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Motion To Admit Additional Document

This document is a motion filed in a civil case in the Municipal Trial Court of Vinzons regarding recovery of possession of land with damages. It requests to admit additional documentary exhibits to aid in determining the true history, identity and boundaries of the lots in question. The motion provides background on the parties originally agreeing to a common surveyor but circumstances preventing that. It then lists 6 specific additional exhibits, including technical descriptions, maps, and ownership documents of the lots to be presented by a private surveyor hired by the defendant. The motion argues this will help the court understand and decide the case, and is not intended to delay proceedings. It requests the court admit the additional exhibits after notice and hearing.

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Frederick Eboña
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11K views3 pages

Motion To Admit Additional Document

This document is a motion filed in a civil case in the Municipal Trial Court of Vinzons regarding recovery of possession of land with damages. It requests to admit additional documentary exhibits to aid in determining the true history, identity and boundaries of the lots in question. The motion provides background on the parties originally agreeing to a common surveyor but circumstances preventing that. It then lists 6 specific additional exhibits, including technical descriptions, maps, and ownership documents of the lots to be presented by a private surveyor hired by the defendant. The motion argues this will help the court understand and decide the case, and is not intended to delay proceedings. It requests the court admit the additional exhibits after notice and hearing.

Uploaded by

Frederick Eboña
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

MUNICIPAL TRIAL COURT OF VINZONS


Fifth Judicial Region
Vinzons, Camarines Norte

_________________
Plaintiff,
Civil Case No. _____________

For: “Recovery of Possession


-versus- With Damages”

__________________,
Defendant.
x--------------------------------------------------------x

MOTION TO ADMIT ADDITIONAL DOCUMENTRAY EXHIBIT

COMES NOW, DEFENDANT _____________, through the


undersigned counsel and unto this Honorable Court, most
respectfully states that:

1. During the Pre-Trial Conference, both the defendant and the


plaintiff agreed to get a common surveyor to survey the lot
subject of this case;

2. Subsequently, both the defendant and plaintiff agreed to


appoint a geodetic engineer from the Provincial Environment
and Natural Resources (PENRO) for the Province of
Camarines Norte, however, when the court issued an order
to PENRO, the latter filed a manifestation that they were
advised to refrain from accepting survey work assigned by
the Court pursuant to DENR Regional Office No. V
Memorandum dated February 10, 2016;

3. The defendant who is an indigent litigant can no longer afford


to hire a common private surveyor since she already
previously hired a private geodetic engineer Hazel V. Mangiga
who is not yet fully paid due to financial constraints;

4. In view of the manifestation from PENRO, the defendant will


be presenting private geodetic engineer Hazel V. Mangiga who
will thoroughly explain the history, identity and boundaries
of Lot 414 and Lot 922-A-3-F-2, the lot subject of this case,
since she already hired her previous to the agreement by the
plaintiff and defendant to appoint a common surveyor;

5. In order to explain thoroughly the history, identity and


boundaries of Lot 414 and Lot 922-A-3-F-2, additional
documentary exhibits will be presented by geodetic engineer
Hazel V. Mangiga, to wit:

a. Technical Descriptions of Lot 922 and Lot 923 to be


marked as Exhibit “31” to “31-A”

b. Plot or Graphical Representation of the Boundaries of


Lot 922 and Lot 923 based on their technical descriptions
to be marked as Exhibit “32”

c. Cadastral Map and Public Land Subdivision to be marked


as Exhibit “33” and “33-A”

d. Tax Mapping from the Assessor’s Office of Vinzons to be


marked as Exhibit “34”

e. OCT No. P-3707 to be marked as Exhibit “35” to “35-C”

f. Request for Survey Assistance and Notification Letters


to be marked as Exhibit “36” to “36-C”

6. The presentation and admission of the foregoing additional


documentary exhibits will aid in knowing and understanding
the true and correct history, identity and boundaries of Lot
414 and Lot 922-A-3-F-2 which is indispensable in deciding
this case;

7. In view of the foregoing, the defendant moves that the above-


mentioned additional documents/documentary exhibits be
admitted;

8. This motion is not intended to delay the proceedings in this


case but solely for the reasons afore-cited.

WHEREFORE, premises considered, it is respectfully prayed of


this Honorable Court that after due notice and hearing, this motion
to admit additional documentary exhibits be noted and admitted into
the Records of this case and consequently admit/grant the same.

Other reliefs just and equitable under the premises are likewise
prayed for.

4, December 2019, Daet, Camarines Norte.


Department of Justice
PUBLIC ATTORNEY’S OFFICE
Daet District Office

By:

___________________________________

NOTICE OF HEARING

The Clerk of Court


Municipal Trial Court of Vinzons,
Vinzons, Camarines Norte

_______________________________
Counsel for the plaintiff

Greetings:

Please take notice that the foregoing motion shall be submitted


for the consideration and resolution of the Honorable Court upon
receipt hereof and on the date most convenient to the Honorable
Court.

____________________________
Counsel for the defendant

Copy furnished:

_______________________________
Counsel for the plaintiff
Baldovino Road, Camambugan
Daet, Camarines Norte

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