(To The Plaintiff'S Formal Offer of Documentary Exhibits) : Comment

Republic of the Philippines
MUNICIPAL TRIAL COURT

THIRD JUDICIAL REGION
Camiling, Tarlac
JUAN AGUSTIN and

IMELDA AGUSTIN
Plaintiffs,
-versus- Civil Case No. 14-22
Spouses ARMANDO LORENZO & For: RECOVERY OF

PACITA LORENZO and POSSESSION WITH
Spouses DIOSDADO TOLENTINO & DAMAGES
AZAIDA SUMAOANG
X------------------------------------------------X
COMMENT
(TO THE PLAINTIFF’S FORMAL OFFER OF DOCUMENTARY
EXHIBITS)
DEFENDANT ARMANDO LORENZO, through the undersigned

counsel, unto this Honorable Court, most respectfully submits this
Comment to the Plaintiff’s Formal Offer of Evidence and state that:
1. Exhibit A and sub markings ( Owner’s Duplicate of TCT no.

257495 and the owner’s copy of Tax Declaration) ) is objected to
for being self serving and the purposes for which it is being
offered are likewise objected to considering that the existence of
the same which is not admitted, does not necessarily prove the
occurrence/existence of the events/facts being used as the basis
for its offer for these are happenings which are not reflected nor
annotated on the face of the said document . In addition, mere
possession of these documents does not automatically mean that
the possessor/bearer of them is the owner of the lot or property
being described therein;
2. Exhibit B (Deed of Sale between Virginia Lorenzo and Leonarda

Lorenzo) is being objected to for being self serving and because of
its non registration, the same does not bind nor affect third
persons. Also, the document does not support the purposes for
which it is being offered.
3. Exhibit C ( Subdivision plan with submarkings) is admitted in so

far as to its existence but the purposes for which this is offered is
objected to because the document does not reveal or prove the
actual occurrence of the facts as being claimed by the plaintiff;
4. Exhibit D and series (Real property taxes receipts) are being
objected to for being self-serving and immaterial. The payment of
real property taxes is not conclusive proof of ownership much
more that the same was not coupled with actual possession of the
lot being taxed upon. It is also noteworthy that the plaintiff claims
ownership of the subject lot since 1998 but based on the tax
receipts, taxes due thereon until 1999 were paid by Leonarda
Lorenzo thru Virginia Lorenza;
5. Exhibits G & H (Deed of Sale between Leonarda and Armando

Lorenzo and TCT with no. 425770) are admitted but the purposes
for which they are being offered are objected to, putting emphasis
on the fact that the Court Order which was made the basis for the
birth of TCT no. 425770 has become final and no Action was taken
to nullify the same hence, the said Title is valid for all intents and
purposes this was used.
6. Exhibit J (Letter) is being objected to on the ground of materiality

and admissibility. The said letter does not relate to the issue on
ownership over the subject property. Also, the identity of the
person who wrote the same was not sufficiently identified and that
its execution was not also proven, hence, its contents are mere
hearsay.
PRAYER
Wherefore, premises considered, it is most respectfully prayed of this

Honorable Court not to admit the foregoing exhibits which were objected to
for reasons as above-stated.
March 6, 2015 in Camiling, Tarlac, Philippines.
PUBLIC ATTORNEYS OFFICE

Counsel for the Defendant Armando Lorenzo
CAMILING (TARLAC) DISTRICT OFFICE
ABC Bldg., Camiling Municipal Compound
Camiling, Tarlac
By:
COHLEEN DIANNE S. ANGWAY-DAIT

Public Attorney II
Roll No.58424 05/04/2010
IBP No. 980657 1/08/2015 ; Benguet
MCLE Compliance No. IV-0008511 10/10/12
Copy furnished:
ATTY. DENNIS V. NIÑO

Counsel for the Plaintiff
E. Rodriguez Sr. Ave. Quezon City
ATTY. JOHNSON VALIN PADRE

(Counsel for Defendant Tolentino)
Escolta Corner Tomas Pinpin
Binondo, Manila
Explanation:
Copies of the foregoing were furnished to the counsel of the Plaintiff

and defendant Tolentino through registered mail due to distance and lack
of personnel to effect personal service.
ATTY. COHLEEN DIANNE ANGWAY-DAIT

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Republic of the Philippines

MUNICIPAL TRIAL COURT

JUAN AGUSTIN and

-versus- Civil Case No. 14-22

Spouses ARMANDO LORENZO & For: RECOVERY OF

DEFENDANT ARMANDO LORENZO, through the undersigned

1. Exhibit A and sub markings ( Owner’s Duplicate of TCT no.

2. Exhibit B (Deed of Sale between Virginia Lorenzo and Leonarda

3. Exhibit C ( Subdivision plan with submarkings) is admitted in so

5. Exhibits G & H (Deed of Sale between Leonarda and Armando

6. Exhibit J (Letter) is being objected to on the ground of materiality

Wherefore, premises considered, it is most respectfully prayed of this

March 6, 2015 in Camiling, Tarlac, Philippines.

PUBLIC ATTORNEYS OFFICE

COHLEEN DIANNE S. ANGWAY-DAIT

ATTY. DENNIS V. NIÑO

ATTY. JOHNSON VALIN PADRE

Copies of the foregoing were furnished to the counsel of the Plaintiff

ATTY. COHLEEN DIANNE ANGWAY-DAIT

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