REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF AGRARIAN REFORM

Adjudication Board
Region III
Diwa ng Tarlak, Tarlac City

NOEL A. QUIRANTE represented by

CARMELITO M. QUIRANTE as
attorney-in-fact,
Plaintiff,
DARAB Case No. III-Y-6272-16
- versus -

SPS. MANOLO and ELIZA SEBASTIAN

and any and all persons acting for or
under their command,
Defendants
x----------------------------------------------------x

COMMENT/OPPOSITION

Plaintiff, through the undersigned counsel, and unto this

Honorable Office, most respectfully submits this Comment/Opposition
to refute the statements and allegations made by the defendants in
their Motion for Reconsidertaion dated ________,and in support thereof,
hereby states that:

1. In their motion, defendants-movants raises the following grounds:

a. The findings of fact that the defendants did not pay the required
rent is not supported by substantial evidence; and

b. The conclusion that defendants should therefore be ejected from

the land is contrary to law and jurisprudence.

2. The crux of the aforementioned grounds is a mere rehash of

movants previous arguments.

3. It is most humbly submitted that movant has failed to raise

matters substantially plausible or compellingly persuasive to warrant
the reversal of the Decision of the Honorable Office.

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4. Considering that the grounds presently raised have been
sufficiently considered, if not squarely addressed, in the subject
Decision, it behooves movant to convince the Honorable Office that
certain findings or conclusions in the Decision are contrary to law. As it
is, however, it is most humbly submitted that the instant motion does
not raise any new or substantial legitimate ground or reason to justify
the reconsideration sought.

5. Defendants consistently fail to present evidence to support their

allegations.

6. The attached Annexes do not prove any tenancy relationship

between the parties. A single receipt should not be considered to create
a tenancy relationship between the parties.

7. The Decision made by the Honorbale Office rests squarely on

established facts and jurisprudence.

8. It is humbly submitted that the Motion Reconsideration deserves

scant consideration. Its submission is an apparent attempt at delaying
the ends of justice;

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that

the Motion for Reconsideration by the defendants be DENIED for lack of
merit.

FINALLY, the plaintiff respectfully pays for such and other reliefs as
may be deemed just and equitable in the premises.

Tarlac City, 27 April 2017.

ESCALONA&FONACIER
119 Rosalia St., Saint Michael Village
Talon Dos, Las Pinas City

LEO MIGUEL A. ESCALONA

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 IBP No. 962487; 06 February 2014
PTR. No. 27188184; 06 February 2014
Roll No. 61822; Admitted to the Bar
April 2013

KARLA FLOR D. FONACIER

IBP No. 012830 Lifetime; 13 May 2014
PTR. No. 10705849; 08 May 2014
Roll No. 62968; Admitted to the Bar
May 2014

Copy furnished:

ATTY. MINERVA V. GABRIEL-

SAHAGUN
Public Attorneys Office
Tarlac City District Office
Tarlac Court Bldg., Tarlac City