REPUBLIC OF THE PHILIPPINES

COURT OF APPEALS
Manila

REGINA GONZALES, ET. AL,

Plaintiffs - Appellants,

-versus- CA GR No. 105432

Civil Case No. 995-M-98
RTC Bulacan Br. 82
SPS. AMADEO MATEO, ET. AL.,
Defendants - Appellees.
x--------------------------------------x

APPELLEES BRIEF
Defendants Appellees SPS. DOLORES AND ARTURO LIM, through counsel,
unto this Honorable Court, most respectfully states that:

TIMELINESS OF THE BRIEF

1. Hereto defendants appellees received the plaintiff appellants Appellants
Brief of January 05, 2016. Pursuant to Sec. 8, Rule 44 of the Rules on Civil
Procedure, the defendant - appellees should file their appellees brief within
forty-five (45) days from receipt of the appellant's brief, or until February 19,
2016;
2. The undersigned counsel begged for the indulgence of the Honorable Court
to give him an extension of ____ days from the deadline or until ______ to
submit the defendants appellees Appellees Brief through a Motion for
Extension dated ________. Hence, this Appellees Brief is timely filed;

BRIEF STATEMENT OF THE CASE

3. Before the Honorable Court is an appeal from the Decision of Regional Trial
Court of Bulacan Branch 82 dismissing the action for Declaration of Nullity of
TCT Nos. T-10700-P(M) and T-10822-P(M) with a claim for damages filed by
plaintiffs appellants Regina Bautista, Conchita Mateo and Ester Feliciano
against Sps. Amadeo and Remedios Mateo, herein defendant appellees
Arturo and Dolores Lim, Sps. Tan Tian Siong and Virginia Ching, and the
Register of Deeds of Bulacan.

4. The plaintiffs - appellants filed their Complaint against the aforementioned

defendants - appellants, which was later on amended to include the Registry
of Deeds of Meycauayan, Bulacan. Thereafter, herein defendants appellees
spouses Lim received the same along with Summons and were able to file
their Answer with Counterclaim on December 1, 1998, the same is attached
hereto as Annex 1;
5. The case was set for pre-trial where the parties filed their respective pre-trial
briefs. During the pre-trial conference on January 28, 2000, the parties
entered into a series of stipulation of facts. Pre-trial was closed and
terminated, and a pre-trial order dated January 28, 200, was issued by the
trial court, the same is attached hereto as Annex 2. Trial on merits ensued;

6. On August 27, 2001, plaintiffs filed an Omnibus Motion for the Production and
to Submit the Questioned Document (Deed of Sale dated October 5, 1990)
for the Determination of the Genuiness / Authenticity to the NBI Questioned
Documents Division or to Camp Crame Questioned Documents Decision. The
Court denied the same considering the manifestations of the defendants
appellees that the subject documents were not in their possession and it is up
to the plaintiff to exert efforts to produce the original copy of the same;

7. On October 15, 2001, plaintiffs filed a Motion to Submit the Questioned

Document (Deed of Sale dated October 5, 1990) for the Determination of the
Genuineness / Authenticity of the Signature of Olimpio Gonzales in the said
Deed of Sale by NBI Questioned Documents Division which was also denied
by the Regional Trial Court considering that the questioned documents and
the sample signatures submitted by counsel for the plaintiff appellants were
merely photocopies. A Motion for Reconsideration was filed by the latter
which was later on granted by the court;

8. The plaintiff appellants presented the following witnesses: plaintiff

appellant Conchita Mateo, Adelia Cruz Demetillo, an NBI Document
Examiner, Atty. Ramon Clemente who notarized the Deed of Absolute Sale
dated October 5, 1990, and plaintiff appellant Ester Feliciano. Thereafter
the plaintiff appellants filed their Formal Offer of Evidence and rested their
case;

9. Defendants Appellees Sps. Amado Mateo and Remedios Mateo presented

the defendant appellee Amado Mateo himself, while defendant appellee
Dolores Lim herself stood as witness for herein defendant appellees Sps.
Lim. Defendant appellees Sps. Virginia Ching and Tan Tian Siong through
counsel manifested that they will adopt as their own evidence the testimonial
as well as documentary evidence of the other defendant appellees.
Thereafter they submitted their Formal Offer of Evidence and rested their
case. The Court ordered the parties to file their respective Memoranda to
which the parties complied;

10. On June 01, 2015, herein defendants appellees received a copy of the
Decision dated April 20, 2015, the dispositive portion of the said Decision
reads:

WHEREFORE, premises considered, for lack of evidentiary merit,

the instant complaint is hereby DISMISSED as against spouses
Amado and Remedios Mateo, spouses Dolores and Arturo Lim,
spouses Virginia Ching and Tan Tian Siong, and the Register of
Deeds of Meycauayan, Bulacan.
 The counterclaims by defendants spouses Mateo and defendants
spouses Lim are likewise DISMISSED for lack of merit.

