Republic of the Philippines

Department of Environment and Natural Resources

Region VII, Province of Cebu
CENRO Cebu City

SPECIAL ADMINISTRATIVE PROCEEDINGS

Heir of Maximina Dela Cruz Alias Maximiana DENR-7, CENRO-PENRO,

Claimant of Lot no.1517-Cad -747-D, Case No. ___________
Tuyan Naga Cebu ___________
___________
Represented by:
Norma Dela Cruz, surviving daughter, For: Nullity, Cancellation of Title
Felicitos Dela Cruz-Grand Son Approved Plan with other
Documents

Attorney-In-Fact:
Rogelio V. Amante
Carlito D. Escote
Plaintiffs

CHARLIE F. FABRE, PhD

OIC, Assistant Regional Director for
Technical Services

CENRO/PENRO OFFICER ARGAO

South Extension Office
Argao Cebu Province

The City Assessor, Naga City Cebu

ATTY. ARIEL B. CONDAT

Register of Deeds
Cebu Province
Nominal Parties
x- - - - - - - - - - - - - - - - - - - - - - - - - - - /

MOTION TO RECALL
Title no. OP-60057, HOMESTEAD PATENT NO. 072234-2007-176
Issued to Sps. Felisa Uy Co and Co Tong Te Sr.
and other Supplemental Documents

COMES NOW, The Plaintiffs, represented by the attorney-In-Fact through

this

verified instrument most respectfully submit this Notice to Recall unto to Honorable

Tribunal in accordance with law do hereby depose and state; That –

1. Plaintiff got surprised the status of their property know as Lot no. 1517-Cad
 747- D at Brgy. Tuyan Naga City, Cebu Province, whom they had recently

knew had already issued and Lot Title no. OP-60057 taken from homestead

Patent no. 072234-2007-176 in favor to both spouse Felisa Uy Co and

Tong Te Sr. with postal address no.82 Magallanes St., Cebu City, bearing

the Tax Declaration No. 01-36-018352.

2. Plaintiffs had already submitted to the Land Registration Authority the

Petition for Consulta of the said title with a separate cause of action. In

consonance to this matter, Plaintiffs had decided refer the issues to this

Honorable Tribunal who was responsible on the Land Investigation,

approved Plan, and the recommendation for issuance of the so-called title

without scrutinizing the real physical status of ownership. Wherein Plaintiffs,

was been deprived to claimed and possession over the said properties who

discovered some anomalous transaction. The ministerial function for the

issuance of said patent in pursuant to Presidential Decree 705 otherwise

known as Forestry Law which the President of the Republic of the

Philippines has the authority to issue the so-called patent. However, the so-

called original patent has full discrepancies that should considered. First and

foremost, dependents fail to Obtain the remaining successors or heir of the

late Maximina Dela Cruz alias Maximiana Dela Cruz, Registered as

cadastral claimants Lot. no 1517, Cad 747-D Located at Tuyan Naga Cebu

as per on the record of the Bureau of Land, Department of Environment and

Natural Resources, Region -7.

2.1 At outset the family tree should be considered, the sibling of the late

Maximina alias Maximiana who got married to Eustaquio Salinas Dela Cruz-

decease who has sibling refer the family tree as per attached hereof.
 PRAYER

Wherefore, in the premise considered all stipulated arguments on issues

was

clearly emphasized of the issuance of original patent of Tittle no. OP-60057

taken from Homestead Patent no. 072234-2007-176 was made done and

prepared through administrative proceedings as orchestrated among

PENRO

and CENRO.

Therefore, no Judicial court proceeding raised in any court in order to

secure

DECREE of so-called title.

Plaintiffs further Pray the reconsideration of this motion to recall including

the

supplemental documents. Furthermore, to prepare a resolution of the

nullification of the above mention title requesting the Register of Deeds of

Cebu Province of the nullification of entries at the Register of Deeds of

Province to give ways referential consideration of issuance of another title to

the plaintiffs.

Other reliefs and remedial issues are also Prayed for.

Respectfully submitted on 8th days of February 2024, in Cebu City

for(CENRO

DENR-7 Argao Cebu.

The Attorney-In-Facts:

ROGELIO V. AMANTE CARLITO D. ESCOTE

Paralegal/Attorney-In-Fact Attorney-In-Fact
TIN. NO. 180-426-105 TIN NO. 289-630-856-00000

Conform by heir successors:

NORMA FERNANDEZ DELA CRUZ FELICITO B. DELA CRUZ
Sole Surviving Heirs of Spouse Grandson/Plaintiff
Daughter/ Plaintiff
National I.D. no. 3175-8389-0560-2840