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Republic of the Philippines 3. 0*COLI

FILE No. :
Third judicial Region CALENDARED
REGIONAL TRIAL COURT CHECKED BY
Baler, Aurora ROUTE To
N"G-00030407
Branch 101

SPOUSES SHERWIN I. TANDAS

AND ROSEVEL Do LORES R.
OK FOR FILING
BELARMINO-TANDAS, SCN/Up to BY
PIO in tiffs,

- versus - Civil Case No. 2019-10-1595

RURAL BANK OF CASIGURAN

IAURORAj, INC.
Post Office

Le er/Package No.
111,111^minimir^nthimi^ <.

Dt;!"endont, Posted on 20
X X Pr^serv his receipt for reference in case of inquiry

Postmaster/Teller

COMMENT/OPPOSITIO
IRe: Motion to Admit Attached Second Amended Complaint
twith Prayer for Preliminary Mandatory InjunctionI
dated t6 ianuaiy 20201

Defendant RURAL BANK OF CASIGURAN IAURORAj, INC. ,

(hereinafter "Defendant Bank"j, by counsel, respectfully opposes the
Motion to Admit Attached Second Amended Complaint twith Prayer for
Preliminary Mandatory injunction) on the following -

GROUNDS

THE COMPLAINT HAS BEEN RENDERED

MooT AND ACADEMIC BY SUPERVENiNG
EVENTS.

AN AMENDMENT OF A COMPLAINT CANNOT

BE MADE WHERE THE COURT HAD NO
IURISDICTION OVER THE ORIGINAL
COMPLAINT.

PLAINTIFFS' MOTION To ADMIT SECOND

AMENDED COMPLAINT SHOULD BE DENIED
FOR BEING A MERE SCRAP OF PAPER.
 .
,

DISCUSSION

THE COMPLAINT HAS BEEN RENDERED

MooT AND ACADEMIC BY
SUPERVENING EVENTS.

I. The Complaint contains SIX (6) causes

of action against
Defendant Bank, thus:

1.1. The first cause of action in the Complaint is Payment

through Consignation. Plaintiffs claim that they offered to pay
Php1,635,430.55, denying liability for any additional interest and
penalty on their outstanding obligation. Plaintiffs allegedIy had no
other recourse but to avail of payment by consigning to this Court
the amount of Php1,146,264.33.

1.2, The second cause of action indicated in the Complaint

is for computation of the actual loan obligation. Plaintiffs claim
that they cannot be made to pay interest after 24 August 2019,
when they allegedIy tendered payment to Defendant Bank.
Plaintiffs claim that their liability only amounts to
Php1,1.46,264.33, which they allegedIy consigned and placed at
the disposal of this Court.

I. 3. Plaintiffs' third cause of action in their Complaint is

for the declaration of nullity of Promissory Note No.
001-201.8-11.26-3256 dated 26 November 201.8.

1.4. The fourth cause of action in Plaintiffs' Complaint is

for the release of their mortgage. Plaintiffs claim that "tallthough
there were real estate mortgages, they were not included nor
referred to in the promissory note. " Plaintiffs further claim that
with the consignation of their payment to this Court, the
mortgages should be cancelled and/or released.

1.5. The fifth cause of action is for Specific Performance

and for the issuance of a Writ of Preliminary Mandatory
injunction for the immediate return of their owner's duplicate of
the certificates of titles of the properties mortgaged to Defendant
Bank. Again, Plaintiffs pray for the release of the real estate
mortgages and the return of their owner's duplicate of the
certificates of titles.
 ,

1.6. Lastly, Plaintiffs pray for the award of damages, on

the ground that Defendant Bank was unjustly in possession of the
owner's duplicate titles of the properties. Plaintiffs argue that
Defendant Bank should have released the certificates of titles of
the properties as early as 24 August 2018, when Plaintiffs claim to
have tendered payment of their obligation.

2. On 23 Iuly 2020, Plaintiffs paid Defendant Bank

PHP3,445,000.00 as full settlement of their entire outstanding
obligation. A copy of the Certification dated 24 Iuly 2020 attesting to the
same is herewith attached as Annex "I. ".

3. Consequently, on 29 Iuly 2020, Defendant Bank returned to

Plaintiffs the owner's duplicate certificates of title of the properties
mortgaged. A copy of the Acknowledgement Form executed by Plaintiffs
attesting to the return of their certificates of titles is attached herewith
as Annex "2".

