Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
City of Paraaque
Branch 258
IN THE MATTER OF APPLICATION FOR
REGISTRATION OF TITLE TO LAND
-

LRC CASE NO. 16-0001

JANE DOE,
Applicant.
x----------------------------------------x

JUDICIAL AFFIDAVIT
I, JANE DOE, of legal age, Filipino citizen, single and resident of Lot
4166, Barangay of San Dionisio, City of Paranaque, the applicant in the
instant case states under oath as follows:
PRELIMINARY STATEMENT
The person examining me is Atty. Mary Alelie D. Batino with law
office address at No. 1234, St. Peter St., Moonwalk, Paranaque City. The
examination is being held at the same address. I am answering her
questions fully conscious that I do so under oath and may face criminal
liability for false testimony and perjury.
PURPOSE OF THE TESTIMONY
The testimony of the witness Jane Doe is being offered to prove the:
1.

The identity of the real property subject matter of this case;

2.

The questioned land title in the name of the applicant covering the
subject property;

3.

The legal history of the antecedent and the current/questioned

land titles;

4.

The identities of the predecesors-in-interest/decedents of the said

legal heirs/applicant;

5.

The legal bases for the claim/prayers of the plaintiffs.

Q Please state your name, age, residence, and occupation of the

witness.
A Jane Doe, 51 years old, married, Lot 4166, Barangay of San
Dionisio, City of Paranaque and a Housewife.
Q- Why are you here now?
A To give a sworn statement by way of a judicial affidavit, the same
to constitute as my direct testimony, in the above-captioned
civil case.
Q- For the record, please state the name and address of the lawyer
who is now conducting or supervising your examination and the
place where the examination is being held now?
A The legal counsel for the applicant, Atty. Mary Alelie D. Batino is
conducting or supervising my examination now at her law office
(Batino Law Offices) located at:
No. 1234, St. Peter St., Moonwalk, Paranaque City
Q In what language do you want your examination to be conducted?
A This judicial affidavit is prepared in English. But I prefer
that my cross examination be conducted in Tagalog for my
convenience and for clarity.
Q Do you undertake to answer the questions to be asked of you,
fully conscious that you will do so under oath, and that you may face
criminal liability for false testimony or perjury?
A -Yes.

Q - Why are your testifying in this case?

A
Doe.

I am testifying in this case as an heir of the deceased, Maria

QAre you familiar with the real property subject matter of this
case?
A Yes. I live in Lot 4166, Barangay of San Dionisio, City of
Paranaque where the subject pr0perty is also located.
Q - Can you describe the subject property?
A - Yes. The subject property is a parcel of land (as shown on plan,
Ap-00-0000433, being an Advance Plan of Lot 4166, Cad. 299,
Paranaque Cadastre, L.R.C. Record No. ___), situated in the
Barangay of San Dionisio, City of Paranaque, Province of Metro
Manila. It is covered by Tax Declaration No. 1234 in the name of
Jane Doe. It has an area of Seven Thousand Four Hundred Thirteen
(7,413) SQUARE METERS, more or less.
Q Are you familiar with the history of the land title of the subject
pr0pety registered in the name of Maria Doe?
A
Yes. I have researched and investigated the history of the
subject property before we filed this case.

Q Who is the deceased Maria Doe?

A - The deceased, Maria Doe, is my mother.
Q

What is the relation of Maria Doe to the subject property?

A-

She was the original owner in fee simple of the Subject Land

Q When did Maria Doe die?

A She died on 1970.

Q Who is the heir of Maria Doe?

I am.

Q -

Why are you running for the subject property?

A
I am running for the subject property because my mother,
Maria Doe was the owner in the fee simple of the Subject Land by
open, continuous, exclusive and notorious occupation, by herself and
her predecessor-in-interest Juana Doe, who is her mother, since time
immemorial, or at least, before 12 June 1945. To the best of
Applicants knowledge and belief, there is no mortgage or
encumbrance of any kind whatsoever affecting the Subject Land, nor
any other person, having any interest therein, legal or equitable, nor
in possession thereof. The Subject Land does not border on a public
way or road. The Subject Land has been certified as alienable and
disposable land by the Department of Environment and Natural
Resources (DENR).

Q What reliefs do you seek from the Court?

A I seek that the Subject Land be brought under the operation of
Presidential Decree No. 1529 and that title under my name be
registered and confirmed.

Q What documents do you wish to submit to the Court?

A
a. Original Approved
Description;

Survey

Plan

Ap-00-008433,

Technical

b. Muniments of title in the possession of the Applicant which prove

its right and title over the Subject Land, as follows:
1. Deed of Absolute Sale;

2. Verification/Certification;
3. Secretary Certificate; and

4. Certification issued by the DENR certifying that the land is

within the alienable and disposable area of the public
domain;
which will be marked during the course of the trial.
Nothing Follows.
Paranaque City, September 14, 2016.
JANE DOE
Applicant
SUBSCRIBED and sworn to before me in Paranaque City on
September 14, 2016, affiant showing his/her competent proof of identity,
Philippine Passport with I.D. No. 123456.

Notary Public
Doc. No. __
Page No. __
Book No. __
Series of 2016.

The undersigned Atty. Mary Alelie D. Batino of legal age, single,

and with law office address at No. 1234, St. Peter St., Moonwalk, Paranaque
City, under oath, deposes and states:
1.

She is the Legal Counsel for the plaintiffs in the above-entitled case;

2. He faithfully recorded or caused to be recorded the questions he

asked and the corresponding answers that the above-named witness
gave;
3. Neither he nor any other person then present or assisting him coached
the witness regarding the latter's answers; and
4. He conducted the examination of the witness at his law office located
at No. 1234, St. Peter St., Moonwalk, Paranaque City.

Paranaque City, September 14, 2016.

Atty. Mary Alelie D. Batino

Affiant
SUBSCRIBED and sworn to before me in xxx City on xxx _____,
2015, affiant showing his/her competent proof of identity, to wit: SSS
Member ID No. xxx.
Notary Public
Doc. No. ___
Page No. ___
Book No. ___
Series of 2016.

EXPLANATION
A copy of this Judicial Affidavit is served on the Court, the Counsel
for the Defendant Leonora Xxx, and the Register of Deeds of Rizal Province
via LBC Express Corp./registered mail due to the great distances of their
respective addresses, due to the urgency of filing the same, and due to the
lack of field personnel of the undersigned counsel at this time.

Mary Alelie D. Batino