Formal Offer of Documentary Exhibits: Regional Trial Court

Republic of the Philippines
REGIONAL TRIAL COURT

Second Judicial Region
Cauayan City, Isabela
Branch 19
SPS. ANDRES P. SORIANO,

JR. and RIOLITA P.
SORIANO duly represented
by JOSELITO R. VELASCO,
Plaintiffs,
CIVIL CASE NO. 19-3415

For: Specific Performance,
-versus- Recovery of Possession
and Damages
BALTAZAR B. BARTOLOME,
Defendant.
x- - - - - - - - - - - - - - - - -- -x
FORMAL OFFER OF
DOCUMENTARY EXHIBITS
(For the Plaintiffs)
The plaintiffs, through counsel, most respectfully offer the

following Documentary exhibits for the purposes stated as follows:
EXHIBIT DOCUMENT PURPOSE
“A” Irrevocable Special 1. To prove that the

Power of Attorney plaintiffs authorized Joselito
executed by Andres P. R. Velasco as attorney-in-fact,
Soriano and Riolita P. to, among others, institute
Soriano dated 9 this action.
December 2014 in
favor of Joselito R. 2. As part of the
Velasco; testimony of plaintiff Riolita P.
Soriano.
“A-1” Signature of plaintiff 1. To prove that plaintiff

Andres P. Soriano; Andres P. Soriano authorized
Joselito R. Velasco as
attorney-in-fact to, among
others, institute this action.
2. To show the usual

signature of plaintiff Andres P.
Soriano.
1
3. To prove that this
signature of plaintiff Andres P.
Soriano is markedly different
from the purported signature
of Andres P. Soriano in the
Deed of Absolute Sale dated
14 November 2011 allegedly
executed by Andres Soriano in
favor of defendant Baltazar
Bartolome.
4. As part of the
testimony of plaintiff Riolita P.
Soriano.
“A-2” Signature of plaintiff 1. To prove that plaintiff

Riolita Soriano; Riolita Soriano authorized
Joselito R. Velasco as
attorney-in-fact to, among
others, institute this action.
2. To show the usual

signature of plaintiff Riolita
Soriano.
3. To prove that this

signature of plaintiff Riolita
Soriano is markedly different
from the purported signature
of Riolita Soriano in the Deed
of Absolute Sale dated 14
November 2011 allegedly
executed by Riolita Soriano in
favor of defendant Baltazar
Bartolome.
4. As part of the
Soriano.
“B” Transfer Certificate of 1. To prove that the

Title No. 022005 in the property subject of the
name of Andres litigation is registered under
Soriano, Jr. married to the name of plaintiff Andres P.
Riolita Pascual issued Soriano married to plaintiff
by the Register of Riolita P. Soriano.
Deeds for the province
of Isabela dated 27 2. As part of the
July 1987; testimony of plaintiff Riolita P.
Soriano.
“C” “Catulagan” executed 1. To prove the existence
2
by Baltazar Bartolome of the said Catulagan.
dated 27 November
2011; 2. To prove that in the
said “Catulagan”, only the
defendant Baltazar Bartolome
appears as a signatory.
3. As part of the
Soriano.
“D” Demand letter dated 1. To prove the existence

23 January 2015. of the said Demand Letter;
2. To prove that the

plaintiffs offered to the
defendant to pay the loan of
the former to the latter in the
amount of Php250,000.00
with demand to the defendant
to surrender the possession of
the property subject of
litigation to the plaintiffs.
3. As part of the
Soriano.
“E” Certificate to File 1. To prove the existence

Action issued by the of the said Certificate.
office of the Lupong
Tagapamayapa of 2. To prove that plaintiffs
Barangay Sinamar complied with the condition
Norte, San Mateo, precedent in instituting this
Isabela dated; action.
3. As part of the
Soriano.
“F” Tax Declaration No. 1. To prove that the

12-31--25-00458 in plaintiffs are the ones paying
the name of Andres the realty taxes of the subject
Soriano; lot.
“G” Official Receipt No.
PGI 0647062 dated 13
February 2015 in the
amount of
Php7,644.32;
“H” Joint Affidavit of Denial 1. To deny that plaintiffs

executed by Andres P. sold the subject lot to the
Soriano and Riolita P. defendant.
Soriano dated 11 June
3
2015; 2. To deny that plaintiffs
appeared before Atty. Louella
Marie R. Agcaoili on 14
November 2011 relative to a
Deed of Sale dated 14
November 2011;
3. To deny the
genuineness and due
execution of the Deed of Sale
dated 14 November 2011.
4. As part of the
Soriano.
“I” Barangay Tanod ID of 1. To show the usual

Andres Soriano respective signatures of the
plaintiffs.
“I-1” Signature of Andres
Soriano 2. To prove that the usual
respective signature of the
“J” Voters I.D. of Riolita P. plaintiffs are markedly
Soriano different from their purported
signature in the Deed of
“J-1” Signature of Riolita P. Absolute Sale dated 14
Soriano November 2011.
3. As part of the
Soriano.
PRAYER
WHEREFORE, it is most respectfully prayed that this
FORMAL OFFER OF DOCUMENTARY EXHIBITS be NOTED
and the exhibits attached hereto be ADMITTED for the
purposes that they are being offered.
RESPECTFULLY SUBMITTED.
Santiago City for Cauayan City, Isabela, 19 October 2020.
THE LAW OFFICES OF DAMASEN & SUBIA

Counsel for the Plaintiffs
Unit 5, Mango Suites, Calao East, Santiago City
E-mail: [email protected]
Mobile No.: 09178730405
Tel. No.: (078) 305-2392
By:
4
ATTY. LUCKY M. DAMASEN
MCLE Compliance No. VI-0018789/2-20-2019
PTR No. 7012010/Santiago City/01-06-2020
Life Member IBP No. 021277/IBP National Office,
Pasig City/01-05-2018
Roll No.37959/07-24-92
&
ATTY. VIRGO M. GULAN

MCLE Compliance Exempted/ Passed the
Bar Exams 26 April 2018
PTR No. 7051474/Santiago City/01-22-2020
IBP No. 117388/02-05-2020
Roll No.71583
NOTICE
The Hon. Clerk of Court

RTC Branch 19, Cauayan City
Isabela
GREETINGS:
Please submit the foregoing Formal Offer of Documentary

Exhibits for the consideration and approval of the Honorable
Court immediately upon receipt hereof.
ATTY. LUCKY M. DAMASEN
Copy furnished:
Atty. Grace A. Manaloto
Counsel for the Defendant
Manaloto Law Office
National Highway, Alibagu, City of Ilagan
EXPLANATION
(Pursuant to Section 11; Rule 13
of the 1997 Rules of Civil Procedure)
5
The original copy of this Pleading/Motion to which this
explanation is attached was:
□ filed with the Honorable Court by registered mail;

□ filed with the Honorable Court by electronic mail;
□ served to the adverse parties by registered mail;
Due to the following reason/s:
□ the distance between this Honorable Court and the counsel’s

office which makes personal filing of the pleading/motion
impracticable;
□ the distance from the office of counsels for both parties which
makes personal service impracticable;
□ lack of office personnel to effect personal service
□ time constraints.
□ Supreme Court Administrative Circular No. 43-2020, directing
that all pleadings shall be filed electronically.
RYAN JAY P. BANEZ

Formal Offer of Documentary Exhibits: Regional Trial Court

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Republic of the Philippines

REGIONAL TRIAL COURT

SPS. ANDRES P. SORIANO,

CIVIL CASE NO. 19-3415

The plaintiffs, through counsel, most respectfully offer the

EXHIBIT DOCUMENT PURPOSE

“A” Irrevocable Special 1. To prove that the

“A-1” Signature of plaintiff 1. To prove that plaintiff

2. To show the usual

“A-2” Signature of plaintiff 1. To prove that plaintiff

2. To show the usual

3. To prove that this

“B” Transfer Certificate of 1. To prove that the

“C” “Catulagan” executed 1. To prove the existence

“D” Demand letter dated 1. To prove the existence

2. To prove that the

“E” Certificate to File 1. To prove the existence

“F” Tax Declaration No. 1. To prove that the

“H” Joint Affidavit of Denial 1. To deny that plaintiffs

“I” Barangay Tanod ID of 1. To show the usual

Santiago City for Cauayan City, Isabela, 19 October 2020.

THE LAW OFFICES OF DAMASEN & SUBIA

ATTY. VIRGO M. GULAN

The Hon. Clerk of Court

Please submit the foregoing Formal Offer of Documentary

ATTY. LUCKY M. DAMASEN

□ filed with the Honorable Court by registered mail;

Due to the following reason/s:

□ the distance between this Honorable Court and the counsel’s

RYAN JAY P. BANEZ

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