4. With the payment of Plaintiffs' obligation and the return of

their owner's duplicate certificates of titles, Plaintiffs'
Complaint-which is premised upon Plaintiffs' payment of their
obligation and the immediate return of their owner's duplicate
certificates of title of the properties mortgaged-has been rendered
moot and academic.

5. The Supreme Court has explained when a case has become

moot and academic, thus:

A moot and academic case is one that ceases to present a

justiciable controversy by virtue of supervening events, so that a
declaration thereon would be of no practical value. As a rule, courts
decline jurisdiction over such case, or dismiss it on ground of
mootness. Whatever judgment is reached, the same can no longer
have any practical legal effect or, in the nature of things, can no
longer be enforced. '

6. in this case, it is clear that the Complaint no longer presents

a justitiable controversy.

6.1. By paying their obligation to Defendant Bank,

Plaintiffs effectiveIy disproved their own assertions in their
Complaint. The payment of the amount of PHP3,445,000.00 is an

' NICort;/r. v. Titong, G. R. No. 207682,10 December 2014.

 ,

acknowledgement of their total obligation to Defendant Bank,

negating their claim that the amount they owed is only
PHP1. ,146,264.33, which they allegedIy consigned to this Court. in
effect, Plaintiffs admit that they were liable to pay interest and
penalties in addition to the amount of their outstanding
obligation, thereby rendering moot and academic their first and
second causes of action for payment through consignation, and
computation of their actual loan obligation, respectively.

6.2. Defendant Bank has accepted Plaintiffs' payment of

PHP3,445,000.00 as full settlement of their obligation. Thus,
Plaintiffs' third cause of action to declare Promissory Note No.
001-2018-11.26-3256 null and void is also rendered moot and
academic, since Defendant Bank, in the Certification dated 24 Iuly
2020, has attested that Plaintiffs no longer have any outstanding
obligation to it.

6.3. With the release of the mortgage and the return of the
certificates of titles to Plaintiffs, their fourth and fifth causes of
action are undoubtedly now moot and academic.

6.4. As to the claim for damages, it is evident that there is

Do basis therefor. By paying to Defendant Bank the amount of
PHP3,445,000.00, Plaintiffs admitted the true amount of their
outstanding obligation. This confirmed the right of Defendant
Bank to retain in its possession the certificates of titles of the
mortgaged properties pending full settlement of Plaintiffs'
obligation. As soon as Defendant Bank received full payment, it
immediately returned to Plaintiffs their owner's duplicate
certificates. This shows that Defendant Bank "did not
unreasonably and in bad faith" withhold the duplicate titles of the
properties, as Plaintiffs claim.

7. The Supreme Court has held that when a case has become
moot and academic, the dismissal of the case is in order-

it is a rule of universal application that courts of justice constituted

to pass upon substantial rights will not consider questions where no
actual interests are involved ; they decline jurisdiction of moot
cases. And where the issue has become moot and academic, there
is no justiciable controversy, so that a declaration thereon would be
of no practical use or value. There is no actual substantial relief
to which the petitioner would be entitled and which would be
negated by the dismissal of the petition. Thus the Court will
refrain from expressing its opinion in a case where no practical
 *

relief may be granted in view of a supervening event. ' (emphasis

supplied)

8. Clearly, the Complaint has been rendered moot and

academic by superventng events. Plaintiffs have paid their full
obligation to Defendant Bank. Defendant Bank has returned to Plaintiffs
the certificates of titles of the mortgaged properties. There is no longer
any relief of practical use or value that can be granted by this Honorable
Court. Accordingly, the Complaint must be dismissed for being moot and
academic.

9. Assuming orguendo that there remain issues ripe for

judicial determination, the Motion to Admit Second Amended Complaint
must be denied for being a mere scrap of paper, and the Complaint
dismissed for lack of jurisdiction.

AN AMENDMENT OF A COMPLAINT
CANNOT BE MADE WHERE THE COURT
HAD NO IURISDICTION OVER THE
ORIGINAL COMPLAINT.

I. 0. Prior to Plaintiffs' filing of the Motion to Admit, Defendant

Bank filed a Motion to Dismiss the Amended Complaint dated 25
October 201.9 on the ground that the Honorable Court has no
jurisdiction over the instant case. Defendant Bank argued that Plaintiffs
deliberately omitted the zonal values of the mortgaged properties
subject of the Complaint in order to lead the Office of the Clerk of Court
to rely on the fair market value of the properties, resulting in the
assessment of significantly lower filing fees. This shows that Plaintiffs
deliberately evaded payment of the correct filing fees in order to
defraud the government.