No pronouncement as to costs.

SO ORDERED.

The said Decision is attached hereto and marked as Annex 3;

BRIEF STATEMENT OF FACTS

A summary of facts of the instant case relative to the defense of herein
defendants appellees are as follows:

11. Amado Mateo, one of the defendants appellees in this case, through a go-
between or ahente, came to herein defendant appellee Dolores Lim to sell a
parcel of land he had procured, the said parcel of land was situated at Bulac,
Sta. Maria, Bulacan with an area of Six Thousand Five Hundred Four (6,504)
square meters, which the latter agreed to buy. However, the titling of the said
parcel of land was still under process and the same when released would be
under the name of its original owner, Olimpio Gonzales (later on the parcel of
land was registered under OCT No. P-5120 (M)). The go-between advised
the parties to just have the sale executed directly by Gonzales and defendant
Dolores Lim to avoid high expenses and for expediency. After Mateo informed
Gonzales of the same, the latter agreed and personally caused the
preparation of the Deed of Sale in favor of defendant appellee Lim. On
October 5, 1990, Gonzales and defendant appellee Dolores Lim signed
and executed the said Deed of Sale in exchange of the amount of Sixty Six
Thousand Pesos (Php 66,000.00), the copy of the same being attached
hereto as Annex 4 . Thereafter, a Transfer Certificate of Title bearing TCT
No. T-10700-P(M) was released by the Register of Deeds of Meycauayan,
Bulacan in favor of herein defendants appellees;

12. On October 15, 1990, defendant Dolores Lim sold to defendant Tan Tian Song
the said parcel of land, together with another parcel of land not subject of this
instant case, for the consideration of Two Hundred Ten Thousand Forty Five
Pesos (Php 210,045.00) evidenced by a Deed of Absolute Sale bearing the
same date and notarized by Atty. Geronimo A. Santos, the copy of the same is
attached hereto as Annex 5. Due to the said sale and upon application to
the Register of Deeds of Meycauayan, Bulacan, a Transfer Certificate of Title
was issued in favor of Tan Tian Siong, bearing TCT No. 10822-P(M);

13. It was later on learned, more or less than a year after the sale that plaintiffs
appellants claimed that the parcel of land subject of the instant case was
donated to them, much to the surprise of the defendants appellees. The
 plaintiffs appellants filed various cases related to their alleged claim on the
parcel of land, such as a case of Estafa against Amado Mateo (September
22, 1992), Perjury against Amado Mateo, Reconstitution of OCT No. P-5120,
and an earlier Declaration of Nullity of TCT Nos. T-10700-P(M) and T-10822-
P(M) with a claim for damages against defendants - appellees of this case
sans Register of Deeds of Meycauayan, Bulacan and plaintiffs appellants
along with Gonzales under Civil Case No 614-M-94 which was later on
dismissed by the Honorable Regional Court Branch 78;

ISSUES
Upon reading the Appellants Brief, it could be gleaned that the following issues
are raised with respect to herein defendant - appellees:

I. THE HONORABLE REGIONAL TRIAL COURT EERED IN FINDING THAT

THERE WAS NO VALID DONATION BETWEEN AND AMONG DONOR
OLIMPIO GONZALES AND DONEE PLAINTIFF APPELLANTS;

II. THE HONORABLE REGIONAL TRIAL COURT EERED IN FINDING THAT

THERE WAS A VALID SALE BETWEEN OLIMPIO GONZALES AMD
DEFEMDANT APPELLEE SPOUSES ARTURO AND DOLORES LIM AS
THE SIGNATURE IN THE SUBJECT DEED OF ABSOLUTE SALE DATED
OCTOBER 5, 1990 WAS A FORGERY

ARGUMENTS
THE HONORABLE REGIONAL TRIAL COURT
DID NOT EER IN FINDING THAT THERE WAS
NO VALID DONATION BETWEEN AND AMONG
DONOR OLIMPIO GONZALES AND
DONEE PLAINTIFF APPELLANTS

