Republic of the Philippines

COURT OF APPEALS
Manila

CA G.R. No. CV- 106967

(RTC-Branch 91, Quezon City)
(Lower Court Case No. Q-12-71901)

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ROSALINA I. CHUA,
Plaintiff-Appellee,

-versus-

MRS. LOLITA G. JABAO, MRS. ELIZABETH OMPOC, MR. &

MRS. ROBERTO GARCIA, MS. ANGELITA DIZON AND SAN
FRANCISCO DEL MONTE, INC.,
Defendant- Appellants.
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BRIEF FOR THE APPELLEE

With
ENTRY OF APPEARANCE
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ALFEROS ARMAS & ASSOCIATES

Law Office
Unit K, No. 1143 San Francisco Del Monte Ave.,
Barangay Paltok 1105, Quezon City
By:

JOHN THOMAS S. ALFEROS III

PTR No. 3846308; 01.07.17 Q.C.
IBP No. 137009; 01.09.17; Q.C.
Roll No. 48188; Page No. 138; Book no. XX
MCLE Compliance No. V-0019255; 04.15.16 until 04.14.19
Mobile No. 0918-9390566
jtsalferosiiilaw@yahoo.com

Page 1 of 15
 INDEX

Pages
COVER PAGE 1

INDEX 2

ENTRY OF APPEARANCE 3

PARTIES 4

STATEMENT OF THE CASE 4

STATEMENT OF THE FACTS 5-6

COUNTER STATEMENT OF FACTS 6

ISSUES 7

ARGUMENTS/DISCUSSIONS 7-11

RELIEF 11

Laws and Authorities in Support of Appellees Brief:

Civil Code of the Philippines

Revised Rules of Court
Regalado, Remedial Law Compendium, Volume 1, 6th Revised Edition
Riano, Civil Procedure, 2nd Bantam Edition 2009

Cases cited:

Uy vs. First Metro Integrated Steel Corporation, Gr. No. 167245,

September 27, 2016,
Gaitero v. Almeria, 651 SCRA 544
Carbonilla v. Abiera, 625 SCRA 461
Delfin v. Billiones, Gr. No. 146550, March 17, 2016
Nazareno vs. Court of Appeals, Gr. No. 138842, October 18, 2000
Beltran vs. Nieves, 634 SCRA 242
Monasterio-Pe vs. Tong 646 SCRA 161
Ramos-Balalio vs. Ramos 479 SCRA 533

Page 2 of 15
 REPUBLIC OF THE PHILIPPINES
COURT OF APPEALS
MANILA

ROSALINA I. CHUA,
Plaintiff-Appellee,

CA G.R. No. CV- 106967

-versus- (RTC-Branch 91, Quezon City)
(Lower Court Case No. Q-12-71901)

MRS. LOLITA G. JABAO, et. al.,

Defendant- Appellants.
x--------------------------------------------x

ENTRY OF APPEARANCE

ALFEROS ARMAS & ASSOCIATES LAW OFFICE, most

respectfully enters its appearance as Co-Counsel for ROSALINA I.
CHUA, Plaintiff-Appellee in the above-entitled case.

Henceforth, it is hereby respectfully prayed that the

undersigned counsel be furnished with copies of all pleadings that
may be filed as well as notices and processes that will be issued in
connection with the above-captioned case at the address herein below
indicated.

ALFEROS ARMAS & ASSOCIATES

Law Office
Unit K, No. 1143 San Francisco Del Monte Avenue
Barangay Paltok 1105, Quezon City

With My Conformity

ROSALINA I. CHUA
Plaintiff-Appellee

Page 3 of 15
 BRIEF FOR THE PLAINTIFF-APPELLEE

Plaintiff-Appellee, by counsel to this Honorable Court most

respectfully presents her brief and avers that:

THE PARTIES

Plaintiff-Appellee, ROSALINA I. CHUA, is of legal age,

Filipino, widow and a resident of 3 K. Resthaven St., Marimar
Townhomes, Barangay Bungad, Quezon City.

Defendant-Appellant, Lolita Jabao, is of legal age, Filipino

and residing at 1439 Camia Street, Area A, Camarin, Caloocan City.
Defendant-Appellants, Elizabeth Ompoc, Mr. & Mrs. Roberto
Garcia and Angelito Dizon, are all of legal ages, Filipinos, and all
residing at 36 Aragon St., San Francisco Del Monte, Quezon City.
Defendant-Appellant, San Francisco Del Monte Inc., is a
corporation organized under and existing under the laws of the
Republic of the Philippines, with office address at Rm. 216 Navidad
Building, corner Pinpin and Escolta, Manila and/or at No. 2541 Jesus
Extension, Pandacan, Manila.