11. The merit in Defendant Bank's argument was confirmed by

Plaintiffs themselves when they filed the present Motion to Admit
Attached Second Amended Complaint which now indicates the zonal
values of the mortgaged properties.

12. In effect, Plaintiffs admit that the Honorable Court did not
acquire jurisdiction over the Complaint, and thus filed the Second
Amended Complaint in order to con/12r jurisdiction upon this Honorable
Court. This, however, cannot be done. As ruled by the Supreme Court-

' Spouses SaunterILO v. Spouses Mogsi'no, G. R. No. 193000,3.6 October 201.3.

.

"By itself, the propriety of admitting R-11 Builders' Second Amended

Complaint is also cast in dubious light when viewed through the prism
of tile general prohibition against amendments intended to
confer jurisdiction where none has been acquired yet. Although
the policy in this jurisdiction is to the effect that amendments to
pleadings are favored and liberally allowed in the interest of justice,
aimendinent is not allowed where the court has ino jurisdiction
over the original complaint and the purpose of the amendment is
to confer jurisdiction upon the court. Hence, with jurisdiction over
the case yet to properly attach, HGC correctly fault the CA for
up holding respondent RTC's admission of R-11 Builders' Second
Amended Complaint despite non-payment of the docket fees for its
original complaint and Amended and Supplemental Complaint as well
as the clear intent to evade payment thereof. " IEmphasis supplied}

13. The foregoing squarely applies to the present case. Since, as

argued by Defendant Bank in its Motion to Dismiss dated 03 December
2019, the Honorable Court does not have jurisdiction over the present
case, Plaintiffs cannot be allowed to amend their Complaint so as to
confer jurisdiction upon this Honorable Court,

PLAINTIFFS' MOTION To ADMIT

SECOND AMENDED COMPLAINT4
SHOULD BE DENIED FOR BEING A
MERE SCRAP OF PAPER.

14. On 23 Ianuary 2020, Defendant Bank, through counsel,

received via private courier a Notice of Hearing dated 20 Ianuary 2020
filed by Plaintiffs, informing Defendant Bank of a hearing scheduled on
24 Ianuary 2020 at 8:30 in the morning. The Notice of Hearing was not
attached to any Motion, but referred to a Motion to Admit Second
Amended Complaint twith Prayer for Preliminary Mandatory
Injunction),

1.5. it was only on 24 Ianuaiy 2020 that Defendant Bank

received through private courier a Motion to Admit Attached Second
Amended Complaint twith Prayer for Preliminary Mandatory
injunction) dated 1.6 Ianuary 2020 thereinafter "Motion to Admit").

1.6. On 31 ianuary 2020, Defendant Bank received a copy of the

same Notice of Hearing dated 20 Ianuary 2020 served by Plaintiffs
through registered mail. Again, the Notice was not attached to any
Motion. To date, Defendant Bank has not received a copy of the Motion
to Admit served through registered mail.

' Home Guoron^, Corp. v. R-JIBuilder^Inc. , G. R. No. 1,92649,09 March 2011.

' At the time t}Ie Motion to Admit was filed, the 1997 Rules of Civil Procedure was still in
effect,
,

I7. At the outset, it bears stressing that service through private

courier is not a mode recognized by the Rules of Court. Even assuming,
however, that the service of the Motion to Admit through private
courier could be considered as effective service to Defendant Bank, the
Motion to Admit filed by Plaintiffs is in violation of Rule 1.5, Section 4 of
the Rules of Court, which provides:

"SEC. 4. Hearing of motion. - Except for motions which the

court may act upon without prejudicing the rights of the adverse
party, ever written motion shall be set for hearin b the a Iicant

Eve written motion re uired to be heard and the notice of the

heartno thereof shall be served in such a manner as to ensure its
recei t b the other ar at least three 3 da s before the date of
11^, unless the court for good cause sets the hearing on shorter
notice. " (Underscoring suppliedI

18. The violation of the above-mentioned provision is two-fold:

first; the Motion to Admit was not set for hearing, and second, there was
non-compliance with the three-day notice rule.

19, By express provision of Section 4 of Rule 1.5, the general

rule is that every written motion must be set for hearing, with the
exception of those motions which the court may act upon without
prejudicing the rights of the adverse party, or non-litigated motions,
thus:

"Section 41ays the general rule that all written motions shall be set for
hearing by the in ovant, except the non-litigated motions or those
which may be acted upon by the court without PI'ejudicing the rights
of the adverse party. These ex porte motions include a motion for
extension of time to file pleadings, motion for extension of time to file
an answer, and a motion for extension of time to file a record on
6
appeal. "

20. A review of Plaintiffs' Motion to Admit would show that the

motion lacked the general requirement of a notice of hearing, and is not
a motion which the court may act upon without prejudicing the rights of
Defendant Bank.