The plaintiffs alleged that Olimpio Gonzales verbally donated to them over two
thousand square meters (2,000 sq. m.) of land, inclusive of the parcel of land subject of
this case, prior to the sale between Gonzales and defendant - appellees Sps.
Mateos, but this claim could not hold water as Article 749 of the Civil Code of the
Philippines states that:

Article 749 of the Civil Code of the Philippines states that:

Art. 749. In order that the donation of an immovable may be valid, it must
be made in a public document, specifying therein the property donated
and the value of the charges which the donee must satisfy.
x x x (Emphasis supplied)
Time and time again the Courts have ruled that verbal donations are void, such as in the
case of Felomina Abellana vs. Sps. Romeo Ponce and Lucila Ponce and the
Register of Deeds of Butuan City (G.R. No. 160488, September 3, 2004):

In the instant case, what transpired between Felomina and Lucila

was a donation of an immovable property which was not embodied
in a public instrument as required by the foregoing article. Being an
oral donation, the transaction was void. x x x No valid title
passed regardless of the intention of Felomina to donate the
property to Lucila, because the naked intent to convey without
the required solemnities does not suffice for gratuitous
alienations, even as between the parties inter se.

xxx

Unlike ordinary contracts (which are perfected by the concurrence of

the requisites of consent, object and cause pursuant to Article 1318
of the Civil Code), solemn contracts like donations are perfected only
upon compliance with the legal formalities under Articles 748 and
749. Otherwise stated, absent the solemnity requirements for
validity, the mere intention of the parties does not give rise to a
contract. The oral donation in the case at bar is therefore legally
inexistent and an action for the declaration of the inexistence of a
contract does not prescribe. x x x (Emphasis supplied)

Also in the case of Leonardo Notarte, et. al. vs. Godofredo Notarte (G.R. No. 180614
August 29, 2012):

Guillermo, on the other hand, claimed to have received 450-sq.m. from

Patrocenia by virtue of an oral donation in 1968 when he was instituted as
a tenant on her land. x x x In any case, the requirement as to form for
contracts of donation to be valid and enforceable, are absolute and
indispensable. The alleged prior oral donation by Patrocenia was thus void
and ineffective.

The plaintiff appellants, to justify the alleged donation, presented two deeds of
donation: one Deed of Donation in favor of Regina Bautista and Conchita Mateo, and
one Pagkakaloob which is in favor of Conchita Mateo. However, both are still
defective, invalid and do not transfer any right.

The Deed of Donation in favor of Regina Bautista and Conchita Mateo was executed on
February 21, 1991 but notarized on February 22, 1991. There is a lack of
communication of the acceptance to the donor after donation has been notarized.
Since there were different dates on the notarization and execution of the document, it
can be concluded that the acceptance was made before the notarization and after the
said notarization there was no proof that the plaintiffs communicated to the donor that
they accepted the said donation, when it is the only point in time when the donation
should have become valid in view of the strict provision of law that the donation must be
in public instrument, and the deed assumes such character only after notarization.

On the other hand, donation to Conchita Mateo, which is under the Pagkakaloob and
covers Four Thousand Five Hundred Four square meters (4,504 sq. m.) is void for
being inofficious, depriving early on his heirs of their legitime, as the subject property of
the Pagkakaloob is the only estate of the purported donor, hence he is donating his
entire estate which is contrary to Article 750 and 752 of the Civil Code of the
Philippines, to wit:

Art. 750. The donations may comprehend all the present property of the
donor, or part thereof, provided he reserves, in full ownership or in
usufruct, sufficient means for the support of himself, and of all relatives
who, at the time of the acceptance of the donation, are by law entitled to
be supported by the donor. Without such reservation, the donation shall
be reduced in petition of any person affected. (634a)

Art. 752. The provisions of Article 750 notwithstanding, no person may

give or receive, by way of donation, more than he may give or receive by
will.

