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October 26, 2017

HON. GIRLIE M. BORREL-YU


Presiding Judge
Branch 35, regional trial Court
Hall of Justice, Ormoc City

Attention: Hon. Clerk of Court Atty. Milreysa Dayandayan

Dear Maam,

Greetings of Peace!

The undersigned is the son of Pacifico Ejercito, who acquired a parcel of land from Socorro
Bahinting Matuguina covered by a Transfer Certificate of Title No. 50262 , who has a pending
case before the Regional Trial Court, Branch 35 in a case docketed as Civil Case No. R-ORM-
08-00057-CV for Quiting of Title, Declaration of Nullity of Documents and Damages. However,
said sale was not annotated in the said title and the latter refused to turn over the possession
of the land to us.

In view thereof, the undersigned wants to exercise his rights of ownership over the said parcel
of land by filing a case against Socorro Bahinting Matuguina, however since the latter has a
pending case before this Honorable Court and to avoid committing forum shopping and litis
pendentia, the undersigned is respectfully asking a copy of the complaint of Remedios Pesquera
Nuevo, et.al., in Civil Case No. R-ORM-08-00057-CV, the answer of the defendants Socorro
Bahinting Matuguina, et.al and the latest Order of this Honorable Court of the said case in
order for me to know if the pending case is connected with the controversy involving the same
parcel of land.

Thank you very much in anticipation of your favorable and immediate action.

Respectfully yours,

QUIRICO G. EJERCITO

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