Republic of the Philippines

REGIONAL TRIAL COURT

8th Judicial Region
Branch 19
Catarman, Northern Samar

IGMEDIO ALCERA,
Plaintiff,
-

CIVIL CASE NO. C-1350

FOR: Reconveyance

Versus

HEIRS OF CELEDONIO
PEDONG, rep by his wife
OTELIA D. PEDONG
Defendants,
x---------------------------------x
MANIFESTATION
WITH MOTION FOR ISSUANCE OF
STATUS QUO ANTE ORDER
The Defendants, through the undersigned counsel unto this
Honorable Court, respectfully moves:
1. That on July 10, 2016 the Plaintiff through stealth and
intimidation have erected post within the land subject of the
above entitled case.
2. That the plaintiff as of the filling of this motion is in the act of
transporting material for the construction of a wall inside the
subject land which is tantamount to placing the law in his
hands despite the pendency of the instant case.
3. That defendants has a clear and unmistakable right to the
subject property being the owner thereof, as evidenced by a
Transfer Certificate of Title with no. T-7829.
4. That the acts of the plaintiff in constructing posts and
transporting materials for the construction of a fence within the
land subject of litigation is a clear violation of preserving the
status quo of the land.
5. That for fear of the defendants that the plaintiff will be able to
finally construct a wall thereby limiting and restricting their

ALCERA vs PEDONG CC NO. 1350. Manifestation with Motion for Issuance of Status Quo Ante Order
[Date]

access to the aforementioned land, a motion to preserve the

status quo is herewith in order.
6. That until the Honorable Court declares the true owner of the
subject land, the plaintiff has no authority to construct or to
exercise any acts of ownership to the subject land.

WHEREFORE, premises are considered, it is most respectfully

Prayed that a Status Quo Ante Order be issued to the Plaintiff, ordering
him to CEASE AND DESIST from the disputed portion of the land
subject matter of the instant case and directing him further to remove
the posts that had been erected in the subject portion of the land.
Other Reliefs as just and equitable are likewise prayed for.
Respectfully submitted
Catarman, Northern Samar

ATTY FRANCO ARCHIE N. TONOG

Counsel for the Defendant
UEP Zone III, Catarman
Northern Samar
Roll No. 65001
IBP No. 1040760 5/16/16
PTR No. 3276706 6/20/16
MCLE: (New Lawyer)

NOTICE OF HEARING
The Clerk of Court
Regional Trial Court
Branch 19
Greetings:
Kindly submit the foregoing Manifestation with Motion for Issuance
of Status Quo Ante Order to the Honorable Court immediately upon
receipt for its consideration and approval without any further arguments
from the undersigned counsel.

ATTY FRANCO ARCHIE N. TONOG

ALCERA vs PEDONG CC NO. 1350. Manifestation with Motion for Issuance of Status Quo Ante Order
[Date]

Copy furnished:
Atty. Johaness Monje
Counsel for the Plaintiff
Catarman, Northern Samar
Reg. Receipt No._____________
Please take notice that counsel has requested for the approval of
this motion immediately upon receipt.

ATTY FRANCO ARCHIE N. TONOG

ALCERA vs PEDONG CC NO. 1350. Manifestation with Motion for Issuance of Status Quo Ante Order
[Date]