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Manifestation

The document is a manifestation submitted by attorneys Lucille Teves and Mercy Dedal on behalf of the defendant Rogelio Itlanas in the civil case Heirs of Buenaventura Tanjay vs. Rogelio Itlanas. The attorneys note a defect in the verification of the previously submitted answer and submit an amended verification. They also argue that the plaintiffs' counsel Gervoso cannot notarize his own verification as he is a party to the case according to Supreme Court rulings. The attorneys request the plaintiffs also submit an amended verification.

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Mercy Dedal-Cruz
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2K views4 pages

Manifestation

The document is a manifestation submitted by attorneys Lucille Teves and Mercy Dedal on behalf of the defendant Rogelio Itlanas in the civil case Heirs of Buenaventura Tanjay vs. Rogelio Itlanas. The attorneys note a defect in the verification of the previously submitted answer and submit an amended verification. They also argue that the plaintiffs' counsel Gervoso cannot notarize his own verification as he is a party to the case according to Supreme Court rulings. The attorneys request the plaintiffs also submit an amended verification.

Uploaded by

Mercy Dedal-Cruz
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

MUNICIPAL TRIAL COURT


8th Judicial Region
Mahaplag , Leyte
--oOo—

HEIRS OF BUENAVENTURA TANJAY


namely: MERCEDES NARRA,
MARILOU PALANAS, LEONILO
TANJAY JR., NICOLAS TANJAY,
AMIEFEL T. EMPRON AND CARMEN
T. ASOY, joined by their respective
spouses ,herein represented by their
Attorney -in-Fact, ERNESTO TANJAY
joined by his wife Racquel Tanjay
  Plaintiffs, CIVIL CASE No. 171
FOR :
RECOVERY OF POSSESSION
-versus- and DAMAGES

ROGELIO ITLANAS
Defendant .
x-------------------------------------------------/

MANIFESTATION
(Submission of Amended Verification )

Atty. LUCILLE M. TEVES and Atty . MERCY G . DEDAL , counsels


of the defendant , respectfully submit amended verification upon
realization that there is a defect on the Answer previously submitted.

Further, that in the complaint filed by the plaintiff, the counsel, Atty.
Gervoso notarized the verification and certification of non-forum
shopping which he himself is a party.

In the case of Ramos vs. Baldo (G.R. No. 199196, March 20,
2012) and Horca vs. People ( G. R. No. 224316, November 10,
2021) , the Supreme Court held that the plaintiff’s counsel
who prepared and signed the plaintiff’s complaint is
disqualified to notarize the verification and certification of
non-forum shopping pursuant to the 2004 Rules on Notarial
Practice. Under the said rule, a notary public is disqualified
from performing a notarial act if he/she is a party to the
instrument or document that is to be notarized.
2

Hence therefore, it is prayed that the counsel of the plaintiffs will


also submit amended verification , otherwise the Complaint lacks
proper verification , thus it can be treated as an unsigned pleading.

Respectfully submitted.

Inopacan , Leyte for Mahaplag , Leyte, Philippines, 13 March 2023.

TEVES LAW OFFICE


San Antonio St.
INOPACAN, LEYTE
6522 Philippines
Email Add : lcmteves@yahoo.com
09266113175

By :

Atty. LUCILLE M. TEVES


Roll of Attorney No. 66995
IBP No. 249420 ;January 09,2023;Leyte Chapter
PTR No.6791929; January 12,2023, Inopacan,Leyte
MCLE Compliance No. VII 0006563

By:

Atty. MERCY DEDAL, MST, RN


Roll of Attorneys 82886
IBP No. 309191; February 2, 2023; Cebu Chapter
PTR No. 8003730; March 9,2023; Mahaplag, Leyte _
MCLE Compliance VIII
Admitted to the Bar May 31,2022

Copy furnished :

ATTY . ALLAN G. JERVOSO Received by: ____________________

Answer
Recovery of Ownership and
Possession with Damages
Heirs of Buenaventura Tanjay vs.
Rogelio Itlanas
3

Counsel for the plaintiffs


Jervoso Law Office Date ___________________
Magsaysay Ave. , Baybay , City, Leyte

RESPECTFULLY SUBMITTED.

Baybay City , Leyte November 24, 2022.

Atty. LUCILLE M. TEVES


Counsel for the Defendant
Roll of Attorneys No. 66995
IBP No. 191746 ;January 12,2022;Leyte Chapter
PTR No.6580638; January 5,2022, Baybay City, Leyte
MCLE Compliance No. VII 0006563

And By :

MERCY G. DEDAL
Roll of Attorneys No. 82886
PTR No. 7230363 : October 3,2022, Mahaplag, Leyte
IBP No. 237341: October 4, 2022; Cebu Chapter
MCLE VIII
Admitted to the Bar May 31,2022.

TEVES LAW OFFICE


G. Mirambel Building
A. Bonifacio St. Baybay City, Leyte
Email Add : lcmteves@yahoo.com
09266113175

EXPLANATION

Answer
Recovery of Ownership and
Possession with Damages
Heirs of Buenaventura Tanjay vs.
Rogelio Itlanas
4

Service is through registered mail due to lack of personnel


to effect personal service .

Copy Furnished :

ATTY . ALLAN G. JERVOSO Post Office Address________


Counsel for the plaintiffs Registry Receipt __________
Jervoso Law Office Date ___________________
Magsaysay Ave. , Baybay , City, Leyte

Answer
Recovery of Ownership and
Possession with Damages
Heirs of Buenaventura Tanjay vs.
Rogelio Itlanas

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