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Republic of the Philippines

REGIONAL TRIAL COURT


Eighth Judicial Region
Branch 18, Hilongos, Leyte
BENITO SABANDO,

CIVIL CASE NO. 722,

Plaintiff,

FOR:
QUIETING OF TITLE AND
DAMAGES WITH
PRELIMINARY INJUCTION

-versus-

.
AGUSTIN RIVERA JR.,
BELEN RIVERA, AND
CIRILO ISRAEL
Defendants.
x------------------------------------x

MOTION FOR JUDGMENT ON THE PLEADINGS

COME NOW, the plaintiff unto this Honorable Court, most respectfully allege:
1.

That defendants in this case have filed an Answer, and in that Answer, it is admitted in
paragraph 2 thereof that the plaintiff is the owner of the subject real property;

2. That said admission is an admission to the material allegation of the plaintiff, and creates
no more genuine issue in this case;
3. That paragraph 9 of the same Answer states that defendants are willing to vacate the
premises when plaintiff will the loan amount of P2,000.00 plus P10,000.00 for the value
of the improvements, to which the plaintiff hereby manifests his willingness to pay the
defendants of the same amount;
4. That having no more genuine issue and invoking Rule 34 of the Rules of Court, judgment
on the pleadings is appropriate.
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable
Court, that judgment be rendered based on the pleadings,
1. Declaring the plaintiff as the lawful owner of Lot 341; and

2. Making the defendants vacate the premises after payment of P12,000.00 by the
plaintiff.

Hilongos, Leyte.
January 11, 2012.

EFREN B. MENDOZA
Counsel for Plaintiff
IBP No. 876811, Jan. 9, 2012,
Tacloban City
PTR No. PL 5137208, Jan. 9, 2012,
Hilongos, Leyte
MCLE Compliance No. II-0006123
(Has complied for third compliance but
still awaiting certificate and
compliance number)

Roll No. 50005


TIN 906-925-044

323 R.V. Villaflores St.


Hilongos, Leyte

NOTICE OF HEARING
To: Atty. Josenilo Reoma
C. V. Alcuino Street
Hilongos, Leyte
Please be notified that on the 1 st day of February, 2013, or as soon as counsel may be
heard, the undersigned will ask the Honorable Court to approve the foregoing motion.
Thank you.

E. B. MENDOZA
The Clerk of Court
RTC Branch 18,
Hilongos, Leyte

Greetings!
Kindly submit the foregoing motion for consideration by the Honorable Court
immediately upon receipt thereof.

Thank you.
E. B. MENDOZA

Copy furnished:
ATTY. JOSENILO REOMA
Counsel for Defendants
C.V. Alcuino Street, Hilongos, Leyte
Republic of the Philippines
REGIONAL TRIAL COURT
Eighth Judicial Region
Branch 18, Hilongos, Leyte
BENITO SABANDO,
Plaintiff,
-versus-

CIVIL CASE NO. 722,


FOR:
QUIETING OF TITLE AND
DAMAGES WITH

PRELIMINARY INJUCTION
.
AGUSTIN RIVERA JR.,
BELEN RIVERA, AND
CIRILO ISRAEL
Defendants.
x------------------------------------x

ENTRY OF APPEARANCE
COMES NOW the undersigned counsel unto this Honorable Court, most respectfully
State:
1. That the undersigned is formally entering his appearance as counsel for the plaintiff;

2. That he prays that he be furnished with all the pleadings, notices, and processes by this
Honorable Court at his address below.

Most respectfully submitted.

EFREN B. MENDOZA
Counsel for Plaintiff
IBP No. 876811, Jan. 9, 2012,
Tacloban City
PTR No. PL 5137208, Jan. 9, 2012,
Hilongos, Leyte
MCLE Compliance No. II-0006123
(Has complied for third compliance but
still awaiting certificate and
compliance number)

Roll No. 50005


TIN 906-925-044

323 R.V. Villaflores St.


Hilongos, Leyte
Copy furnished:
ATTY. JOSENILO REOMA
Counsel for Defendants
C.V. Alcuino Street, Hilongos, Leyte