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Formal Offer of Evidence-Ancheta vs. Ancheta

The document is a formal offer of documentary evidence from the defendant in the civil case of Bienvenido R. Ancheta versus Mila R. Ancheta regarding recovery of possession and damages of a lot in question. The defendant offers 24 exhibits including property records, tax receipts, affidavits, and correspondence to prove that the original owners were Pedro and Francisca Ancheta, their children inherited the land, and that the defendant has a right to her share of the land.

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62 views3 pages

Formal Offer of Evidence-Ancheta vs. Ancheta

The document is a formal offer of documentary evidence from the defendant in the civil case of Bienvenido R. Ancheta versus Mila R. Ancheta regarding recovery of possession and damages of a lot in question. The defendant offers 24 exhibits including property records, tax receipts, affidavits, and correspondence to prove that the original owners were Pedro and Francisca Ancheta, their children inherited the land, and that the defendant has a right to her share of the land.

Uploaded by

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

Second Judicial Region


MUNICIPAL TRIAL COURT IN CITIES
Santiago City
Branch II

BIENVENIDO R. ANCHETA,
Plaintiff, Civil Case No. 21-054

-versus- FOR:

MILA R. ANCHETA and all “Recovery of Possession


Persons claiming rights under her, and Damages”
Defendants.
x------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

Defendants, through the undersigned counsel, and unto this Honorable Court,
respectfully offer in evidence the following documents:

Exhibit “1”- Sketch Plan of the lot in question.

Exhibit “2”- Property Record Form of the lot in question in the name of Pedro
Ancheta.

Exhibit “3”- Death Certificate of Pedro Ancheta.

Exhibit “4”- Death Certificate of Francisca Ancheta.

Exhibit “5”- Affidavit of Villamor Ancheta, Apolinario Ancheta, Elena Ancheta,


Bienvenido Ancheta, Mila Ancheta, and Sotera Ancheta.

Exhibit “6”- Order in MSA V-58896 of Pedro Ancheta dated April 8, 1980.

Exhibit “7”- Miscellaneous Sales Application.

Exhibit “8”- Order in MSA No. (II-2) 1049 dated September 11, 1989.

Exhibit “9”- Realty Tax Receipt No. 3046537

Exhibit “10”- Realty Tax Receipt No. 7873841

Exhibit “11”- Realty Tax Receipt No. 0019496

Exhibit “12”- Realty Tax Receipt No.0040896

1
Exhibit “13”- Realty Tax Receipt No.0084529

Exhibit “14”- Realty Tax Receipt No. 0063497

Exhibit “15”- Realty Tax Receipt No.0113761

Exhibit “16”- Realty Tax Receipt No.0139351

Exhibit “17”- Realty Tax Receipt No. 0276701

Exhibit “18”- Realty Tax Receipt No. 0308257

Exhibit “19”- Realty Tax Receipt No. 0333516

Exhibit “20”- Realty Tax Receipt No. 0333516

PURPOSES: Exhibits “1” to “20” are offered to prove that the lot in question was
originally owned by spouses Pedro Ancheta and Francisca Ancheta who declared it with
the Assessor’s Office of Santiago, Isabela and Pedro Ancheta applied for Miscellaneous
Sales with the Bureau of Lands until his and his demise; that upon the death of the
spouses Pedro Ancheta and Francisca Ancheta, their children inherited the land; that an
Affidavit of Adjudication with Waiver was executed by some of the heirs of Pedro and
Francisca Ancheta which was the basis of the application for Miscellaneous Sales of
Bienvenido Ancheta and the cancellation of Miscellaneous Sales Application of Pedro
Ancheta; that despite the affidavit of adjudication with waiver signed by defendant, she
continued paying the taxes of the land;

Exhibit “21”- Letter of defendant to Atty. Jose Romeo S. Dela Cruz dated October
17, 2020.

Exhibit “22”- Demand to vacate of Atty. German M. Balot addressed to defendant


dated February 13, 2020.

Exhibit “23”-Response letter of defendant dated February 27, 2020 to Atty.


German Balot’s letter.

Exhibit “24”- Registry Return Receipts to Atty. Jose Romeo S. Dela Cruz.

PURPOSE: Exhibits “21”, “22”, “23”, and “24” are offered to prove that even prior
to the filing of the complaint in this case, and when asked to vacate the subject land, she
explained to Atty. Balot and Atty. Dela Cruz that she and other co-owners of the subject
land have a right over their respective shares so that plaintiff should reconvey their
shares to them.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this Honorable


Court to admits exhibits “1”, “2”, “3”, “4”, “5”, “6”, “7”, “8”, “9”, “10”, “11”, “12”, “13”,

2
“14”, “15”, “16”, “17”, “18”, “19”, “20”, “21”, “22”, “23”, and “24” in evidence for the
purposes above-stated.

He prays for such other relief and remedy just and equitable in the premises.

Santiago City, June 21, 2023.

ATTY. ABRAHAM B. SABLE


SABLE & PARTNERS
4 Lanes, Villasis, Santiago City
MCLE Exemption No. VII-Acado05482, Valid Until 04-14-2025
Not. Com. No. 0270, Issued on July 12, 2022 by the RTC Br.36
PTR No. 3323003, 01-03-23
IBP No. 263537, 01-03-23
Roll No. 25865
Until December 31, 2023
Santiago City
Counsel for Defendant

Copy furnished:

ATTY. JOSE ROMEO S. DELA CRUZ


Santiago City

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