Republic of the Philippines

Regional Trial
th
7 Judicial Region
Branch 6
Cebu City

ROSANA SUAREZ, MARIA SUAREZ AND

CONCHITA SUAREZ ,
Plaintiff,
Civil Case No. CEB-1234
-versus- For: ANNULMENT OF
SALE
JOLLEANE PERINO,
Defendant.
x---------------------------------------------------------x

PLAINTIFFS, FORMAL OFFER OF EVIDENCE

Plaintiffs, through counsel and to the Honourable Court,

respectfully offers as an integral part of his testimony, the following
exhibits, as well as the respective purpose/s for which the probative
and evidentiary value thereof are being sought admission, to wit:

EXHIBIT DESCRIPTION PURPOSE

A Tax Decl’n no. 67890 To show that Plaintiff is the
for the year 2015 in lawful owner of property
the name of Rosana with Lot No. 12345.
Suarez
B Tax Decl’n no. 101112 To show that the property
in the name of was unlawfully transferred
Defendant Jolleane to Defendant through a
Perino forged deed of sale

C Tax Decl’n no. 67891, in x property was unlawfully

the name of Jolleane transferred to Defendant
Perino, issued in lieu of
Tax Decl’n 67890

D Deed of Absolute Sale To show that the Defendant

executed on March immediately took the
26, 2015 by Rosana Plaintiff to the hospital to
Suarez, in favor of seek medical attention after
Defendant the incident.

E Certificate to File To show that plaintiffs have

Action, issued by the resorted to barangay court
Brgy. Captain of but conciliation failed.
Labangon, Cebu City

F Judicial Affidavit of To show that Plaintiff

Rosana Vda. De Rosana Suarez executed a
Suarez Judicial Affidavit on
October 2, 2019 narrating
the events that transpired
leading to the filing of the
case..
 G Marriage Contract of To show Plaintiff is lawfully
Rosana Vda. Suarez married to Juan Suarez
and Juan Suarez, thus, making the property
issued by PSA subject of the case,
conjugal.

H Death Certificate of To show the fact of death of

Juan Suarez the husband of plaintiff
Rosana Suarez. Also, that
the other half of the
property lawfully belongs
pro indiviso to their
children.

I Judicial Affidavit of To show that plaintiff

Maria Cruz Rosana Suarez in fact an
illiterate and the latter’s
intent was only to mortgage
and not sell the property.

All exhibits are offered to prove and substantiate all the

allegations and causes of action in the answer, including prayer for
attorney’s fees, moral damages and costs of suit.

WHEREFORE, it is most respectfully prayed that the foregoing

exhibits presented during the trial of the instant case be admitted in
evidence.
Other reliefs just and equitable are likewise prayed for.

11th of November, 2019, Cebu City, Cebu, Philippines

CULABAN AND ASSOCIATES LAW FIRM

1st Floor, Vistana Building, Junquera Street,
Cebu City, Philippines

prepared by:

ATTY. NILO P. CULABAN, JR., CPA

Lead Counsel for Defendant
1st Floor, Vistana Building, Junquera Street,
Cebu City, Philippines
attynpcjrcpa@gmail.com
Telephone No. (032) 328-2233
Mobile No. 09561278024
PTR No. 1122334 – 01/10/19 – Cebu City
IBP OR No. 345678 – 01/02/19 – Cebu City
MCLE Compliance No. VI-0011223 – 04/17/19
Roll of Attorneys No. 1112

ATTY. RABINDRANATH S. POLITO

Counsel for Defendant
1st Floor, Vistana Building, Junquera Street,
Cebu City, Philippines
attyrspolito@gmail.com
Telephone No. (032) 328-2233
Mobile No. 09338596421
PTR No. 4455667 – 01/10/19 – Cebu City
IBP OR No. 113355 – 01/02/19 – Cebu City
MCLE Compliance No. VI-0077115 – 04/17/19
Roll of Attorneys No. 1107
 ATTY. PHILIP ROBERT S. JARAMILLO
Counsel for Defendant
1st Floor, Vistana Building, Junquera Street,
Cebu City, Philippines
philjaramillo@gmail.com
Telephone No. (032) 328-2233
Mobile No. 09338596421
PTR No. 1256262 – 01/10/19 – Cebu City
IBP OR No. 712718 – 01/02/19 – Cebu City
MCLE Compliance No. VI-00772125 – 04/17/19
Roll of Attorneys No. 99886

ATTY. JOHN LIEF GARRET T. SUMALPONG

Counsel for Defendant
1st Floor, Vistana Building, Junquera Street,
Cebu City, Philippines
jlgsumalpong@gmail.com
Telephone No. (032) 328-2233
Mobile No. 09338596421
PTR No. 111111 – 01/10/19 – Cebu City
IBP OR No. 222222 – 01/02/19 – Cebu City
MCLE Compliance No. VI-0069115 – 04/17/19
Roll of Attorneys No. 69696

ATTY. KENDRICK MARIO B. SIAO

Counsel for Defendant
1st Floor, Vistana Building, Junquera Street,
Cebu City, Philippines
kmsiao@gmail.com
Telephone No. (032) 328-2233
Mobile No. 09338596421
PTR No. 857664 – 01/10/19 – Cebu City
 IBP OR No. 647381 – 01/02/19 – Cebu City
MCLE Compliance No. VI-0077355 – 04/17/19
Roll of Attorneys No. 2109

ATTY. CARMELLA GAYE D. PEREZ

Counsel for Defendant
1st Floor, Vistana Building, Junquera Street,
Cebu City, Philippines
cgperez@gmail.com
Telephone No. (032) 328-2233
Mobile No. 09338596421
PTR No. 612517 – 01/10/19 – Cebu City
IBP OR No. 192189 – 01/02/19 – Cebu City
MCLE Compliance No. VI-0022115 – 04/17/19
Roll of Attorneys No. 9107

Copy furnished through personal service:

ATTY. CHERRY MAE VELOSO

Counsel for Plaintiff
No. 60, Manros Plaza, Mango Avenue,
Cebu City, Philippines