REPUBLIC OF THE PHILIPPINES

OFFICE OF THE PROVINCIAL SHERIFF

Province of Batangas
Hall of Justice
Pallocan West, Batangas City

SPS. LUCILO R. MANALO AND

GUADALUPE R. MANALO,
Applicants-Mortgagees,

- versus - Case No. ___________

SPS. GAVINO C. CORONA AND

VICTORIA V. CORONA,
Mortgagors.
x---------------------------------------------x

APPLICATION FOR EXTRA-JUDICIAL

FORECLOSURE OF MORTGAGE

APPLICANTS-MORTGAGEES, by counsel and to this Honorable Office, most

respectfully allege:

1. Applicants-Mortgagees SPOUSES LUCILO R. MANALO AND

GUADALUPE R. MANALO, are of legal age, with residence at 111
Ylagan St., Aplaya, Bauan, Batangas. While mortgagors SPOUSES
GAVINO C. CORONA AND VICTORIA V. CORONA, have their
residence address at Manghinao Proper, Bauan, Batangas.

2. On September 30, 2003, mortgagors and mortgagees executed a deed of

mortgage of a parcel of land, to secure payment of the loan of THREE
HUNDRED THOUSAND PESOS (P300,000.00), Philippine Currency,
extended by the mortgagees to the mortgagors, payable on or before May
8, 2004, with 12% interest thereon per annum. A copy of the
SANGLAAN NG ISANG LAGAY NA LUPA dated September 30,
2003 is attached herewith and made an integral part hereof as Annex “A”.

3. On September 17, 2004 the said deed of mortgage was inscribed and
annotated on Transfer Certificate of Title No. T-108120 covering the
mortgaged parcel of land and issued by the Registry of Deeds for the
 Province of Batangas under the name and favor of herein mortgagees.
Said mortgaged parcel of land is more particularly described as follows:

Transfer Certificate of Title No. T-108120

“A parcel of land (Lot 6121-C-1-B, of the

subdivision plan, Psd-01-127211, being a portion of Lot
6121-C-1, Psd-04-089048, L.R.C. Record No. ), situated
in the Barangay of Manghinao, Municipality of Bauan,
Province of Batangas. Bounded on the SW., along line 1-2
by Lot 6121-C-4, (Alley 3.00 m. wide); on the NW., along
line 2-3 by Lot 6121-C-2, both of Psd-04-089048; on the
NE., along line 3-4 by Lot 6130, Cad-584, Bauan Cadastre;
on the SE., along line 4-5 by Lot 6121-D, Psd-041006-
073644; on the SW. & SE., along lines 5-6-1, of the
subdivision plan. Beginning at a point marked “1” on
bearing N. 79 deg. 39’ W., 1270.82 m. from BLLM No. 1,
Cad-584, Bauan Cadastre, ----

thence N. 3 deg. 26’W., 2.50 m. to point 2;

thence N. 80 deg. 53’E., 35.49 m. to point 3;
thence S. 08 deg. 25’E., 12.90 m. to point 4;
thence S. 80 deg. 53’ W., 25.96 m. to point 5;
thence N. 04 deg. 17’W., 10.45 m. to point 6;
thence S. 80 deg. 53’W., 11.49 m. to the point

of beginning, containing an area of THREE HUNDRED

FORTY FIVE (345) Square Meters. All points referred to
are indicated on the plan and are marked on the ground by
P.S. cycl. Conc. mons. 15 x 60 cm.; corners 2, 3, 4 by Old
PS., bearings grid; date of original survey, March 2-Oct. 11,
1978, and that of the subdivision survey, Nov. 20, 1999,
and was approved on May 4, 2000.”

4. The loan became due and payable on May 8, 2004, and notwithstanding
demands the mortgagors failed and refused to pay the same, such that the
mortgagor’s obligations as of the present amount to:

Principal P300,000.00
12% Interest (May 8, 2004 to present) 150,000.00
TOTAL P450,000.00

Exclusive of expenses relative to this extra-judicial foreclosure, sheriff’s

fees, transfer and registration expenses, and other costs, for which
mortgagors should likewise be assessed and held liable to pay. A copy of
the demand letter dated June 10, 2008 and the Registry Return Card
 are attached herewith and made integral parts hereof as Annexes “B” and
“B-1”.

5. The attached deed of mortgage provides that in case of default, the

mortgaged property may be foreclosed extra-judicially, to wit:

“Kung sakaling hindi naming mabayaran ang pagkakautang

na ito, pati na ang interes sa loob ng WALONG BUWAN
simula sa paglagda ng kasulatang ito, hinahayaan naming
gumawa ng angkop na hakbang ang mag-asawang Lucilo at
Guadalupe R. Manalo upang masingil nila sa amin ang
utang na ito kasama na ang pagpapailit ng lupa na
nabanggit. Dahil dito, aming itinatayong kinatawan
(attorney-in-fact) and mag-asawang Lucilo at Guadalupe R.
Manalo sa pagpapailit ng lupa sa labas ng hukuman, at
amin silang binibigyan ng kapangyarihang mamosecion
ditto at magpasubasta (sell on public auction in foreclosure)
sa publiko ng lupa matapos na manotipikahan sa loob ng 20
araw ang mga dapat manotipikahan at ang pasubasta’y
pangangasiwa ng Provincial Sheriff ng Batangas;”

PRAYER

WHEREFORE, it is respectfully prayed that the Provincial Sheriff of the Province

of Batangas foreclose and sell the said mortgaged property in accordance with law and in
compliance with its requirements.

Other reliefs just and equitable under the premises are likewise prayed for.

Batangas City. July 18, 2008.

JAERO P. GARCIA
Counsel for Applicants
Room 3 Golden Luck Bldg.
Apacible St., Batangas City
PTR No. 0989701; 01.08.08; Makati
IBP No. 729900; 12.28.07; Batangas
Roll of Attorney’s No. 46776
MCLE Compliance No. II-0010272
 VERIFICATION/CERTIFICATION

REPUBLIC OF THE PHILIPPINES )

BAUAN, BATANGAS ) SS.

WE, SPOUSES LUCILO R. MANALO AND GUADALUPE R. MANALO,

after having been duly sworn to in accordance with law, do hereby depose and state that:

1. We are the Applicants-Mortgagors in the above-entitled application; we caused

the preparation thereof and we have read the contents and the same are true and correct of
our own personal knowledge;

2. We have not commenced any other action or proceeding involving the same
issues in Supreme Court, the Court of Appeals or any other tribunal or agency. To the
best of our knowledge, no such action or proceeding has been filed or is pending before
the Supreme Court, the Court of Appeals or any other tribunal or agency. If we should
hereafter learn that a similar action or proceeding has been filed or is pending, we hereby
undertake to report that fact within five (5) days therefrom to the court or agency wherein
the original pleading and sworn certification contemplated therein has been filed.

LUCILO R. MANALO GUADALUPE R. MANALO

Affiant Affiant

SUBSCRIBED AND SWORN TO before me this _____ day of July 2008 affiants
exhibiting to me their ___________________________ issued on _____________ at
_______________________ and _________________________ issued on
______________________ at ___________________________.

Doc. No. ____;

Page No. ____;
Book No. ____;
Series of 2008.