Republic of the Philippines

MUNICIPAL TRIAL COURT

Second Judicial Region
Lubuagan, Kalinga

JANE DOE, CIVIL ACTION NO. 112233

Plaintiff,
FOR

-versus- RECOVERY OF POSSESSION / ACCION

PUBLICIANA

JOHN DOE and all

persons claiming rights
under him,
Defendant.
x--------------------------x

FORMAL OFFER OF EXHIBITS

PLAINTIFF, through the undersigned counsel and to

his Honorable Court most respectfully offers in
evidence the following exhibits, to wit:

1.Exhibit A and A-1 – Certificate of Indigence issued

by the Barangay Chairman of Poblacion, Lubuagan and
MSWD of Lubuagan.

2.Exhibit B and B-1 – Tax Declarations nos. 1711 and

1619 issued under the name of Alilong Ngayaan.

3.Exhibit C and series – official receipts of real

estate tax payments.

4.Exhibit D – Tax Declaration under the name of

Ahleine Padilla.
 Exhibits A to D are being offered to prove that
the Plaintiff and her family since time immemorial
have been in possession of the land in dispute as
they have performed acts of dominion over the same.

5.Exhibits E and series – Decisions and Orders of the

MTC Lubuagan, Kalinga over criminal case no. 520.
These are being offered to prove that the defendant
indeed does not have any legal right to possess the
property.

6.Exhibits F and series – Photos of illegal

improvements by the defendant. These are being
offered to prove the illegal improvement by the
defendant.

7.Exhibits G and series – Certificate to File Action,

Minutes of the Barangay Meetings, Certification
from the Barangay of Dangoy, Lubuagan, Kalinga.
These are being offered to prove that plaintiff had
complied with the condition precedent for filing
her claims before the court.

8.Exhibit H is remarked as Sketch Map Survey by the

Municipal Assessor of Lubuagan, Kalinga.

9.Exhibit I – Sketch Map Survey of the PENRO,

Kalinga.

Exhibits H and I are being offered to prove

that defendant does not have any tax declarations
over the property disputed or anywhere near the
 area so that defendant only recently illegally
intruded the land in dispute.

10. Exhibit J and series – Judicial Affidavit of

Cathy Bongabong and her Affidavit as attached to
the Judicial Affidavit.

11. Exhibit K and series – Judicial Affidavit of

Ahleine Padilla and her Affidavit as attached to
the Judicial Affidavit.

12. Exhibit L – Affidavit of Ereneo Alicog.

13. Exhibit M – Affidavit of Saat Oggas.

14. Exhibit N – Affidavit of Panyao Lomas-i.

Exhibits J to N are being offered to prove the

allegations of possession on the complaint and the
ownership of the plaintiff of the property disputed. To
prove that all adjacent owners acknowledge the
possession and ownership of the Alilong family and that
of the plaintiff’s and also to prove that defendant is
a mere squatter or intruder in the area where the land
disputed is situated.

All foregoing exhibits are also offered in evidence

to form part of the testimony of the petitioner and her
witnesses who have identified the same and to prove all
other relevant matters.
 WHEREFORE, premises considered, it is most
respectfully prayed of this Honorable Court to admit
all the foregoing exhibits for the purposes for which
they are being offered and to form part of the
testimony of the herein Plaintiff.

With the admission of all the foregoing exhibits,

the Plaintiff rests her case.

Respectfully submitted.

June 14, 2019. Here at Lubuagan, Kalinga Province.

Public Attorney’s Office

Lubuagan, Kalinga

Roksan Dakila
Counsel for Plaintiff
Roll No. _______________
IBP No. _________________
MCLE Compliance No. VI-0001232

The Clerk of Court

MTC Lubuagan, Kalinga

Please submit the foregoing formal offer of

exhibits for the kind consideration and approval of
this Honorable Court immediately upon receipt hereof.

Roksan Dakila

Copy Furnished: