REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

5TH JUDICIAL REGION
BRANCH 156, ANY TOWN, BULACAN

JUANA DELA CRUZ

Petitioner,
-versus-

CIVIL CASE No. 12345

For: Quieting of Title

PEDRO SANTOS
Defendant.
x------------------------------------------------x
MANIFESTATION WITH MOTION TO STRIKE OUT
____________________________________
COMES NOW the undersigned counsel for the defendants in the above-entitled case and
to this Honorable Court, respectfully manifests:
1. That on January 5, 2012 the Honorable Judge issued an Order directing counsel for
the plaintiff to make and submit the necessary corrections in the Formal Offer of
Exhibits filed by the latter within fifteen (15) days from receipt of such Order;
2. That on April 19, 2012, this Honorable Court averred plaintiffs failure to comply with
the January 5, 2012 Order, and by motion of plaintiffs counsel, the Honorable Judge
granted another fifteen (15) days therefrom to comply with said Order;
3. That notwithstanding, counsel for the plaintiff has yet to make and submit the
corrections in the Formal Offer of Evidence as ordered by this Honorable Court;
4. That with counsel for the plaintiffs inexcusable failure to comply with this
Honorable Courts Order, the presentation of defendants evidence is held in
abeyance and is unjustifiably delayed.
In view of the foregoing, defendants through the undersigned counsel respectfully
motions this Honorable Court to strike out the following exhibits in Plaintiffs Formal Offer of
Evidence, on the ground that these exhibits were neither previously marked nor presented
during the trial:
1.
2.
3.
4.
5.

Exhibit A - Sinumpaang Salaysay of Mario Valiente;

Exhibit D - Tax Declaration No. 9876;
Exhibit F - Tax Declaration No. 2345;
Exhibit J - Tax Declaration No.0007;
Exhibit Q - Tax Declaration No.7890.
PRAYER

WHEREFORE, premises considered, it is most respectfully prayed that this Honorable

Court strike out Exhibit A - Sinumpaang Salaysay of Mario Valiente; Exhibit D - Tax
Declaration No. 9876; Exhibit F - Tax Declaration No. 2345; Exhibit J - Tax Declaration

No.0007; and Exhibit Q - Tax Declaration No.7890 from Plaintiffs Formal Offer of Evidence for
the reason herein set forth.
Other reliefs just and equitable under the premises are also prayed for.
RESPECTFULLY SUBMITTED.
Metro City for Anytown, Bulacan, August 7, 2012.

SERCHIEF YOUNG
Counsel for the Defendants
Roll No. 12345
IBP No.111177/ January 23, 2012 / Metro City
PTR No. 998866 / Metro City / Jan. 31, 2012
MCLE Compliance III No. 8000
YOUNG, OLD & TRODDEN LAW OFFICES
Suite 101, Philippine Tower
Liberality Street, Metro City
Tel. no. (632) 222-0000
e-mail: serchief@yahoo.com

NOTICE
The Branch Clerk of Court
RTC Branch 156
Anytown, Bulacan
Greetings:
Please submit the foregoing Manifestation with Motion to Strike Out (Unmarked
Exhibits in Plaintiffs Formal Offer of Evidence) to the Honorable Court for its consideration
upon receipt hereof.
SERCHIEF YOUNG

Copy Furnished:
ATTY. ROMEO JULIETA
Counsel for the Plaintiff
588 Shakespeare Street
Anytown, Bulacan
Explanation
The undersigned counsel informs the Honorable Court that copy of the foregoing
MANIFESTATION with MOTION TO STRIKE OUT was served upon counsel for the plaintiff by
registered mail due to distance, time constraints and lack of staff to effect personal service.

SERCHIEF YOUNG