Republic of the Philippines

REGIONAL TRIAL COURT

Third Judicial Region
Branch 13
City of Malolos
ALEXIS JEROME S. PANGANIBAN
and FLORA S. PANGANIBAN
Plaintiffs,
-versus2015

CIVIL CASE No. 462-MFor: Quieting of Title,

Recovery of Ownership
and Possession, and
Damages

PERLA MUTUC and all persons

Residing, renting, and deriving
Rights under her
Defendants.
x-------------------------------------------------x

FORMAL OFFER OF EXHIBITS

NOW COMES PLAINTIFFS, through counsel, unto this Honorable
Court most respectfully submits his Formal Offer of Exhibits in the
above-entitled case, stated as follows:

EXHIBIT
A
PURPOSE
:
Alexis

DOCUMENT
Deed of Conditional Sale
To prove sale between GSIS and plaintiff,
Jerome Panganiban.

Notice if Approval by GSIS

PURPOSE
:
To prove approval from the Housing
Department of GSIS dated November 22, 2010 with
Control No. 102010-114

Record on Housing Loan

PURPOSE
:
To prove the record on Housing Loan
issued by GSIS on June 17, 2015 under its Housing
Account Reconciliation Department

TCT No. T-80.570

PURPOSE
:
To prove that GSIS is the registered
owner of the subject property.

Deed of Conditional Sale

PURPOSE
:
To prove the sale on installment basis
between William Jose and Phil-Ville Development and
Housing Corporation dated July 14, 1984.

Deed of Absolute Sale

PURPOSE
:
To prove the sale of the same property
including its improvements between Spouses William
and Lita Jose and Spouses Generoso and Ma. Teresa
Cereno dated December 18, 1984 consisting of two
pages

Special Power of Attorney

PURPOSE
:
To show power of attorney executed by
Generoso Cereno in favor of Perla Mutuc dated
December 27, 1884 consisting of 1 page

Deed of Absolute Sale

PURPOSE
:
To
prove
sale
between
Spouses
Generoso and Ma. Tersa Cereno and Perla Mutuc dated
December 27,1984 consisting of 1 page

Memorandum of Agreement

PURPOSE
:
To prove undertaking between Spouses
Generoso and Ma. Tersa Cereno and Perla Mutuc dated
December 27,1984 consisting of 1 page that defendant
Mutuc shall assumed obligations to GSIS

J
2002

Notice from GSIS dated October 9,

PURPOSE
:
amortization

K
2005

Notice from GSIS dated January 10,

PURPOSE
:
amortization

L
Sale

To prove failure of William Jose to pay

To prove failure of William Jose to pay

Cancellation of Deed of Conditional

PURPOSE
:
To prove that since there is no response
from William Jose, GSIS was constrained to cancel the
deed of conditional sale and foreclosed the property on
March 16, 2005

M
9,2011
M-1

Demand Letter served on June

Certification of Delivery

PURPOSE
:
To prove the demand to Perla to vacate
property and the corresponding certification of delivery
by Meycauayan Post Office

N
2011

Certification to file action June 2,

PURPOSE
:
To prove that Plaintiff, Flora Panganiban
has earnestly tried to settle amicably through the
barangay

Civil Case No. 495-M-2011

PURPOSE
:
To prove that amidst the effort of
Plaintiff, Flora Panganiban, to settle the issue to vacate
the property outside the court, defendant Perla Mutuc,
instead file a civil case against her and GSIS, et al.

P
2014

Court Order dated November 4,

PURPOSE

To show proof that Civil Case No.

495-M-2011 has been dismissed accordingly.

R

Entry of Judgment

PURPOSE

To show proof the finality of Court

Order dated November 4, 2014 as issued by

Supreme Court dated April, 2015
S
9,2015

Certificate to file action dated July

PURPOSE
:
To prove that once again, Plaintiff, Flora
Panganiban has earnestly tried to settle amicably
through the barangay for defendant, Perla Mutuc and
all those deriving rights under her to vacate the
property

Special Power of Attorney for Flora

Panganiban

PURPOSE
:
To prove legal authority of Flora
Panganiban to represent Alexis Jerome Panganiban

Engagement Contract

PURPOSE
:
To prove that towards all efforts of the
plaintiff to settle the issue outside of the court, she had
been left with no other choice but to secure the
services of the undersigned counsel to enforce their
right on the property that they bought from GSIS

Notice of Hearing to declare defendant

in Default

PURPOSE
:
defendant

To prove the lack of interest of the

PRAYER
WHEREFORE, it is most respectfully prayed to this Honorable
Court that the foregoing attached marked documentary exhibits
10, including Exhibit 1, 2,3,4 to 4-F-a, 5, 7, 8,
9, 11 12 13 14 and 15 attached in the records of this
Court be admitted, including the purposes for which they are
being offered.
Upon admission of the foregoing documentary
testamentary exhibits, the accused rests his case.
RESPECTFULLY SUBMITTED.
Marilao for City of Malolos, Bulacan, May ____, 2016.

and

NENITA D.C. TUAZON

TUAZON LAW
Counsel for the Defendants
Unit J, 2nd floor, FNR Bldg, MacArthur Hway, Abangan Norte, Marilao, Bul.

Landline (044) 7111709/mobile 0998-5602610/0922-8431235

Email address: tuazonlawoffice@yahoo.com
Roll of Attorney No. 47194
IBP LIFE NO. 591042 5/19/2003
PTR NO. 0604821, 1/4/16 Marilao, Bulacan
MCLE Exemption No. V-001622, Valid until April 14, 2019

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