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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


FIRST JUDICIAL REGION
BRANCH __
LAOAG, ILOCOS NORTE

REPUBLIC OF THE
PHILIPPINES, represented by
the Department of Public
Works and Highways (DPWH),
Plaintiff,

-versus- Civil Case No. B-10182


For: Expropriation

JUAN VALDEZ and CLETO


DALUDADO,
Defendants.
x--------------------------------------x

URGENT MOTION FOR


THE ISSUANCE OF A WRIT OF POSSESSION

Plaintiff REPUBLIC OF THE PHILIPPINES, represented by


the Department of Public Works and Highways (DPWH), through
the Office of the Solicitor General (OSG), respectfully states:

1. Sometime this February 2019, the DPWH deposited


before this Honorable Court Land Bank Check No. 0000805586
with amount of Php2,965,000.00 representing 100% zonal
valuation of the subject properties. A photocopy of the is
attached as Annex “A.”

2. With the foregoing, plaintiff respectfully moves that


this Honorable Court SET a hearing for the presentation of
defendants’ proof of identity and ownership of the subject lot
and that at said hearing:

(a) Defendant be directed to submit its Board


Resolution showing its authorized
representative to appear in the above-
captioned case and receive said check, as well
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COMPLAINT
DPWH v. Laguna Properties Holdings, Inc.,
Civil Case No. ______________
x----------------------------------------------x

as proof of its Articles of Incorporation,


ownership of the subject lots, and updated
payment of all requisite taxes and fees to the
relevant local and national government
agencies, including but not limited to real
property taxes on the subject lots and
improvements.

(b) Subject to clearance from plaintiff of


defendant’s satisfaction or completion of the
above-requirements in accordance with
Section 6 of Republic Act No. 10752 and its
IRR, and Commission on Audit requirements,
release the treasury check deposited with this
Honorable Court to the defendant, or its
authorized representative;

(c) thereafter, for this Honorable Court to ISSUE


an order of expropriation placing said lots in
plaintiff’s possession and directing the
Register of Deeds to register and annotate the
Writ of Possession issued by this Honorable
Court in the corresponding Certificate of Title,
the Primary Entry Book, and the Registration
Book;

Other forms of relief, just and equitable under the


premises, are likewise prayed for.

Makati City for Binan, Laguna, February 26, 2019.

JOSE C. CALIDA
Solicitor General
Roll No. 24852
IBP Lifetime Member No. 015360, 08-08-16
MCLE Exemption No. VI-000016, 9-28-16

NYRIAM SUSAN O. SEDILLO-HERNANDEZ


Assistant Solicitor General
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COMPLAINT
DPWH v. Laguna Properties Holdings, Inc.,
Civil Case No. ______________
x----------------------------------------------x

Roll No. 35338


IBP Lifetime Member No. 07708, 08-13-08
MCLE Compliance No. V-0008885, 07-01-15

MARLON P. BOSANTOG
Associate Solicitor
Roll No. 59094
IBP (Lifetime)No.013966; 06-30-2015
MCLE Compliance No. V-00008845; 07-01-2015

OFFICE OF THE SOLICITOR GENERAL


134 Amorsolo Street, LegaspiVillage, MakatiCity
Tel. No. 817-9836; E-mail: docket@osg.gov.ph

NOTICE OF HEARING