I. STATEMENT OF THE CASE

1.0 This is a case of Recovery of Possession and Damages, filed by

the Plaintiff-Appellee, Rosalina I. Chua, before the Regional Trial
Court Branch 91 of Quezon City, to recover possession from the
Defendants-Appellants Mrs. Lolita G. Jabao et,al., of a real
property situated at # 36 Aragon St., Barangay Paltok, Quezon City,
covered by Transfer Certificate Title No. 004-2010009085 of the
Registry of Deeds of Quezon City.

1.1 The Defendant-Appellants appealed before this Honorable

Court the decision of the Regional Trial Court Branch 91, Quezon
City, dated 11 January 2016, the dispositive portion of which reads as
follows:

WHEREFORE, premises considered, judgment is

hereby rendered, ordering defendants Lolita G. Jabao,
Elizabeth Ompoc, Sps. Roberto Garcia and Angelita
Dizon and all person claiming rights under them:

1. To VACATE the subject property covered under TCT

No. 004-2010009085 in the name of plaintiff

Page 4 of 15
 Rosalina I. Chua and surrender the possession thereof
to herein plaintiff and
2. To PAY plaintiff the amount of SIXTY THOUSAND
PESOS as acceptance fee and FIVE THOUSAND
PESOS (P5,000.00) per court appearance. 1

II. STATEMENT OF FACTS

2.0On October 11, 2010, Plaintiff-Appellee purchased from the

defendant-appellant San Francisco Del Monte, Inc. a parcel of land
identified and covered by Transfer Certificate of Title No. RT 118492
(210018) of the Register of Deeds of Quezon City, more particularly
described as follows:

TRANSFER CERTIFICATE OF TITLE

No. RT-118492(210018)

A parcel of land (shown on the plan of subdn. As lot

No. 3, Blk No. 75, Psd-1650, being a portion of Lot 4-2-B-
6, Psd 1577, GLRO Rec. No. 3563), Situated in Barrio of
San Francisco Del Monte, Municipality of San Juan Del
monte, Rov. Of Rizal; xxx containing an area of Three
Hundered Twenty Eight (328) Sq. Meters, more or less.
xxx2

2.1While it appears on the face of Transfer Certificate of Title No. RT-

118492(210018) that the location of the property is in the Barrio of
San Francisco Del Monte, Municipality of San Juan Del Monte,
Province of Rizal, its actual location is at 36 Aragon St., Brgy. Paltok,
San Francisco Del Monte, Quezon City, as per certification of the
Land Registration Authority, dated August 23, 20123;

2.2By virtue of Deed of Absolute Sale, Transfer Certificate of Title No.

RT-118492(210018), in the name of defendant San Francisco Del
Monte, Inc., was cancelled and Transfer Certificate if Title No. 004-
2010009085 was issued in the name of herein Plaintiff-Appellee,
Rosalina I. Chua.4

2.3The above-mentioned purchase, as earlier stated, is evidence by a

Deed of Absolute Sale, dated October 11, 2010, with a warranty that
1 Copy of the said Decision dated 11 January 2016 is hereunder attached as ANNEX 1.

2 Copy of the quoted TCT No. RT-118492(210018) is hereunder attached as ANNEX 2.

3 Copy of the said Certification is herein attached as ANNEX 3.

4 Copy of the said TCT No. 004-2010009085 is hereunder attached as ANNEX 4

Page 5 of 15
the property sold is free from all liens and encumbrances of
whatever kind and nature5;
2.4When Plaintiff-Appellee was to take possession of the above-
described property, Defendant-Appellants, Lolita G. Jabao, Elizabeth
Ompoc, Mr. and Mrs. Roberto Garcia, Angelita Dizon, and tenants
refused to surrender possession of the same to the herein Plaintiff-
Appellee, despite repeated demands verbal and written and
because of the said refusal of Defendants-Appellants Lolita G. Jabao,
Elizabeth Ompoc, Mr. and Mrs. Roberto Garcia, to vacate the said
premises, Plaintiff-Appellee could not take possession of the property
that she legally owns;