21. In fact, under Rule 1.0, Section 3 of the Rules of Court,

' Philippine Notion o1Bonk v, Deang Morketing Corp. , G. R. No. L77931. , 08 December 2008;
Pomeo v. PIOnters Development Bunk G. R No. 193650,08 October 20t4.
' Spouses Rustio v. Rivern, G. R, No. 156903,24 November 2006.
 .

Plaintiffs' Motion to Admit should have been made with leave of court '
The same provision also states that any order of the court thereon must
be "after notice to the adverse party, and an opportunity to be heard"-

"Section 3. Amendments by leave of court, - Except as provided in

the next preceding section, substantial amendments may be made
only upon leave of court. But suchleave may be refused ifit appears to
the court that the motion was made with intent to deja . Orders of
the court u on the matters rovided in this section shall be made
u on motion filed in court and after notice to the adverse ar
and an o ort, InI to be heard. "~ IEmphasis supplied)

22. Plaintiffs' Motion to Admit, therefore, by express provision

of the law, was a litigated motion, and therefore should have contained a
Notice of Hearing.

23. Plaintiffs, realizing their non-compliance with the foregoing

rule, later filed a separate Notice of Hearing dated 201anuary 2020. The
belated submission of a separate Notice of Hearing, however, cannot
cure the fatal defect in their Motion to Admit, which must be treated as a
mere scrap of paper-

"As prescribed by the aforequoted provisions, a in ovant shall set his

Inotion for hearing, unless it is one of those which a court can act upon
without prejudicing the rights of the other party, The prevailing
doctrine in this jurisdiction is that a motion without a notice of
hearing addressed to the parties is a mere scrap of paper. "
(Emphasis supplied)

24. Moreover, Plaintiffs' attempt to remedy their omission by

later filing a Notice of Hearing dated 20 Ianuary 2020 was already too
late, and was in fact, in violation of the second paragraph of Sec. 4, Rule
15 of the Rules of Court, or the three~day notice rule. The provision
requires the in ovant to ensure that the motion to be heard and the notice
of the heonrig there^' are received by the other party at least three (3)
days before the date of hearing, which requirements are mandatory,
thus:

"The foregoing requirements - that the notice shall be directed to the

parties concerned, and shall state the time and place for the hearing of
tile motion - are mandatory, and if not religiously complied with,
tile motion becomes pro forma, A motion that does not comply
with the requirements of Sections 4 and 5 of Rule 1.5 of the Rules

7 Rule 10, Sec. 3 of tlie Rules of Court.

Old.
' Boutisto v. Cousopin, Ir. , A. M. No. RTj-07-2044,22 Iune 2011.
.

of Court is a worthless piece of paper which the clerk of court has

no right to receive and which the court has no authority to act
upon. The logic for such requirement is simple: a motion invariably
contains a prayer which the in ovant makes to the court which is
usually in the interest of the adverse party to oppose. The notice of
hearing to the adverse party is therefore a form of due process; it
gives the other party tile opportunity to properly vent his
opposition to the prayer of the unovant. In keeping with the
principles of due process, therefore, a motion which does not
afford the adverse party a chance to oppose should simply be
disregarded. Principles of natural justice demand that a right of a
party should not be affected without giving it an opportunity to be
heard.

"Harsh as they may seem, these rules were introduced to avoid

capricious change of mind in order to provide due process to both
parties and to ensure impartiality in the trial.

"it is important, however, to note that these doctrines refer

exclusively to a motion, since a motion invariably contains a prayer,
which the in ovant makes to the court, which is to repeat usually in the
interest of the adverse party to oppose and in the observance of due
process, the other party must be given the opportunity to oppose the
motion. in keeping with the principles of due process, therefore, a
motion which does not afford the adverse party the chance to
oppose it should simply be disregarded. Failure to comply with
the required notice and hearin is a fatal defect that is
deleterious to respondents cause. " CEmphasis supplied}

25. The Notice of Hearing was received by counsel for

Defendant Bank only a day before the hearing, while the Motion to
Admit was received by counsel already on the day of the hearing itselfj
both of which were sent via private courier. The Notice of Hearing sent
through registered mail was received by Defendant Bank's counsel only
on 31 ianuary 2020, a weel< after the scheduled hearing.

