Cadastral Cases Nos.

18-1488, 18-1489, 18-1490 and 18-1491

Entry of Appearance Good morning your Honorable Commissioner, I am

Atty. Stewart Paul Torre respectfully appearing for
Petitioners Arturo Calsa and Ibrahim Calanao in
Cadastral Cases Nos. 18-1488, 18-1489, 18-1490 and
18-1491 for Issuance of an Order to Surrender the
Owner’s Copy of the Transfer Certificate of Title.

Your honor, I would like to manifest that this cadastral

cases involve the same petitioners and respondents,
with intertwined issues and subject matters which
aside from this Honorable Court was raffled to
branches 33, 37 and 38. Consequently, orders to
consolidate from the aforesaid branches of the
regional trial court were already issued to petitioners’
counsel and being the court with the lowest case
number, this honorable court is assigned to here this
consolidated cases.

You honor, I would like to manifest that no oppositor

or intervenor is present in today’s hearing.
Particularly, respondent IBC is not represented. Thus,
I respectfully move for the presentation of evidence ex
parte and the appointment of the Clerk of Court as the
Commissioner to receive petitioners’ pieces of
evidence.

Your Honor, I am ready for the presentation and

marking of our documents to establish jurisdictional
facts of the case.

Presentation and Your honor, I would like to manifest that the original
Marking of Evidence copies of the documents to be presented and marked
as evidence were already submitted through the
office of the clerk of court. Thus, we respectfully pray
that the petitioners photocopy be compared to the
original to be first determined as the faithful
reproduction of the original and thereafter be
allowed to be marked as evidence.

Thank you your honor!

 For the petitioners, Your Honor, may we pray that
the certified true copy of the certificates of title
nos.: T-59380, T-59381, T-59382 and T-59383 be
marked as Exhibits A, B, C and D.

Your honor, may we also pray that the Final Deed of

Sale dated September 6, 2007 be marked as Exhibit
E;

Likewise your honor, we pray that a copy of the

demand letter dated August 1, 2017 addressed to
respondent IBC be marked as Exhibit F;

The petitioners also respectfully pray that a

Certification issued by the Registry of Deeds of Iloilo
City affirming that the certificates of title of the
abovementioned lots remain INTACT be marked as
Exhibit G;

Lastly, we respectfully pray that the Tax Declaration

and the Official Receipt for the payment most recent
of real property tax both dated February 9, 2018 be
respectively marked as Exhibits H and I

Formal offer of exhibits Exhibits A to I are being offered to this Honorable

Court to prove the jurisdictional facts of these
cadastral cases and to support the grant of the
petitioners prayer as follows:

a. a. To declare the lost Owner’s

Duplicate of OCT No. F-12742 as null and
void; and
b. To order the Registry of Deeds for the
Province of Iloilo to issue a New Owner’s
Duplicate Certificate for OCT No. F-12742
which shall in all respects be entitled to
like faith and credit as the original
duplicate certificate and shall be
registered as the original duplicate of title
for OCT No. F-12742 for all purposes of
 the Land Registration Act (Act. No. 496, as
amended).

I hereby submit this formal offer of exhibits for the

appreciation of this Honorable Court.

Your Honor, I rest my case.