Republic of the Philippines

MUNICIPAL TRIAL COURT

Luna, Apayao

Patrick S. Mabini,
Plaintiff, Civil Case No. _________
For: Annulment/Declaration
of
-versus- Nullity of the Deed of Absolute
Sale, Transfer Certificate of
Title, Reconveyance and
Damages
Jimmy B. Calelao.
Defendant.
x-----------------------------------------x

MOTION TO INTERVENE

Movant Valentino Mabini, thru his undersigned counsel, unto this

Honorable Court most respectfully request for leave to intervene in the above-
captioned case, and states THAT:

1. The movant is the father of the herein plaintiff Patrick S. Mabini;

2. The movant is one of the sons of the late Wilson Mabini who is the son
of Sebio I. Mabini;

3. As a son of Sebio I. Mabini, the movant is a co-heir of the land originally

registered under the name of Sebio I. Mabini with Original Certificate of
Title No. 1234567;

4. The movant has a legal interest in the matter under litigation, or in the
success of the complainant;

5. This intervention will not, in the least, unduly delay or prejudice the
adjudication of the rights of the original parties in the case;

WHEREFORE, it is most respectfully prayed that the said movant be

allowed to intervene in this action by filing a Complaint-In-Intervention, a copy
of which is attached to this motion.
 Province of Apayao. June 15, 2022.
RAKESH C. REDDY
09755926781
San Carlos, Sta. Marcela, Apayao
PTR No. 1234567/February 14, 2020/Apayao
IBP No. 12345/January 14, 2020
Date Admitted: June 7, 2020

Copy Furnished:

KYLE POPPY C. EDAY

Counsel for the Plaintiff
San Carlos, Sta. Marcela, Apayao

BRANCH JAKE E. MADARIAGA

Counsel for the Defendant
Poblacion, Luna, Apayao

EXPLANATION

Service of the foregoing was done thru registered mail to the defendant and
personal service to the plaintiff.