26. The Notice of Hearing dated 20 Ianuary 2020 was served

only four (4) days before the scheduled hearing. The Supreme Court
takes "judicial notice that service by registered mail in our jurisdiction
does not take place in one day. Service of notice by registered mail only
four (4) days before the date of hearing, therefore, does not amount to
ensuring
,, Tl
the other party's receipt at least three (3) days before the
hearing. "

27. Thus, the Motion to Admit should be denied outright for

being a mere scrap of paper.
10 Acornpodo v. Spouses Cosmilla, G. R. No. 198531,28 September 2015.
" Coffiny Metal Corporation v. Loguno WestMu!ti-Purpose Cooperotive, Inc. , G. R. No. 172204,
021uly 2014.
 28 in view of the foregoing, Plaintiffs' Motion to Admit should
be denied for being contrary to law and jurisprudence.

PRAYER

WHEREFORE, defendant RURAL BANK OF CASIGURAN

LAURORA), INC. respectfully prays that this Honorable Court render
judgment -

I. DISMISSING the Complaint for. being moot and academic;

OR

2. DISMISSING the instant case for lack of jurisdiction;

3. DENYING the Motion to Admit Attached Second Amended

Complaint twith Prayer for Preliminary Mandatory
Injunctionj dated 16 Ianuary 2020; and

4 ORDERING the Plaintiffs to pay Defendant Bank attorney's

fees and litigation expenses in the amount of not less than
Php500,000.00, plus costs of suit.

Defendant Bank respectfully prays for such further or other relief

as may be deemed just or equitable.

Makati City for Baler, Aurora, 29 September 2020.

NISCE MAMURIC GUINTO RIVERA &

ALCANTARA
For Dt^lendont Bank
8th Floor, 139 Corporate Center
1.39 Vatero Street, Salcedo Village
Makati City
Tel No. (02) 7751.2222
Fax No. (02) 7751.2405

By:

PE . SANTIAGO
PTR No. 8117251; 01/02/2020; Makati City
IBP No. 101704; 0T/06/2020; Calmana
MCLE Coinp. V1~0025282; 04/08/2019
Roll No. 36800
Email: peter, santiago@rimgra-law. coin
 KENNETll C. IEsus
PTR No. 8117253; 01/02/2020; Makati City
IBP No. 101706; 01/06/2020; Makati City
MCLE Coinp. No. V1-0009467; 06/20/2018
Roll No. 51003
Email: ken. dejesus@rimgra-law. coin

EMICA . MIGRINO
PTR No. Bit7 9 011 2/2020; Makati City
IBP Lifetime No. So; o5/24/2016; RSM
MCLE Coinp. V1-0008808; 05/25/2018
Roll No. 65997
Email: enka. inigrino@rimgra-law. coin

R MINA RAE R. MANALO

PTR No. 81 261; 01/02/2020; Makati City
IBP No. 1017/1; 01/06/2020; Makati City
MCLE Coinp. No. V!-00/0389; 07/10/2008
Roll No. 69384
Email: romina. manalo@rimgra-law. coin

^;

(by registered moil and private courted

AtIy. Aurea Elmora A. Casiano

RE ,,,,,,,,,,, jjjjjjjjjjjjjjj
Counsellor Plaintiffs
Brgy. Bacong, San Luis
32 0I Aurora

'oratorse 'ce rid Re ' stere

in Private Courier

Due to the distance involved and lack of available messengers, the

undersigned was constrained to file and serve this Comment/OPPo"t, bn
IRe: Motion to Admit Attoched Second Amended Complaint fryith Proyer
for Prelimino, y Mondotoiy Inj'uriction) doted 16 Januory 2020j by
registered mail and private courier.

OMINA RAE R. MANALO

 REPUBLIC OF THE PHILIPPINES) Amended Annex "A" to
MAI<ATl, METRO MANILA ) s, s. Revised Circular No. I-88
and Circular No. 19-91

AFFIDAVIT OF SERVICE
IRevised as of April 1994)
^;^ s Parolegal of NISCE MAMURIC GUINTO RIVERA &
ALCANT M LAW OFFICES with office address at 8th Floor, 139 Corporate Center, Valero
Street, Salcedo Village, Makati City, after being duly sworn, depose and say:

That on 29 September 2020, I served a copy of the following pleading/paper:

