are likewise prayed for.

Tagum City, Davao del Norte, Philippines, November 4, 2013.

HAROLD R. SATOR
Counsel for the Petitioner
PTR No. 1344057; 01/02/2013; Tagum City
IBP No. 851410; 01/02/2013; Davao del Norte Chapter
Roll of Attorneys No. 50087/Page No. 18/Book No. XX102
TIN 937-389-881
MCLE Compliance No. IV-0000816; Issued on 12/09/2010

SATOR AND PARTNERS LAW OFFICE

Suarez Building, Sobrecary Mabini Streets, Tagum City
Telefax: (084) 216-3382

Copy furnished:

THE CITY PROSECUTOR Received by: ____________

Office of the City Prosecutor
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Tagum City Date Received: __________

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