Republic of the Philippines

REGIONAL TRIAL COURT

6th Judicial Region
Branch ____
____
IN THE MATTER OF THE Spl. Civil Case No. _____
SURRENDER OF TRANSFER
CERTIFICATE OF TITLE No.
_____ BY _______,

_______,
Petitioner.
x--------------------x

ADDENDUM
(To REJOINDER with MOTION TO DISMISS)
COME NOW, oppositor through the undersigned counsel unto
this Honorable Court, respectfully submits this addendum to his ____
on the following grounds:
1. That scrutiny of the Special Power of Attorney dated ____
it failed to mention that petitioner is duly authorized to file
2. Section 5 (d) of R.A. 8369 (An Act Establishing Family
Courts) stated that:
Sec. 5. Jurisdiction of Family Courts. - The
Family Courts shall have exclusive original
jurisdiction to hear and decide the following cases: 
a) xxx
b) xxx
c) xxx
d) Complaints for annulment of marriage,
declaration of nullity of marriage and those
relating to marital status and property
relations of husband and wife or those
living together under different status and
agreements, and petitions for dissolution of
conjugal partnership of gains;  [Emphasis
supplied]
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed
that the rejoinder be noted accordingly and dismiss the case for lack of
jurisdiction.
Other legal and equitable reliefs are also prayed for.
______.

Oppositor
 NOTICE
GREETINGS!
Please take notice that the foregoing rejoinder and motion shall
be submitted immediately upon receipt hereof and be heard on _____ in
the morning or as soon as counsel and matter may be heard.

Oppositor