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Republic of the Philippines

REGIONAL TRIAL COURT


National Capital Judicial Region
Branch 223, Quezon City

IN RE: PETITION FOR ISSUANCE OF WRIT


OF POSSESSION UNDER SECTION 7 OF
ACT NO. 3135 AS AMENDED OVER THE
PROPERTY COVERED BY TRANSFER
CERTIFICATE OF TITLE NO. 004-2012002-
959 OF THE REGISTRY OF DEEDS OF
QUEZON CITY IN THE NAME OF MARIBEL
C. LAROZA

L.R.C CASE NO. R-QZN-


14-06105-R

GENEROSO B. DIUCO,

SUBMISSION

MOVANT, LEONOR MARIANO, through the undersigned counsel


and unto this Honorable Court most respectfully avers that:

In compliance with the Honorable Courts Order dated February


10, 2017 (copy of which is herein attached as ANNEX A for reference)
tentatively setting this case for the reception of evidence on April 07,
2017, Movant respectfully submits the following documents:

1. Copy of Decision dated March 07, 2017 issued by


the Quezon City Regional Trial Court, Branch 225
in the case entitled Jose T. Mateo v. Maribel Laroza
docketed as Civil Case No. R-QZN-13-72894 which
was filed by herein Movant against Maribel Laroza
for Annulment of the latters Title. The Honorable
Court in the said Decision ANNULED Ms. Maribel

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Larozas title, and Ordered the Registry of Deeds
to CANCEL TCT NO. 004-2012002-959 and to
REINSTATE TCT NO. 4832 (353785) or issue a
new title covering the subject property in the name
of Movant, Jose T. Mateo as ANNEX B; and

2. Copy of Movants Formal Offer of Evidence submitted


in the case of Jose T. Mateo v. Maribel Laroza docketed
as Civil Case No. R-QZN-13-72894 which includes the
respective Judicial Affidavits.

Lastly, herein Movant respectfully reserves the right to present


additional evidence as the need arises.

PRAYER

WHEREFORE, in view of the foregoing, it is most respectfully


prayed of this Honorable Court that the foregoing submission be
NOTED.

OTHER RELIEFS, just and equitable under the premises are


likewise prayed for.

RESPECTFULLY SUBMITTED.

Quezon City, 31 March 2017.

ALFEROS ARMAS & ASSOCIATES


Law Office
Unit K, No. 1143 San Francisco Del Monte Avenue
Barangay Paltok 1105, Quezon City

by:

ATTY. JAIRUS B. RUBIO


Counsel for the Movant
Roll No. 64701
PTR No. 2182274; January 06, 2017; Quezon City
IBP No. 1067008; January 20, 2017; Quezon City

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MCLE Compliance No. V-0022377
Email Ad: jairusbaldemorrubio@gmail.com
Tel No. 9584884/09174348111

COPY FURNISHED WITH EXPLANATION

SANHI PEREZ AND SAN GABRIEL


Counsel for the Petitioner
25/F Galleria Corporate Center EDSA
Cor. Ortigas Ave. Quezon City

A copy of this SUBMISSION was served to the other party by


means of registered mail with return receipt due to distance and
lack of personnel to effect personal service thereof.

ATTY. JAIRUS B. RUBIO


Counsel for the Movant