REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
CALAMBA CITY, LAGUNA
BRANCH 34

IN RE: PETITION FOR

ISSUANCE OF WRIT OF
POSSESSION OVER THE REAL
PROPERTY COVERED BY
TRANSFER CERTIFICATE OF
TITLE NO. T-755449 OF THE
REGISTRY OF DEEDS FOR
CALAMBA CITY LAGUNA IN
THE NAME OF METROPOLITAN
BANK & TRUST COMPANY,

LRC CASE NO. 13-5845

METROPOLITAN BANK &
TRUST COMPANY,
Petitioner.
x-------------------------------------------x

FORMAL OFFER OF EVIDENCE

Petitioner METROPOLITAN BANK & TRUST COMPANY

(“Metrobank”), by counsel, to this Honorable Court respectfully
offers in evidence the following documentary exhibits for
admission as its evidence-in-chief in the above-captioned case, to
wit:

EXHIBIT DESCRIPTION PURPOSE

“A” Petition as filed in Court To prove that petitioner

(Court on 23 January 2014 Metrobank filed the Petition
Records) at bar in accordance with
the Act No. 3135, as
amended. To also prove
compliance with the
jurisdictional requirements
of this Honorable Court.

“B”, “B-1” Transfer Certificate of To prove the identity of the

and “B-2” Title No. T-755449 real property subject of this
(marked as case.
Annex “E”

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 in the
Judicial
Affidavit)
“B-3” Annotation of the To prove that petitioner
(marked as Certificate of Sale as Metrobank caused the
Annex “E-1” Entry No. 2013024338 registration of the
in the Certificate of Sale issued in
Judicial its favor by the Office of the
Affidavit) Clerk of Court of Calamba
City Laguna.
“C” Order dated January 27, To prove that this Court
(Court 2014 found petitioner
Records) Metrobank’s Petition to be
sufficient in form and in
substance and set the
same for initial hearing on 2
April 2014 at 8:30 o’clock in
the morning. To also prove
compliance with the
jurisdictional requirements
of this Honorable Court.
“D” and Certificate of Posting To prove that petitioner
“D-1” dated April 2, 2014 and Metrobank caused the
(marked as signature of Sheriff posting of the Order dated
Annex “H” Vincent Patrick Mataban January 29, 2014 in the: 1.)
in the Provincial Capitol of
Judicial Laguna, Sta. Cruz, Laguna,
Affidavit) 2.) City Hall, Calamba City
Laguna, and 3.) to this
Honorable Court. To also
prove compliance with the
jurisdictional requirements
of this Honorable Court.
“E” Promissory Note No. To prove that Spouses
(marked as 174-446-00079245-0 Carole May V. Haurisjah
Annex “A” and Henki Haurisjah
in the obtained a loan from
Judicial petitioner Metrobank.
Affidavit)
F Promissory Note No. -same as above-
(marked as 174-446-000-79245-0
Annex “B”
in the
Judicial
Affidavit)
“G” Promissory Note No. -same as above-
(marked as 174-446-000-770656
Annex “C”

2
 in the
Judicial
Affidavit)
“H” Metrohome Loan and To prove that, in order to
(marked as Mortgage Agreement secure their loan
Annex “D” obligations, Spouses
in the Haurisjah executed a
Judicial Metrohome Loan and
Affidavit) Mortgage Agreement in
favor of petitioner
Metrobank over the real
property covered by
Transfer Certificate of Title
No. T-755449.
“J” Petition for Extra-Judicial To prove that petitioner
(marked as Foreclosure Metrobank initiated an
Annex “F” Extra Judicial Foreclosure
in the over the real property
Judicial covered by Transfer
Affidavit) Certificate of Title No. T-
755449.
“I” Notice of Sheriff’s Sale To prove that the Office of
(marked as dated May 15, 2013 the Clerk of Court and Ex-
Annex “G” Officio Sheriff of Calmba
in the City Laguna set the public
Judicial auction of the real property
Affidavit) covered by Transfer
Certificate of Title No. T-
755449 on June 13, 2013.
“K” Certificate of Posting To prove that the Notice of
(marked as dated May 20, 2013 Extra Judicial Sale was
Annex “H” posted in three (3)
in the conspicuous places where
Judicial the subject property is
Affidavit) located and where the
auction sale took place.
“L” Affidavit of Publication To prove that the Notice of
(marked as Extra Judicial Sale was
Annex “I” in published in Free Times
the Judicial Journal, a newspaper of
Affidavit) general circulation.
“M” Certificate of Sale dated To prove that petitioner
(marked as June 26, 2013 Metrobank participated in
Annex “J” in the public auction sale
the Judicial scheduled on June 13,
Affidavit) 2013 and was adjudged as
the winning bidder for the
property covered by

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 Transfer Certificate of Title
No. T-755449 of the
Registry of Deeds of
Calamba City Laguna.
“N” Demand Letter dated To prove that petitioner sent
(marked as December 13, 2013 a written demand to
Annex “K” Spouses Haurisjah as well
in the as all those claiming rights
Judicial under them, to voluntarily
Affidavit) surrender and vacate
possession of the subject
real property, otherwise,
petitioner Metrobank will be
constrained to file
appropriate petitioner in
court to place it in
possession of the same.
“N-1” and Registry receipt no. To prove that the demand
“N-2” 044939 and 044940 letter was sent to Spouses
(marked as Haurisjah via registered
Annex “K-1” mail at their last known and
and “K-2” in given addresses.
the Judicial
Affidavit)
“O” Judicial Affidavit of Ma. To prove the testimony of
Criselda Villegas petitioner Metrobank’s lone
witness in the person of
Ma. Criselda Villegas.
“O-1” Signature of Ma. Criselda To prove the genuiness and
Villegas due execution of the
Judicial Affidavit of Ma.
Criselda Villegas.

WHEREFORE, it is respectfully prayed of this Honorable

Court that the foregoing exhibits be admitted for the purposes for
which the same are being offered and as part of the testimony of
petitioner Metrobank’s lone witness, MA. CRISELDA
VILLEGAS,HEAD OF RHE Consumer Lending Business Center
under its Countryside Consumer Lending Division.

Pasig City for Calamba City, Laguna, May 19, 2014.

CORPUZ EJERCITO MACASAET RIVERA

& CORPUZ LAW OFFICES
Counsel for Petitioner
16/F U1602 The Centerpoint Building
Doña Julia Vargas Avenue corner Garnet Road,

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 Ortigas Center, Pasig City
Philippines 1605
Tel Nos. (+632) 638-8658, (+632) 638-4602
Facsimile No. (+632) 637-2148

By:

NOEL FRANCIS N. RIVERA

IBP NO. 948308- 01/02/2014– Pangasinan
PTR NO. 9443812-1/03/2014- Pasig City
Roll No. 41766
MCLE Certificate of Compliance No. IV-0005327
Issued on 27 March 2012

RAMON GERARD S. HERNANDEZ

Roll No. 61347
PTR NO. 9443815/01-03-14 Pasig City
IBP Lifetime No. 010787/ Batangas City
MCLE Compliance No.: IV-0012329
Issued on February 7, 2013