2.5 Plaintiff-Appellant, through her lawyer then, on November 12,

2010, demanded to the Defendant-Appellants Lolita G. Jabao,
Elizabeth Ompoc, Mr. and Mrs. Roberto Garcia, to vacate the
premises but, despite the said demands, the said Defendants-
Appellants failed, refused and neglected and still fail, refuse and
neglect to vacate the said premises6;

2.6Despite repeated demands made by the Plaintiff-Appellee to the

Defendant-Appellants and because of the latters continued and
obstinate refusal to heed the said demands and vacate the premises
and peacefully surrender possession to the Plaintiff-Appellee, plaintiff
was constrained to bring the matter to the Lupong Tagapamayapa of
Barangay Paltok, District 1, Quezon City, where earnest efforts were
exerted towards amicable settlement but to no avail, as shown by the
document titled Certificate to File Action issued by the Tanggapan
ng Lupong Tagapamayapa of Barangay Paltok, District 1, Quezon
City7, pursuant to the provision of Sections 410 and 412 of RA 7160;

2.7Because of the unjustified refusal of the of Defendant-Appellants

Lolita G. Jabao, Elizabeth Ompoc, Mr. and Mrs. Roberto Garcia, to
vacate the subject premises, Plaintiff-Appellee was compelled to file
an action for ejectment against the said Defendant-Appellants before
the Metropolitan Trial Court of Quezon City, Branch 36, which case,
however, was dismissed on the ground of lack of jurisdiction 8.

2.8It was discovered by herein Plaintiff-Appellee that Defendant-

Appellants Lolita G. Jabao, Elizabeth Ompoc, Mr. and Mrs. Roberto
Garcia, and Angelita Dizon are no longer residing in the house on the
property but are leasing the same to other persons who are paying
rents to them;
5 Copy of the said Deed of Absolute Sale dated October 11, 2010 is hereunder attached as ANNEX 5.

6 Copies of the Demand Letters is herein Attached as ANNEXES 6 to 6-B.

7 Copy of the said Certificate to File Action is herein attached as ANNEX 7.

8 Copy of the said Decision dated July 27, 2011, is herein attached as ANNEX 8.

Page 6 of 15
2.9 The summons for defendant Elizabeth Ompoc was unserved.
The summons and copy of complaint to defendant San Francisco Del
Monte, Inc., were returned unserved because no company is holding
office at the given address.

2.10 In an order dated March 18, 2013, Defendant-Appellants Lolita

G. Jabao, Angelita Dizon, Mr. & Mrs Roberto Garcia were declared in
default for failure to file their Answer within the period allowed by the
Rules. Defendant-Appellant Jabao filed a Motion for Reconsideration
of the Order dated March 18, 2013 which the trial court granted and
admitted her answer.

2.11 Atty. Ramon R. Mendez, the counsel of the Defendant-

Appellants, moved for the postponement of the hearing set on March
20, 2015 for reasons that he was allegedly scheduled to go to Texas,
USA for medical checkup from March 15, 2015 to June 30, 2015. The
said motion was granted, thus the marking of exhibits before the
Branch Clerk of Court set on March 20, 2015 and the pre-trial set on
April 10, 2015 were cancelled and reset to July 6, 2015 and August 7,
2015.

2.12 During the continuation of the pre-trial on August 7, 2015, Atty.

Ramon R. Mendez, Jr., failed to appear despite notice. Upon Motion,
plaintiff was allowed to present evidence ex-parte.

2.13 On February 18, 2016, Defendant-Appellants, through their

new counsel, Atty. Jayson Del Rosario of the Public Attorneys Office,
filed an Entry of Appearance with Motion for Extension of Time to
file Motion for Reconsideration. The Trial Court, in its order dated
March 1, 2016, granted the said extension.

2.14 On the 09 March 2016, Defendant-Appellants filed a Motion to

Admit Attached Motion for New Trial, instead of Motion for
Reconsideration. Expectedly, the trial court denied the said Motion in
its Order dated 02 May 2016.

2.15 Un-wavered defendants-appellants appealed the instant case.

III. ISSUES

The following issues were raised by the Defendant-Appellants

in their Brief

1. THE TRIAL COURT ERRED IN DENYING

DEFENDANT-APPELLANTS MOTION FOR NEW
TRIAL DESPITE THE FACT THAT THERE WAS A

Page 7 of 15
 REASONABLE GROUND FOR GRANTING THE SAID
MOTION.