NATURE OF PLEADING

COMMENT/OPPOSITION
IRe: Motion to Admit Attached Second Amended Complaint
twith Prayer for Preliminary Mandatory Injunction
dated t6Ianuary 20201

in the Regional Trial Court, Branch 101, Baler, Aurora, entitled ':Spouses Sherwin
Tondos ond Rosevel Dolores R. Belarmino-Tondos vs Ruml Bonk of Cosiguron" Civil Case No.
2019-10-1595, Pursuant to sections 3,4,5 and 13 Rule 13 of the Rules of Court, as follows

^ling ond Service by Regi'stered Moil:

Atty. Aurea Elnora A. Casiano Reg. No. By depositing copies on 29

Counselfor Plumtjff's September 2020 at
Brgy. Bacong San Luis as

3201 Aurora evidenced by Registry

Receipt Nunibers indicated
after the names of the
addressees and with the
Instructions to the
postmaster to return the mail
to the sender after ten (10)
days if undelivered.
29 September 2020, Makati City, Philippines.

I
,;^;f;
SUBSCRIBED AND SWORN to before me this 29 September 2020, at Makati City,
Philippines, affiant is exhibiting to me his I' C> ':'^, ' '

Doc.
Doc.N0 06;
No.
Page Nor'q~';
101^
CAMILL ENNIFER . ,,, ANTOZA
Book No. ^'~; Notary ubl c fro I ,Kgt 111
Series of 2020.
APPo at merit NO M ,470i92Li20j
if Floor 139 Corporate e", Yaleio Sirea
S* 10 Village I\, dkati C tv
Ho o Attorney* 1.1ti 64 ', 9
MCLE Coinp NO V! 00,379905/25/201^
18P N0 0107090101 020, lisM
T A IviKT 811.7257 f , ? nil I. a' V
 REPUBLIC OF THE PHILIPPINES) Amended Annex "A" to
MAI<ATl, METRO MANILA ) s. s. Revised Circular No. I-88
and Circular No. 19-91

AFFIDAVIT OF SERVICE
(Revised as of April 1994j

I, ,
as Parolegal of NISCE MAMURIC GUINTO RIVERA &
ALCANTAl{A W O F1CES with office address at 8th Floor, 139 Corporate Center, Valero
Street, Salcedo Village, Makati City, after being duly sworn, depose and say

That on 29 September 2020, I served a copy of the following pleading/paper:

NATURE OF PLEADING

COMMENT/OPPOSITION
IRe: Motion to Admit Attached Second Amended Complaint
twith Prayer for Preliminary Mandatory Injunction
dated 16 ianuary 20201

in the Regional Trial Court, Branch 101, Baler, Aurora, entitled ':Spouses Sherwin
Tondos rind Rosevej Dojores R. Belormino-Tondos vs Ruml Bonk of Cosiguron" Civil Case No
2019-10-1595, Pursuant to sections 3,4,5 and 13 Rule 13 of the Rules of Court, as follows

Fillh9 rind Service by LBC:

Any. Aurea Elnora A. Casiano Tracking No By depositing copies on 29

Brgy, Bacong, San Luis September 2020 at
3201Aurora as evidenced
by Tracking Numbers and
indicated after the names of the
addressees and with the
instructions to the postmaster to
return the mail to the sender
after ten (10) daysif undelivered.

29 September 2020, Makati City, Philippines.

,Z'!! ,, ,
I^An'on"
SUBSCRIBED AND SWORN to before me this 29 September 2020, at Makati City,
Philippines, affiant is exhibiting to me his SSS ID No.

Doc. No. UV ;
Page No. IE ;
Book No. _.^._ ;
CAM!L/'I ^IFFFt I " N101A
11 C tJ
NoaryP bic ron v,
Series of 2020. ,9. ''''1
Appo ntme t N0 I\4.2
';" Floor 1.3 C roof, !te Co I Vale o C ;, ,**. I

Salce 0\ 1:14ge. M kal City

1:0 of Alt rneY 1.1t 47. ,o
MCLE Coinp NO V10003799,05/25/ J 11, ;
18P N0 01 7 9 o1.1)e^/*o20 I M
I IviKT 117 I
,

$6 $9
'^! *"\* I*,* ,,^
~.- . --. .

Republic of the Philippines

Third Judicial Region
REGIONAL TRIAL COURT
Baler, Aurora
OFFICE OF THE Ex. OFFlcio SHERIFF
--o0000-"

^::I=, I^, 11 IEI^ A TIQ. N.

