REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 100, QUEZON CITY

IN RE:
CANCELLATION OF LEGAL ENCUMBRANCE
UNDER SEC.7, R.A. NO. 26 ON TCT NO. N-41674
OF THE REGISTRY OF DEEDS OF QUEZON CITY

LRC No. 123780

SPS. JUAN MIGUEL SANCHEZ and

MARIA SANCHEZ,
Petitioners.
x---------------------------------------------------------x

FORMAL OFFER
OF DOCUMENTARY EVIDENCE

Petitioners, by counsel, unto the Honorable Court, most respectfully offers

for admission the following documentary exhibits which were identified by
Petitioner Juan Miguel Sanchez and who testified thereon, as part of his testimony,
and for the following specific purpose and other related matters:

EXHIBIT NATURE PURPOSE

“A” Petition for Cancellation To prove existence of the
of Encumbrance Petition

“B” Order of Hearing dated To prove compliance

9 December 2015 with jurisdictional
requirements of notice
and posting
“B-1” Proof of mailing of copy
of above Order to the
Office of the Solicitor
General

“B-2” Proof of mailing of copy

of above Order to the
Department of
Environment and
Natural Resources

“B-3” Proof of mailing of copy

of above Order to the
Office of the City
Prosecutor

“B-4” Proof of mailing of copy

of above Order to the
Register of Deeds of
Quezon City

“B-5” Proof of mailing of copy

of above Order to the
 Office of the City
Attorney

Proof of mailing of copy

“B-6” of above Order to the
Land Registration
Authority

Certificate of Posting
“C” dated 14 January 2016

“D” Copy of Deed of To prove that Petitioners

Absolute Sale between legally acquired
Spouses Juan Miguel ownership of Lot No. 7-
Sanchez and Maria H covered by Transfer
Sanchez and Philippine Certificate of Title No.
National Bank dated 3 N- 41674 and the
March 2008 townhouse built thereon

Signature of Juan
“D-1” Miguel Sanchez as
vendee

“D-2” Signature of Maria

Sanchez as vendee

“E” Copy of Transfer To prove that Petitioners

Certificate of Title No. are the registered
N-41674 owners of Lot 7-H
covered by TCT No. N-
41674
“E-1” Stamped annotation To prove the existence of
pursuant to Section 7 of an encumbrance
RA 26 found at the back pursuant to Section 7,
portion of TCT No. N- RA 26 on TCT No. N-
41674 41674

“F” Original Certification To prove that the

dated 20 October 2015 Register of Deeds of
issued by Ms. Rosanna Quezon City has issued a
Reyes, Records Officer, certification that the
of the Register of Deeds two-year lien provided
of Quezon City under Section 7 of RA26
annotated at the back of
TCT No. N-41674 has
already expired on 20
November 1992 without
anybody laying claim or
interest thereon

To prove that no person

has registered any claim
on the property subject
of this case

“G” Certified Copy of Tax To prove that Petitioners

Declaration No. E- are the declared owners
125679 of Lot 7-H covered by
TCT No. N-41674
 “H” Certified Copy of Tax To prove that Petitioners
Declaration No. D-- are the declared owners
15748 of the townhouse built
on Lot 7-H covered by
TCT No. N-41674

“I” Tax Clearance Certificate To prove that Petitioners

issued by the City have paid taxes for the
Treasurer of Quezon City lot for the current year.

Notation in above Tax

Clearance that previous
“I-1” payments are verified To prove that Petitioners
using computer records have been paying taxes
for the lot for the
previous years.
“J” Tax Clearance Certificate To prove that Petitioners
issued by the City have paid taxes for the
Treasurer of Quezon City townhouse on the
subject lot for the
Notation in above Tax current year.
Clearance that previous
“J-1” payments are verified To prove that Petitioners
using computer records have been paying taxes
for the townhouse on the
subject lot for the
previous years.
“K” Judicial Affidavit of To prove that he is one
Juan Miguel Sanchez of the Petitioners in this
dated 1 May 2016 case and he owns the
parcel of land covered by
TCT No. N-41674
“K-1” Signature of Juan
Miguel Sanchez To prove that TCT No.
N- 41674 has an
encumbrance relating to
Section 7 RA26
annotated on the back
portion thereof

To prove that he has

secured a Certification
from the Registry of
Deeds of Quezon City
that above encumbrance
on TCT No. N- 41674 has
already expired on 11
November 1992

To prove that no person

has made any claim on
the property

To prove that, as owner

of the property, he has
been paying taxes for the
same
The foregoing exhibits were marked during the initial hearing or trial. Their
original or certified true copies already form part of the record of this case and have
already been submitted to the Honorable Court.
 Comparison with the original documents was done during trial wherein
witness who testified thereon was presented and duly identified and affirmed the
same.

PRAYER

WHEREFORE, it is respectfully prayed that the foregoing exhibits be

admitted for the purposes for which they are respectively offered in evidence.

Other reliefs which are just and equitable are likewise prayed for.

15 April 2016, Quezon City.

BERNADETTE STA. MARIA

Counsel for Petitioners
Roll No. ____
Lifetime IBP No. ____; Quezon City
PTR No. _____ ; Quezon City
MCLE Compliance No. _______; 2/20/2013; Pasig City
Tel. No. _____

EXPLANATION
The foregoing Formal Offer is being served through licensed courier due to
lack of personnel to effect personal service.

BERNADETTE STA. MARIA

Copy furnished:

Office of the Solicitor General

134 Amorsolo St., Legaspi Village, Makati City

The Register of Deeds for Quezon City

East Avenue, Diliman, Quezon City

Land Registration Authority

East Avenue, Diliman, Quezon City

City Prosecutor’s Office

Quezon City Hall, Quezon City

City Attorney’s Office

Quezon City Hall, Quezon City

Dept. of Environment & Natural Resources

Visayas Avenue, Quezon City