2. THE TRIAL COURT GRAVELY ERRED IN RULING

FOR PLAINTIFF-APPELLLEE DESPITE THE FACT
THAT HER COMPLAINT LACKED ANY CAUSE OF
ACTION AGAINST THE DEFENDANT-APPELLANTS.

IV. DISCUSSION

The Regional Trial Court is

correct in denying Defendant-
Appellants Motion for New Trial

4.0 In denying Defendant-Appellants Motion for New Trial, the

Trial Court in its Order dated 02 May 2016, ratiocinated that:
A new trial may be granted on the following
grounds: fraud, accident, mistake or excusable negligence
and newly discovered evidence.

Defendant averred that there was an excusable

negligence in view of the untimely death of her counsel,
Atty. Ramon B. Mendez on November 15, 2015.

The court observed that defendant Jabao knew of

Atty. Mendez death on November 27, 2015 and yet she
waited for the Courts decision before she went to the
Court to inform of her counsels death.

Further, in an Order dated March 1, 2016, the Court

granted Atty. Jayson del Rosarios Motion for Extension
of Time or Until March 04, 2016 to file a Motion for
Reconsideration of the Decision dated January 11, 2016.
Defendants Jabao Motion for New Trial was filed in
Court only on March 09, 2016, without any explanation
why the Motion was belatedly filed.
Under the circumstances, the Court finds no
compelling reason that constitutes fraud, accident,
mistake or excusable negligence and newly discovered
evidence in contemplation under Rule 37 of the Rule of
Court that warrant the grant of new trial.

WHEREFORE, the Motion for New Trial is

DENIED

Page 8 of 15
 SO ORDERED.9

4.1The Trial Court committed no error in the afore-quoted Order, for

the same is based on the clear and categorical wording of the laws and
jurisprudence;
4.2 Under the Rules, A motion for new trial or reconsideration is
filed within the period for appeal (Sec. 1, Rule 37, Rules of Court) and
No motion for extension of time to file a motion for new trial or
reconsideration shall be allowed (Sec. 2, Rule 40: Sec. 3, Rule 41,
Rules of Court);

4.3 Further, the Rules states that the period for appeal is within
fifteen (15) days after notice to the appellant of the judgment or final
order appealed from (Sec. 2, Rule 40; Sec. 3, Rule 41; Sec. 2, Rule 45,
Rules of Court). The filing of a timely motion or new trial interrupts
the period to appeal (Sec. 2, Rule 40; Sec 3, Rule 41, Rules of Court);

4.4 Furthermore, the aggrieved party may move the trial court to
set aside the judgment or final order and grant a new trial for one or
more of the following causes materially affecting the substantial right
of the said party:

a.) Fraud, accident, mistake or excusable negligence

which ordinary prudence could not have guarded
against and by reason of which such aggrieved
party has probably impaired in his rights; or

b.)Newly discovered evidence, which could not,

with reasonable diligence, have discovered and
produced at the trial, and which if presented
would probably alter the result (Sec. 1, Rule 37,
Rules of Court).

4.5 In this case, the Trial Court correctly observed that Defendant-
Appellant Jabao knew of Atty. Mendez death on November 27, 2015
and yet she waited for the Courts decision dated January 11, 2016
which she claimed to have received on February 3, 2016 before she
went to the Court to inform of her counsels death. This alone would
show non-excusable negligence and lack of ordinary prudence on the
part of the Defendant-Appellant;

4.6 The Plaintiff-Appellee disagree to the contention of the

DefendantAppellants that the Trial Court strictly applied the rules of
procedure in denying the latters motion for new trial, for the same is
not correctly anchored on facts and in law;

9 Copy of the afore-quoted Order dated 02 May 2016 is herein attached as ANNEX 9.

Page 9 of 15
4.7 A thorough review of the records of the case would clearly
reveal that the Trial Court was very lenient to the Defendant-
Appellant. It could be recalled that Defendant-Appellant was already
declared in default, however upon filing of a motion for
reconsideration by the Defendant- Appellant the Trial Court
reconsidered its order. Worthy also of mentioning is the fact that the
Trial Court also granted the several motions for postponement of the
Defendant-Appellants;

