sabando vs. rivera

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Republic of the Philippines REGIONAL TRIAL COURT Eighth Judicial Region Branch 18, Hilongos, Leyte BENITO SABANDO, CIVIL CASE NO. 722, Plaintiff, FOR: QUIETING OF TITLE AND -versus- DAMAGES WITH PRELIMINARY INJUCTION . AGUSTIN RIVERA JR., BELEN RIVERA, AND CIRILO ISRAEL Defendants. x------------------------------------x MOTION FOR JUDGMENT ON THE PLEADINGS COME NOW, the plaintiff unto this Honorable Court, most respectfully allege: 1. That defendants in this case have filed an Answer, and in that Answer, it is admitted in paragraph 2 thereof that the plaintiff is the owner of the subject real property; 2. That said admission is an admission to the material allegation of the plaintiff, and creates no more genuine issue in this case;

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Sabando V rivera

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Page 1: Sabando vs. Rivera

Republic of the PhilippinesREGIONAL TRIAL COURT

Eighth Judicial RegionBranch 18, Hilongos, Leyte

BENITO SABANDO, CIVIL CASE NO. 722, Plaintiff, FOR: QUIETING OF TITLE AND -versus- DAMAGES WITH PRELIMINARY INJUCTION

.

AGUSTIN RIVERA JR.,BELEN RIVERA, ANDCIRILO ISRAEL

Defendants.x------------------------------------x

MOTION FOR JUDGMENT ON THE PLEADINGS

COME NOW, the plaintiff unto this Honorable Court, most respectfully allege:

1. That defendants in this case have filed an Answer, and in that Answer, it is admitted in

paragraph 2 thereof that the plaintiff is the owner of the subject real property;

2. That said admission is an admission to the material allegation of the plaintiff, and creates

no more genuine issue in this case;

3. That paragraph 9 of the same Answer states that defendants are willing to vacate the

premises when plaintiff will the loan amount of P2,000.00 plus P10,000.00 for the value

of the improvements, to which the plaintiff hereby manifests his willingness to pay the

defendants of the same amount;

4. That having no more genuine issue and invoking Rule 34 of the Rules of Court, judgment

on the pleadings is appropriate.

Page 2: Sabando vs. Rivera

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable

Court, that judgment be rendered based on the pleadings,

1. Declaring the plaintiff as the lawful owner of Lot 341; and

2. Making the defendants vacate the premises after payment of P12,000.00 by the

plaintiff.

Hilongos, Leyte.

January 11, 2012.

EFREN B. MENDOZA Counsel for Plaintiff

IBP No. 876811, Jan. 9, 2012, Tacloban City

PTR No. PL 5137208, Jan. 9, 2012, Hilongos, Leyte

MCLE Compliance No. II-0006123 (Has complied for third compliance but still awaiting certificate and compliance number)

Roll No. 50005 TIN 906-925-044 323 R.V. Villaflores St.

Hilongos, Leyte

NOTICE OF HEARING

To: Atty. Josenilo Reoma C. V. Alcuino Street Hilongos, Leyte

Please be notified that on the 1st day of February, 2013, or as soon as counsel may be heard, the undersigned will ask the Honorable Court to approve the foregoing motion.

Thank you.

E. B. MENDOZA

Page 3: Sabando vs. Rivera

The Clerk of CourtRTC Branch 18, Hilongos, Leyte

Greetings!

Kindly submit the foregoing motion for consideration by the Honorable Court immediately upon receipt thereof.

Thank you.

E. B. MENDOZA

Copy furnished:

ATTY. JOSENILO REOMA Counsel for DefendantsC.V. Alcuino Street, Hilongos, Leyte

Page 4: Sabando vs. Rivera

Republic of the PhilippinesREGIONAL TRIAL COURT

Eighth Judicial RegionBranch 18, Hilongos, Leyte

BENITO SABANDO, CIVIL CASE NO. 722, Plaintiff, FOR: QUIETING OF TITLE AND -versus- DAMAGES WITH PRELIMINARY INJUCTION

. AGUSTIN RIVERA JR.,BELEN RIVERA, ANDCIRILO ISRAEL

Defendants.x------------------------------------x

ENTRY OF APPEARANCE

COMES NOW the undersigned counsel unto this Honorable Court, most respectfully State:

1. That the undersigned is formally entering his appearance as counsel for the plaintiff;

2. That he prays that he be furnished with all the pleadings, notices, and processes by this

Honorable Court at his address below.

Most respectfully submitted.

EFREN B. MENDOZA Counsel for Plaintiff

IBP No. 876811, Jan. 9, 2012, Tacloban City

PTR No. PL 5137208, Jan. 9, 2012, Hilongos, Leyte

MCLE Compliance No. II-0006123 (Has complied for third compliance but still awaiting certificate and compliance number)

Roll No. 50005 TIN 906-925-044 323 R.V. Villaflores St.

Hilongos, Leyte

Page 5: Sabando vs. Rivera

Copy furnished:

ATTY. JOSENILO REOMA Counsel for DefendantsC.V. Alcuino Street, Hilongos, Leyte