REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT OF NEGROS OCCIDENTAL

6th Judicial Region
Branch 45, Bacolod City
-o0o-

HEIRS OF THE LATE SOTERA

ARTIFICE MARTINEZ,
Plaintiffs,
-versus- CIVIL CASE NO. 17-15000

SPS. MAE ANGELINE P. DELOSO

AND VICENTE DELOSO II, MAE
TIFFANY C. PARCON AND THE
REGISTRY OF DEEDS, BACOLOD
CITY,
Defendants.
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FORMAL OFFER OF EXHIBITS

COME NOW plaintiffs by undersigned counsel and to this Honorable

Court most respectfully submit their FORMAL OFFER OF EXHIBITS for
admission to support the fact that they are real parties in interest in the
above-entitled case, as follows:

Exhibit : "A”
Description : Death Certificate of Sotera Artifice-Martinez

Exhibit : “B”
Description : Declaration of Heirship and Extra-judicial Settlement of
Estate;

Exhibit : “C”
Description : Affidavit of Publication;

PURPOSE/S: Exhibits “A”, “B” and “C” are formally offered to prove that
Sotera Artifice-Martinez died on January 2, 2015 and
Survived by her nephews and nieces, the plaintiffs in this
Case. As the only heirs of the late Sotera Martinez, they
Adjudicated among themselves TCT No. T-326194 known
As Lot No. 1355-A-3 containing an area of 76,288 Square
Meters located at Barangay Granada, Bacolod City by
executing a Declaration of Heirship and Extra-Judicial
Settlement of Estate and the same was published in a
newspaper of general circulation in compliance with law
as shown in the Affidavit of Publication. Until now, the said
Declaration of Heirship and Extra-Judicial Settlement of Estate
 has never been questioned and opposed, hence, it is still valid
and legal;

Exhibit : “D”
Description : Certified True Copy of Transfer Certificate of Title No.
T-326194;
Purpose : Exhibit “D” is formally offered to prove that the late Sotera
Artifice-Martinez is the absolute and registered owner of
the said property covered by TCT No. T-326194;

Exhibit : “E”
Description : Admission and Discharge Record issued by Riverside
Medical Center;

Exhibit : “F”
Description: Clinical Data and Physician’s Progress Notes issued by
Riverside Medical Center;

PURPOSES : Exhibits “E” and “F” are formally offered to prove that the
Late Sotera Martinez was admitted for treatment at the
Riverside Medical Center on March 31, 2012 and she was
Diagnosed as having Dementia or the Progressive deterio-
Ration of one’s cognitive and intellectual functions;

Exhibit : “G”
Description : Certified True Copy of TCT No. 092-2014004449 issued in
the names of the defendants;

Exhibit : “H”
Description : Deed of Absolute Sale dated June 24, 2014 purportedly
executed by the late Sotera Martinez in favor of the
defendants selling the subject property for P1,000,000.00;

Purposes : Exhibits “G” and “H” are formally offered to prove that TCT No.
092-2014004449 was illegally issued which proceeded from an
spurious and defective Deed of Absolute Sale dated June 24, 2014
because at that time Sotera Artifice-Martinez has no longer the
mental capacity to contract or sell her properties due to dementia,
the consideration of P1,000,000.00 was very small and that
signature of Sotera is different from her usual signatures and she
never placed her thumb mark on any document she signed;

l
Exhibit : “I”
Description : Minutes of conversation taken from Charidel Grijaldo, caregiver
of Sotera, on September 12, 2015 in front of Barangay Officials of
Barangay Sara-et, Himamaylan City;
Exhibit : “I-1”
Description : Translation of the Minutes of Conversation taken from Charidel
Grijaldo;

Purposes : Exhibits “I” and “I-1” are formally offered to prove that Sotera
Martinez was under the care of Charidel Grijaldo and that the
former did not travel to Bacolod City in year 2014 and that she
forgotten everything;

Exhibit : “J”
Description : Affidavit of Adverse Claim dated September 22, 2015;

Purpose : Exhibit “J” is formally offered to prove that an Affidavit of

Adverse Claim was executed by the plaintiffs in this case and have
it recorded and annotated at the back of TCT No.092-2014004449
in order to protect and preserve the estate of the late Sotera
Artifice-Martinez; and

Exhibit : “K”
Description : Tax Declaration issued by the Office of the Assessors of Bacolod
City;

Purpose : Exhibit “K” is formally offered to prove that the market value of
the property is P1,144,320.00 while the assessed value is
P436,420.00;

The foregoing exhibits are also offered as part of the testimonies of the
Alfredo A. Parcon and Rodolfo A. Lomugdang, Jr., plaintiffs in this case.

All of the foregoing exhibits/evidences marked in this case were already

submitted and found on the records of this case.

WHEREFORE, premises considered, it is respectfully prayed of this

Honorable Court that the above-mentioned exhibits/evidences be admitted as
part of the evidences of the plaintiffs in this case.

Bacolod City, Philippines, December 28, 2021.

ATTY. NICANDRO A. AGUILAR

Counsel for the plaintiffs
Rm. 206, TG Building,
Gatuslao Street, Bacolod City
PTR No. 8617206-01/15/21
 IBP No. 138534 -1/05/21
Roll No. 33660/p.232
MCLE VI-0002236-5/16/17

Copy Furnished:

ATTY. ROMEO S. SUBALDO

Counsel for the defendants
2nd Floor, Door 2, Cineplex Bldg.
Araneta Street
Bacolod City