4.8 Further, when Atty. Jayson Del Rosario of the Public Attorneys
Office, counsel of the Defendant-Appellants, filed for an Extension
of Time to file Motion for Reconsideration the same was
granted by the Trial Court this alone made the Decision becomes
final and executory since motion for extension of time to file motion
for reconsideration is not allowed by the Rules of Court. Despite the
facts that the Defendant-Appellants was given another fifteen (15)
days or until March 04, 2016 to file her motion for reconsideration,
still Defendant-Appellant fails to file the same and instead she filed a
motion for new trial on March 09, 2016, without any explanation
why the Motion was belatedly filed;

4.9 With the above facts, herein Defendant-Appellants has the

audacity of claiming that the Trial Court strictly applied the Rules
against her;

4.10 The Plaintiff-Appellant also disagree to the contention of the

Defendant-Appellants that their negligence and that of their counsels
constitutes excusable negligence which is a ground for the grant of
new trial. In the case of Uy vs. First Metro Integrated Steel
Corporation, Gr. No. 167245, September 27, 2016, the Supreme
Court explicitly stated that petitioners argument that his counsels
negligence was so gross that he was deprived of due process fails to
impress. Gross negligence is not one of the grounds for a motion for a
new trial. We cannot declare his counsels negligence as gross as to
liberate him from the effects of his failure to present countervailing
evidence. The Court does not consider as gross negligence the
counsels resort to dilatory schemes, such as (1) the filing of at least
three motions to extend the filling of petitioners answer; (2) his non-
appearance during the scheduled pre-trials; and (3) the failure to file
petitioners pre-trial brief, even after the filing of several motions to
extend the date for filing;

4.11 Despite of the leniency of the Trial Court to the Defendant-

Appellants and the unvarying non-compliance of the Defendant-
Appellants to the rules, her claim of excusable negligence is an affront
not only to the majesty of laws and rules but also to logic and
common sense;

Page 10 of 15
The trial court is correct in
ruling for the Plaintiff-
Appellee
4.12 The claim of the Defendant-Appellant that Plaintiff-Appellee
lacked any cause of action is again not supported by law and
jurisprudence. In a litany of decisions of the Supreme Court it stated
that Whoever owns the property has the right to possess it. (Gaitero
v. Almeria, 651 SCRA 544). Without a doubt, the registered owner
of real property is entitled to its possession. (Carbonilla v. Abiera,
625 SCRA 461);

4.13 In this case as correctly pointed out by the Trial Court that the
evidence presented by Plaintiff-Appellee established with certainty
her ownership over the subject property by virtue of a Deed of
Absolute Sale executed between her and defendant-appellee San
Francisco Del Monte10. An executed contract carries with it the
presumption of validity (Delfin v. Billiones, Gr. No. 146550, March
17, 2016) and in this case, the Deed of Absolute Sale was uncontested.
The identity of the parcel of land subject of the case was likewise
uncontested;

4.14Further, as correctly pointed out by the Trial Court, it appears

that Plaintiff is an innocent purchaser for value who relied on the title
of the San Francisco Del Monte, Inc. the rule is settled that every
person dealing with the registered land may safely rely on the
correctness of the certificate of title issued therefore and the law will
in no way oblige him to go behind the certificate to determine the
condition of the property. (Nazareno vs. Court of Appeals, Gr. No.
138842, October 18, 2000.)

4.15 Hence, being the registered owner of the subject property that is
being unlawfully occupied by herein Defendants-Appellants, the
Plaintiff-Appellee should have possession of her property. The
Supreme Court in one case, had the occasion to rule that Registered
owners are entitled to the possession of the property covered by the
title from the time such title was issued in their favor 11. Settled is the
rule that the right of possession is a necessary incident of
ownership12;

10 Copy of the said Deed of Sale is herein attached as ANNEX 5.

11 Beltran vs. Nieves, 634 SCRA 242

Page 11 of 15
 4.16 Again it is undisputed in this case that the Plaintiff-Appellee is
the lawful and registered owner of the subject property that is covered
by Transfer Certificate of Title No. 004-2010009085 of the Registry
of Deeds of Quezon City. Suffice it to state that the Plaintiff-Appellee
is also the one paying the realty taxes of the subject property 13 and it
is well settled in this jurisdiction that although tax declarations or
realty tax payments of property are not conclusive evidence of
ownership, nevertheless, they are good indicia of possession in the
concept of owner for no one in his right mind would be paying taxes
for a property that is not in his actual or at least constructive
possession.14;