The donation shall be inofficious in all that it may exceed this limitation.
(636)

It bears reiterating that under Article 752 of the Civil Code, the donation is inofficious if it
exceeds this limitation no person may give or receive, by way of donation, more than
he may give or receive by will. In Imperial vs. Court of Appeals, we held that
inofficiousness may arise only upon the death of the donor as the value of donation may
then be contrasted with the net value of the estate of the donor deceased. (Rolando
Santos vs. Constancia Santos Alana, G.R. No. 154942 August 16, 2005)

Assuming that these deeds of donation were validly executed and/or bereft of any
defect, it could be gleaned that the donations were done after the sale of the property to
herein defendants appellees Sps. Lim. The Deed of Donation in favor of Regina
Bautista and Conchita Mateo was executed on February 21, 1991 while the
Pagkakaloob to Conchita Mateo was dated March 21, 1991, however the sale between
Gonzales and Mateos occurred prior to the donations, and even the sale of the land to
herein defendants appellees Sps. Lim took place prior the donations, which was on
October 5, 1990, or around four (4) to five (5) years before the alleged donation. The
ownership of the defendant appellees in this case were more of value or weight
than their alleged possession. As correctly put by the trial court, With the sale to the
Mateos, Olimpio Gonzales therefore had no more rights nor interest to the subject
property when he signed the Deed of Donation bequeathing his property to defendants
Regina Gonzales and Conchita Gonzales. Such donation cannot be given weight in as
much as the subject of the donation does not belong to the donor. A basic principle in
property rules is that a person cannot give what he does not own nemo dat quod non
habet. x x x In sum, such donation did not transfer any rights or interests to herein
plaintiffs. Having acquired no rights over the property, they have thus no cause of action
to seek the cancellation of the transfer certificates of title of the subject property which
the defendants have lawfully acquired. (Decision, April 20, 2015, pages 21-22)
Further, as stated by the trial court in its Decision:

Second, even if the plaintiffs presented two (2) Deed of Donations (sic) dated
February 21, 1991 and March 14, 1991 executed by Olimpio Gonxales conveying
the subject property to them, plaintiffs never contested the fact that the subject
property was already sold to defendants Mateos before the same was donated to
them. Plaintiffs did not deny that the sale of the property to Mateos preceded the
donations. In fact, plaintiffs, through their counsel, admitted during pre-trial
Conference that Olimpio Gonzales formerly owned the subject property and was
sold to defendants Mateos. (Par. 1, Pre-Trial Order dated January 28, 2000).
Also, the Court need not resolve the issue whether the land as a whole sold by
Olimpio Gonzales to defendants Mateos in September of 1976 is the same land
subject and covered by OCT P-5120 as this was already admitted by the
plaintiffs and embodied in the pre-trial order. It is settled that The admissions of
the parties during the pre-trial as embodied in the pre-trial order of the court are
binding and conclusive on them, unless there is a clear showing that the
admission was entered through palpable mistakes. Such admissions cannot be
contradicted by the parties. (Decision, April 20, 2015, page 20)

If there were any defects or any claims over the property, the defendant appellees
Sps. Lim are considered purchasers for value and in good faith and thus protected by
the law, which will be discussed later on.

THE HONORABLE REGIONAL TRIAL COURT

DID NOT EER IN FINDING THAT
THERE WAS A VALID SALE BETWEEN
OLIMPIO GONZALES AND DEFENDANT APPELLEE
SPOUSES ARTURO AND DOLORES LIM

The plaintiff-appellants contest that the signatures of Olimpio Gonzales in the documents
respondents were forged, relying on the NBI QDD Report. Sadly, to conclude that the
signatures were forged based on the said report does not hold water. Time and time
again, the Supreme Court has ruled that the opinions of handwriting experts, even those
from the NBI, are not binding to the courts. The same could not conclusively state whether
a signature is a forgery or not. In Nancy Lorzano vs. Juan Tabayag Jr. (G.R. No.
189647, February 6, 2012), it is ruled that [I]t is true that the opinion of handwriting
experts are not necessarily binding upon the court, the experts function being to place
before the court data upon which the court can form its own opinion. Handwriting experts
are usually helpful in the examination of forged documents because of the technical
procedure involved in analyzing them. But resort to these experts is not mandatory or
indispensable to the examination or the comparison of handwriting. A finding of
forgery does not depend entirely on the testimonies of handwriting experts,
because the judge must conduct an independent examination of the questioned
signature in order to arrive at a reasonable conclusion as to its authenticity.
(Emphasis supplied).