THIS Is To CERTIFY that on July 23,2020, S . SHERW

and ROSEVEL B. TANDAS paid the total amount f THRE
HUNDRED FORTY FIVE THOUSAND (P3,445,000.00) PESOS P , ,
in LBP Manager's Check No. 0000002534 dat d 09 ' '
I'445,000.00 in cashl as full payment for the entire obii all f S "
Tandas and Rosevel B. Tandas with the Rural Bank of C ,
Inc. as payee under Extra~Judicial Foreclosure No. 2020-02-00, '
Due to the said undertaking, the scheduled bl'
coming July 30,2020 at 10:00 o'clock in the mornin f t
Building, Baler, Aurora and on July 31,2020 at 2:00 ' I k '
front of Municipal Building of Diiasag, Dilasag, Aurora I h
Baler, Aurora, July 24,2020

-,.

I, '<' ,
^\IQ!=:. be?~Q D O I^ o
-~.-. . ~ .

Sheriff IV

COPY FURNISHED

I'Mayor s Office, Baler, Aurora A^^-I .\o u\ e-e- 6~7. < ,/ - coz. o

2. Post Office, Baler, Aurora ILL, ^< I L C ,L, '-, O jut4J 7 I, ,/ 121, ^.*)
<
3. Barengay Hall, Brgy. Buhangin, Baler, Aurora I^^-<\^- ' tv~u, 0'^^S a A-^, I 13.1>-o
4. Barangay Hall, Brgy, Reserva. Baler, Aurora
\^' fret 12 of fret1\:, o7"12ql'^.-*>
5, Mayor's Office, Dilasag, Aurora hot1 1-1 co 6^ , 2.1 1:17'
6. Post Office, Dilasag, Aurora

IF, ~.

7. Barengay Hall, Brgy. Maligaya Dilasag, Aurora 12::@c ') 0 ^!3, - L, \ 1.74' o4 -z_:7.1-^:.>
.

,
F~

8. Barengay Hall, Brgy. Di!aguidi, Oilasag, Aurora I*_ 6. I,,, g. ?!,-.. 11.7

9, Barangay Hall, Brgy. Diniog, Oitasag, Aurora

I
.\- ,I---
, 0. Barengay Hall, Brgy. Masagana, Dilasag, Aurora

11. Rural Bank of Casiguran (Aurora), Inc. ,

12. Sps. She ruin I. Tandas & Rosevel B. Tandas

a
I3. Atty. Glory Pearl D. Amwao

I"
a 4. Atty. Raquel R. Dujunco
Atty. Gennethe Anne R. Villabeza
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RURAL BANK OF CASIGURAN (AURORA), INC.

Jose Angry I I A V FlitJe. Pi. \Lilcic. '1011. Big\,. 0.1 ,::o, 131 1, <21 - A L, ! ,,, . ,