4.17The Plaintiff-Appellant likewise disagree to the contention of the

Defendant-Appellants that plaintiff-appellee is not a buyer in good
faith considering that there is a notice of Lis Pendens with regard to
the HLURB Case No. 081810-14334 filed by Jabao against SFDM
when the latter failed to fulfill its obligation to her, which notice was
inscribed on 22 September 2010. However, a close perusal of the said
documents reveals that the Deed of Absolute executed by the
Plaintiff-Appellee and the defendant San Francisco Del Monte Inc.
was executed on 11 October 2010 or merely 19 days from the
inscription of the said notice;

4.18 In view of the foregoing, the Plaintiff-Appellee, being the

registered owner of the subject property and the one paying the realty
estate taxes, should have the right to recover possession of the subject
property from Defendant-Appellant who have been enjoying the
property of the Plaintiff-Appellee for so long a time;

4.19 ALL TOLD, the Defendants-Appellants has not presented any

evidence to merit reversal of the decision of the Regional Trial Court
of Quezon City and in fact the issues raised in the appeal were matters
properly addressed by the Regional Trial Court, thus, Denial of this
Appeal is just proper.

RELIEF

WHEREFORE, premises considered, it is most

respectfully prayed of this Honorable Court that the Decision of the
Regional Trial Court Branch 91, Quezon City, in Civil Case No. Q-12-
12 Monasterio-Pe vs. Tong 646 SCRA 161

13 Copy of the said Tax Official Receipts is herein attached as ANNEX 10.

14 Ramos-Balalio vs. Ramos 479 SCRA 533

Page 12 of 15
71901 be UPHELD.

Plaintiff-Appellee prays that this Honorable Court order the

Court a quo for execution of the abovementioned decision and for
other relief just and equitable in the foregoing premises.

RESPECTFULLY SUBMITTED.
25 January 2017, Quezon City for Manila.

ALFEROS ARMAS & ASSOCIATES

Law Office
Unit K, No. 1143 San Francisco Del Monte Ave.,
Barangay Paltok 1105, Quezon City
By:

JOHN THOMAS S. ALFEROS III

PTR No. 3846308; 01.07.17 Q.C.
IBP No. 137009; 01.09.17; Q.C.
Roll No. 48188; Page No. 138; Book no. XX
MCLE Compliance No. V-0019255; 04.15.16 until 04.14.19
Mobile No. 0918-9390566
jtsalferosiiilaw@yahoo.com

Copy Furnished:

AGUSTIN TOMAS C. TRIA TIRONA

Counsel for Defendant-Appellants
PUBLIC ATTORNEYS OFFICE
Special and Appealed Cases Service
DOJ Agencies Building
NIARoad corner East Avenue
1104 Diliman, Quezon City

EXPLANATION
(Pursuant to Rule 13 Section 11 of the 1997 Rules of Civil Procedure)

Copy of the foregoing Appellees Brief was served upon

defendant-appellants counsel via registered mail due to time
constraints, distance and lack of personnel of the undersigned
counsel to effect personal service for which the kind understanding of
this Honorable Court is pleaded.

Page 13 of 15
 JOHN THOMAS S. ALFEROS, III

REPUBLIC OF THE PHILIPPINES}

QUEZON CITY }s.s.

AFFIDAVIT OF SERVICE
I, IAN C. DUERO, of legal age, Filipino and with postal address at Unit
K, 1143 San Francisco Del Monte Avenue, Barangay Paltok 1105, Quezon City,
after having been sworn to in accordance with law, do hereby depose and state
that:

I am the personnel of Alferos Armas and Associate Law Office and I have
today furnished a copy through registered mail with return card of the Appellees
Brief in the case entitled ROSALINA I. CHUA vs. MRS. LOLITA G. JABAO,
et. al., docketed as CA G.R. No. CV- 106967 pending before the Court of
Appeals to:

AGUSTIN TOMAS C. TRIA TIRONA

Counsel for Defendant-Appellants
PUBLIC ATTORNEYS OFFICE
Special and Appealed Cases Service
DOJ Agencies Building
NIARoad corner East Avenue
1104 Diliman, Quezon City

I am executing this Affidavit of Service to attest to the truth of the

foregoing facts and for any legal purposes it may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 26 TH day of

January 2017 at Quezon City.

Ian C. Duero
Affiant

SUBSCRIBED AND SWORN to before me this 26TH day of January

2017 in Quezon City, Affiant exhibiting to me his Company I.D. bearing no.
13122990.

Doc. No. ______;

Page 14 of 15
Page No. ______;
Book No. ______;
Series 2017.

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