Republic of the Philippines

REGIONAL TRIAL COURT

Eleventh Judicial Region
BRANCH 50
Alabel, Sarangani Province

SPS. VINCENT CIVIL CASE NO. 0084-20

ENRIQUES GONZALES
AND ADELFLOR
DUQUEZA GONZALES,
Plaintiff,

-versus- -for-

DANGA BAD, JIMMY QUIETING OF TITLE AND/OR

YUNI, BILLY BAO, AND IN THE ALTERNATIVE,
THEIR UNNAMED RECOVERY OF POSSESSION
SPOUSES AND ALL AND OWNERSHIP,
PERSONS, PRIVIES DAMAGES AND
AND/OR AGENTS ATTORNEY’S FESS WITH
UNDER THEIR PRAYER OF PRELIMINARY
DIRECTION, MANDATORY/PROHIBITORY
Defendants. INJUNCTION
x-----------------------------------x

COMPLIANCE
(to the Order dated 22 June 2020)

COMES NOW Defendants, DANGA BAD, JIMMY YUNI and

BILLI BAO, through counsel from the Public Attorney’s Office, and
unto this Honorable Court, most respectfully state and aver that:

1. On 22 June 2020, the defendants through counsel received an

Order that the instant case is governed by A.M. No. 19-10-20-
SC (2019 Proposed Amendments to the 1997 Rules of Civil
Procedure) which took effect on 1 May 2020. Thus, the
defendants are directed to comply with Rule 7 thereof within
thirty (30) calendar days from receipt thereof.

SPOUSES GONZALES vs BAD, ET.AL//CIVIL CASE NO. 0084-20//QUIETING OF TITLE AND/OR

RECOVERY OF POSSESSION, ETC.
COMPLIANCE
Page 1 of 4
2. Thus, in view of the foregoing, the defendants have until 22
July 2020 to file their compliance. Hence, this compliance and
it’s attachments is filed within the reglementary period;

WITNESSES

1. DANGA BAD – the witness, Danga Bad, as one of the

defendants in this case shall testify that he is the owner of Lot
No. 523, Bsd-20321 which is where the property of the other
two (2) defendants were built. He will also prove that he has no
property or any construction which encroached Lot No. 521,
property of the plaintiffs, Spouses Gonzales. Attached herewith
is the Judicial Affidavit of Danga Bad marked as Annex “1” and
shall form an integral part of the Answer;

2. JIMMY T. YUNI – the witness, Jimmy Yuni, as one of the

defendants in this case shall testify that the property or any
construction which encroached Lot No. 521, property of the
plaintiffs, Spouses Gonzales has already been demolished
which rendered this instant complaint moot and academic.
Attached herewith is the Judicial Affidavit of Jimmy T. Yuni
marked as Annex “2” and shall form an integral part of the
Answer;

3. BILLY BAO - the witness, Billy Bao, as one of the defendants in

this case shall testify that the property or any construction
which encroached Lot No. 521, property of the plaintiffs,
Spouses Gonzales has already been demolished which
rendered this instant complaint moot and academic. Attached
herewith is the Judicial Affidavit of Danga Bad marked as
Annex “3” and shall form an integral part of the Answer; and

4. RICARDO P. PAÑARES, SR. – he will testify that he was the

Lupong Tagapamayapa who conducted the mediation before
the Barangay regarding the issue between Sps. Gonzales and
Bad, Bao and Yuni. That he will also testify that upon checking
the area, the portion of the house and cr which encroached Lot
No. 521 have already been demolished.

SPOUSES GONZALES vs BAD, ET.AL//CIVIL CASE NO. 0084-20//QUIETING OF TITLE AND/OR

RECOVERY OF POSSESSION, ETC.
COMPLIANCE
Page 2 of 4
 DOCUMENTARY EVIDENCE

1. Transfer of Rights dated 29 January 1990 – to prove that Lot

No. 521 was sold to Danga Bad by Carlos Faciol. Same is
already attached and marked as Annex “1” in the Judicial
Affidavit of Danga Bad;

2. Real Property Field Appraisal & Assessment Sheet –

Land/Plants & Trees with ARP No. 04905 – to prove that Lot
No. 521 is under the appraised and assessed under the name of
Danga Bad. Same is already attached and marked as Annex “2”
in the Judicial Affidavit of Danga Bad;

3. Sketch Plan of Lot 523, Bsd-20321 as Prepared for Bad Danga

dated 15 February 2018 – to prove that it is only on February
15, 2018 that Lot No. 523 was relocated. Same is already
attached and marked as Annex “3” in the Judicial Affidavit of
Danga Bad; and

4. Two (2) photos proving that the toilet and the front fence had
already been demolished. Same are already attached and
marked as Annex “4” and “5” in the Judicial Affidavit of Danga
Bad.

WHEREFORE, it is respectfully prayed of this Honorable Court to

take due notice of the foregoing compliance.

Other reliefs just and equitable are likewise prayed for.

Alabel, Sarangani Province, 21 July 2020.

RESPECTFULLY SUBMITTED:

PUBLIC ATTORNEY’S OFFICE

Department of Justice
Sarangani District Office
Alabel, Sarangani Province

SPOUSES GONZALES vs BAD, ET.AL//CIVIL CASE NO. 0084-20//QUIETING OF TITLE AND/OR

RECOVERY OF POSSESSION, ETC.
COMPLIANCE
Page 3 of 4
 BY:

BAI ALEFHA HANNAH M. MUSA-ABUBACAR

Public Attorney II
Roll of Attorney No. 67366
MCLE Compliance No. VI-0009755
IBP OR No. 120317-11/Jan/2020
Email Add: hannahalefha20@gmail.com
09090154295
PTR Exempt

NOTICE

THE CLERK OF COURT

RTC Branch 50
Alabel, Sarangani Province

GREETINGS!

Please submit the foregoing COMPLIANCE for consideration

and approval of the Honorable Court immediately upon receipt
hereof.

BAI ALEFHA HANNAH M. MUSA-ABUBACAR

ATTY. MARLON P. VILLANUEVA

Counsel for the Plaintiffs
Mezzanine Floor, ODABAS Bldg.
Daproza Avenue corner C.M. Recto Street
General Santos City

EXPLANATION

Service of the foregoing COMPLIANCE was made through

registered mail due to distance, manpower and time constraint.

BAI ALEFHA HANNAH M. MUSA-ABUBACAR

SPOUSES GONZALES vs BAD, ET.AL//CIVIL CASE NO. 0084-20//QUIETING OF TITLE AND/OR
RECOVERY OF POSSESSION, ETC.
COMPLIANCE
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