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RECE!VED THE FOLLOWING DOCUMENTS FROM RURAL BANK OF GASIGURAN

(AURORA), INC. the following documents to wit
1101';gint:11 copy of 1111/1. under TCT No. 051 '20/5000908{Inclo, in' I o1.1 * -:, I SHERWIN
I. TANDAS married 10 ROSEVEL Do LORES B. TANDAS. I'
Originol COPY o1 Tox Declerolion No. 02-030002-00847-R. /02-030002-00840 (100
sqm - Residentiol Lot No. 1204. B Ts-25810coiec! un 131gy. MOS, 19<, 11<, - 11th<<111
A ui Dr. .J; "
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1111/01/14, I LDPy o1 I <. 1x Roc!::11.1 NG 3183 :tritecl June 22.201 <^
. I PC. Vicinity Mop I
21 01'igino! copy o1 Tillo tint"er TCT No. 051-20130013571111d. ,I file ridt':,. -! ROSEVEL
Do LORES R. BELARMINO morned to Sherwin I. TANDAS ,' .
twigi!1.1 C (JPy of Tox Deciorofion No. TD No. 02-0101 I -01600-R (140'sqm ~
ResidentiolLoiN0,6.8 rib0-1.11, \1147Ui*.,<.,_:letiii\1<:9y. but, \lit. I'll. '*. ,*,;^.*1.1
I. p, .. \/;*1.11y tviLi!, I' ~ '~ ., r L . , . _.
31'01 1911/01 c. ,UV o1 Tillu ulna TCT No. 051 -201500i39/11:1, :!,:, lit, - I Kin, t-- , 11 SHERWIN
I. TANDAS morned 10 ROSEVEL Do LORES B. TANDAS.
tin;, 1.01 <. 00v ,! Tox Decioroiion No. 02-01010-03017-R. (229 sqm - Residenti. I
Lot No. 2524-8-2-E 10-.:(liedi:. 131.1;y. Pegeivcl B, .Ilei At. Ir:'110 .
oilCji!Talc, rival Tclxi. .!e. inn, '*linche!I~^ F1 N, ' ',', *"14thitI I, !.,' ;.: I'.^..
I 0<'. ViC!itiiy IV\fill, '~
4. I>1'10iitci! ,\)Fly o! Tit IC unde. I TCT No. 051 '20/5001401'!. 11 Id. ! I I'd I* I, ,if . - ^! SHERWiN
I. TANDAS morned 10 ROSEVEL Do LORES B. TANOAS I
011,111^. I CojJy digx Deciorotion No. 02-01010-03010-R, (228 sqm ~ Residentiol
Lof No. 2524-B-2.1 10<:cited lit 819y. Reservo. Bo!e:I Augoioj
011,111til Copy o1 10x Recap>I N0 31 I I ;;lied .Iunc I62014
} DC. Vicinity Moil
51 \ 1119/1it xi , ' L, !, y of Till!: ^ true! TCT No. 051 '20/30009j 5 '11/10i I! ^e: 1.01, I*.! t, : ROSEVEL
Do LORES R. BELARMINO morned to Sherwin I. TANDAS
I'hoio C I>!,/ of Tox Deciorotion No. TD No. 02-030007-01649-At 40,891sqm - I~
Residentiol Lot No. I . b ul>.:I. F' !, 11 : 10<. 1.1jut1 111 H! q y Elm~g. Eiji-, IbLit I ,\. I ^, , ,, - I
OilyJiiic:!,. o0y Of fox S ' c:e!pi uncle; of!. N(* Xi; 14 cici!e, :I jut, , 16 ,A1 I I'

,.,,,,,,,,,,, mm onom re, ,,.. .,, tomoo, ^ , ^ ,;,,*, ^,** rum, ~ am^*,^.
Do LORES R. BELARMINO in orried to Sherwin I. TANDAS ,.
Photo COPY o1Tox Deciorofion No. TD No. 02-1010-02543'(6401;Qin ~ Residentio!
Lol No. 2686 Pis- I I , \! ^! xi. 4'1<, I, toc <'110ct lit 81qy F:*-., t;,..,.'I IJii\ I\ :. ! ,'..,! , .I, I
011,111Lii COPY .\f Tclx ~',:<: e, 11 it - it\!:!*:. I -. I L. ' h*,... 41 I , ,1<1; erj .111, \,. I '. ,, . : ,*,'
I PC. '/ICiriily Mop I'
7.1<>!'igiit<:1:<:0py c, I litle Lii'Ide! KOT No. P-9649, ;;cic: lite lionie o' SHERWIN I.
TANDAS monted 10 ROSEVEL DotORES B. TANDAS.
Pi\,\',,, :4.1, -,' o1 Tox Deciorofion No. 07-030001 -01233-{113,402 ';Elm - Cocolond
Lot No. 693-C, CSd"04-020227-Djot:<:let* malt:. v ,*talkitr, y, , ii!I. "*. c;.. A. .-.,!. :!
< )ruinol I. 'upy d T, x Receij, ! F10 lint, er <~). R. N\., I I 15 Unity I ;, me i A ?i, ; * .,! *, !
Tclx Ciec:101'1ce wider O. R. Nt?. 152407'
I PL:. Vicinity Mop/
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8101/9!or"I copy o1 1111e :inclci TCT No. T-38635tJi\!ei ille litimi, ,! SHERW:N .
TANDAS monted to ROSEVEL Do LORES B. TANDAS. ,'
1'1'lotoccf. >y of Tox Deciorofion No. 07-030005.00463-A. (30,000 s in - Irri .
Ricelond/Up10nd Lot No. 1432-B of the SLik>ciivisior\
Oilosog Aurorci. v
IJF. r\ 10< '<lIec! in 131< y. D I \*! it I
Origincil COPY of Tclx Receipt No. LJnde! C>. R. hit\. 31 13 doled .11 , ? I6 1< , '
Tclx ,.!6,101i<. e uri, icy C. ; R. No. I 5240, ' ~ ' ' ' ' ' ~ "'
ipc. Vicinity Mop' I ,
9101igiitol COPY of Vonous 0111cio! Receipt uitoei OR. 03724'111:*7?;;,{' .' ?, I
0,7244 CIO!ec: July ;-'4202(I ' '
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