It suffices that there is a visible general resemblance on the specimen signature and
the questioned one, determination of such will be within the judges independent
judgement. In Emiliano Alcos, et. al. vs. Intermediate Appellate Court, et. al. (G.R.
No. 79317, June 28, 1988), the Supreme Court stated that, The authenticity of
signatures in questioned documents has frequently been the subject of proffered expert
testimony. Such issue, however, is not a highly technical issue in the same sense that
questions concerning, e.g., quantum physics or topology or molecular biology, would
constitute matters of a highly technical nature. The opinion of a handwriting expert on
the genuineness of a questioned signature is certainly much less compelling upon
a judge than an opinion rendered by a specialist on a highly technical issue. The
signatures on a questioned document can be sighted by a judge who can and
should exercise independent judgment on the issue of authenticity of such
signatures. "The test of genuineness," Chief Justice Moran stressed in his standard
treaties, "ought to be the resemblance, not to the formation of the letters in some
other specimen or specimens, but to the general character of writing, which is
impressed on it as the involuntary and unconscious result of constitution, habit, or
other permanent course, and is, therefore, itself permanent." (Emphasis supplied.)

Assuming that there were little dissimilarities between the signature of Olimpio Gonzales
from the evidence submitted by the defendant appellees and the one submitted by the
plaintiff - appellants sample and the genuine one, which is actually a different document
from that which is the subject of this case, one should not disregard the fact that there is
a considerable span of time between the execution of the signatures, and as time has
passed it is not impossible that dissimilarities would surface as it is highly improbable that
signatures and handwriting can be duplicated or repeated exactly. Aside from span of
time, there are different situations that could contribute to the discrepancies between
signatures such as the position of the writer, the condition of the surface, the well-being
of the writer during the time he was affixing his signature or handwriting, etc. We have
ourselves examined the signatures of Emiliano Alcos and Cristeta Emnace Alcos in the
2 May 1950 Deed of Sale in favor of Blas P. Cavada, Sr., and the standard or control
signatures. It appears to the Court that there is a visible general resemblance between
the questioned signatures and the standard signatures, which general resemblance is
particularly marked in respect of the standard signature of Cristeta Emnace Alcos dated
27 September 1945 and the 12 May 1949 signatures of Emiliano Alcos. This general
resemblance is somewhat less marked when one compares the questioned signatures
with the other standard signatures of Emiliano Alcos and Cristeta Emnace Alcos, i.e.,
which were executed thirteen (13) years later than the questioned signatures; the general
resemblance, however, is still there and visible. Thus, we consider that the Court of
Appeals correctly rejected the unquestioning adoption by the trial court of the conclusions
of one witness albeit presented as an expert on questioned documents. (Ibid.)

A finding of forgery does not depend entirely on the testimonies of handwriting experts,
because the judge must conduct an independent examination of the questioned signature
in order to arrive at a reasonable conclusion as to its authenticity.

In Lorenzo v. Diaz, the factors involved in examining handwritings were identified and
explained in these words:
"x x x [T]he authenticity of a questioned signature cannot be determined
solely upon its general characteristics, similarities or dissimilarities with the
genuine signature. Dissimilarities as regards spontaneity, rhythm,
pressure of the pen, loops in the strokes, signs of stops, shades, etc.,
that may be found between the questioned signature and the genuine
one are not decisive on the question of the formers authenticity. The
result of examinations of questioned handwriting, even with the
benefit of aid of experts and scientific instruments, is, at best,
inconclusive. There are other factors that must be taken into
consideration. The position of the writer, the condition of the surface
on which the paper where the questioned signature is written is
placed, his state of mind, feelings and nerves, and the kind of pen
and/or paper used, play an important role on the general appearance
of the signature. Unless, therefore, there is, in a given case, absolute
absence, or manifest dearth, of direct or circumstantial competent evidence
on the character of a questioned handwriting, much weight should not be
given to characteristic similarities, or dissimilarities, between that
questioned handwriting and an authentic one."

Forgery cannot be presumed. It must be proved by clear, positive and convincing

evidence. The burden of proof lies in the party alleging forgery. (Nora T. Jimenes, et.
al. vs. Commission on Ecumenical Mission and Relations of the United
Prysbyterian Church in the United States of America, et. al., G.R. No. 140472, June
10, 2002; emphasis supplied.)
Assuming, por arguendo, that the signature on the subject Deed of Absolute Sale was
forged, the rights and interests of the defendant appellees are protected by law. The
defendant appellees in this case are purchasers for value and in good faith. By
definition, an innocent purchaser for value is someone who x x x purchases a property
without any notice of defect or irregularity as to the right or interest of the seller. He or she
is without notice that another person holds claim to the property being purchased. (Heirs
of Gregorio Lopez vs. Development Bank of the Philippines, G.R. No. 193551,
November 19, 2014). In the present case, they believed that the parcel of land they are
purchasing is free from defects and any other claims, and that they were transacting with
people who have the right to dispose the said property, i.e. the owner of the parcel of land
Olimpio Gonzales, and they have paid the full and fair price for such purchase. In fact,
the defendant- appellees, prior to purchasing the property, verified from the Register of
Deeds if there is any defect or infirmity in the title of the real property they were to acquire
by purchase, and were told that there was none. As put by the trial court:

Defendants Lim merely relied on the validity or correctness of the certificate of title
issued in the name of Olimpio Gonzales. x x x The rights of an innocent purchaser
for value must be respected and protected notwithstanding the fraud employed by
the seller in securing his title. In this case, the failure of the plaintiffs to adduce
evidence that Spouses Dolores and Arturo Lim x x x were cognizant of any
imperfection in the title of the seller of the subject property makes them an innocent
purchaser. As such their right to the property must be upheld. (Decision, April 20,
2015, page 22)

Jurisprudence has defined an innocent purchaser for value as one who buys the property
of another without notice that some other person has a right to or interest therein and who
then pays a full and fair price for it at the time of the purchase or before receiving a notice
of the claim or interest of some other persons in the property. Buyers in good faith buy a
property with the belief that the person from whom they receive the thing is the owner
who can convey title to the property. Such buyers do not close their eyes to facts that
should put a reasonable person on guard and still claim that they are acting in good faith.

The established rule is that a forged deed is generally null and cannot convey title, the
exception thereto, pursuant to Section 55 of the Land Registration Act, denotes the
registration of titles from the forger to the innocent purchaser for value. Thus, the
qualifying point here is that there must be a complete chain of registered titles. This means
that all the transfers starting from the original rightful owner to the innocent holder for
value and that includes the transfer to the forger must be duly registered, and the title
must be properly issued to the transferee x x x The forged instrument eventually became
the root of a valid title in the hands of an innocent purchaser for value. The new title under
the name of the forger was registered and relied upon by the innocent purchaser for value.
Hence, it was clear that there was a complete chain of registered titles. (Spouses
Dominador Peralta and Ofelia Peralta vs. Heirs of Bernardina Abalon, G.R. No.
183448, June 30, 2014)

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this
Honorable Court that the appealed Decision be affirmed.

Such other relief and remedies just and equitable under the premises are being
prayed for.

Respectfully submitted, City of Malolos, Bulacan (for City of Manila),

__________________.

DEGALA LAW OFFICE

(DEGALA, DEGALA & DEGALA Lawyers)
Counsel for the Respondent
The Cabanas Garden Mall, Km. 44-45, McArthur Highway,
Longos, City of Malolos, Bulacan
Mobile Phone No. 09229494430

For the firm:

ATTY. JESUS RICARDO C. DEGALA III

SC. Roll No. 39020
IBP O.R. No. ______ _______ BULACAN
PTR O.R. No. ______ _______ MALOLOS
MCLE Compliance Certificate No. _____________

Copy furnished:
Atty. Maria Eleonor Eusebio Cruz
(Counsel for the Plaintiffs - Appellants)
Rm. 7 G/F Hiyas Convention Center Annex
Capitol Compound, City of Malolos, Bulacan

Atty. Conrado P. Sajor

(Collaborating Counsel for the Plaintiffs Appellants)
Sandico St., Poblacion 1, Marilao, Bulacan

Atty. Dante H. Cortez

138 F. Blumintrit Cor. Gen. Bautista
San Juan, Metro Manila

Sps. Amado and Remedios Mateo

Brgy. Bulac, Sta. Maria, Bulacan

The Branch Clerk of Court

Branch 82 RTC Bulacan
City of Malolos

NOTICE

The Clerk of Court

Court of Appeals
Manila

Greetings!

For the urgent and good cause, please take notice that the undersigned counsel
for the defendants - appellees submit the foregoing Appellees Brief to the Honorable
Court for its kind consideration immediately upon receipt thereof.

ATTY. JRC DEGALA III

EXPLANATION
Copy of the foregoing Appellees Brief will be sent to the parties via registered
mail for lack of a messenger employed by the undersigned to effect personal service.
ATTY. JRC DEGALA III