LETTER-COMPLAINT
Blk 4, Lot
14 Sappire St.,
Palmera
Hills IIE Subd.,
Taytay,
Rizal
December 11,
2014
THE HON. CONCHITA CARPIO-MORALES,
Ombudsman
Ombudsman
Building, Agham Road, North Triangle
Diliman,
Quezon City
Dear
Ombudsman Morales:
I am LAOAG
A.PARAS, 66 years old, married and a resident at the above address. I was
constrained to file another complaint in relation to my former letter-complaint
filed on May 28, 2012 with the Ombudsman after I consolidated all pertinent
documents in respect of my adverse possession of property located at the
aforesaid address with TCT No. 599677 in the name of fictitious couple, Carlos
Mangona and Cheryl Ann Mangona. Copy of the said letter-complaint is hereto
attached.
I acquired
the said property by ADVERSE POSSESSION since Year 2000. After residing thereat
for 12 years I filed with the Registry of Deeds-Binangonan a Petition for
ADVERSE CLAIM under Section 70 of P.D. 1529 for issuance of an Original
Certificate of Title (OCT) in my favor on September 5, 2012 which was annotated
at the back of TCT No. 599677.
On December
5, 2014, a Friday, my family was threatened by Sheriff IV Ma. Teresa Leis to be
evicted from our home within five (5) days from said date if no action is filed
by Laoag Paras to appeal the Decision of Rizal RTC Br 98 Judge Ma. Consejo
Ignalaga on September 19, 2013, granting petitioner BALIKATAN’s application of
a writ of possession of property located at the above address.
On her
decision, Judge Ignalaga subsequently issued a Certificate of Sale of TCT No. 599677 “…on July 22,
2010 and registered with the Office of Registry of Deeds for Marikina,
Metro Manila on March 31, 2009 under Entry No. 2012000398.
On May 4, 2009, a demand letter was sent by petitioner’s counsel to Carlos
Mangona, Jr. to vacate the subject property but failed to comply.”
On the same
date of July 22, 2010, another Certificate of Sale of TCT No. 599677
but distinct from the one issued by Judge Ignalaga, was also issued to
Balikatan Property Holdings, Inc. by the Antipolo City Clerk of Court and
Ex-Officio Sheriff Joselita C. Malibago-Santos, prepared and verified by
Rolando P.Palomares, Sheriff-in-Charge, and noted by Executive Judge Ruth C.
Santos. In its footnote of the 2-page certificate of sale, spouses Carlos
Mangona and Cheryl Ann Mangona were allegedly copy furnished thru mail dated
August 22, 2010.
On page 5 of
TCT No. 599677, Entry No. 2012000398 dated January 13, 2012 2:27 pm, there
appears an annotation “Certificate of
Sale: Issued by the Sheriff of Regional Trial Court, Antipolo City, in favor of
Balikatan Property Holdings, Inc. as the highest bidder, for the sum of Phl
629,129.36 subject to redemption within a period of one (1) year from and after
the date of registration hereof in accordance with the Certificate of Sale
dated July 22, 2010. Federico M. Cas, Registrar of Deeds” for Registry of
Deeds-Binangonan, Binangonan, Rizal.
On the same
page 5 of TCT No. 599677 after 2 spaces below is written, Entry No. 2012008124
dated September 5, 2012 2:15 pm – “Consulta
raised by registrant: Memoramdum: October 17, 2012, 10:38 am Re: Notice of Adverse
Claim under Entry No. 2012008124 dated 09/05/2012, to the Administrator,
LRA. Edgar H. Naig, Uploading Clerk, Registry of Deeds.” (emphasis supplied)
In its
footnote – “This title is subject of an on-going transaction with Entry No.
2012008124 and Entry Date: Sept 5, 2012 2:15PM” OR No. 1005084346; OR Date:May
26, 2013; Amt Paid: 311.54. Issued at Registry of Deeds of Province of Rizal.
Requested by LAOAG PARAS.
It is very
clear therefore, that the Notice to Vacate which was served to Laoag Paras’
family by Sheriff IV Maria Teresa S. Leis based on the Decision of Presiding
Judge of RTC Br 98, Taytay, Rizal, Ma. Consejo Ignalaga was SPURIOUS?
Precisely,
Balikatan is making this PRETEXT against Laoag Paras and other homeowners in
conspire with Sheriff Leis in able for Paras to violate Section 5, Rule 7 of
the Rules of Court, otherwise, known as the Forum Shopping Law, when he will
supposedly files LIS PENDENS with the Ignalaga court?
Double
selling of low-cost housing a la Delfin Lee by Balikatan is rampant in Rizal
province.
I pray that
Your Honor finds my complaint of conspiracy against my family by Balikatan and
Taytay RTC Br 98 meritorious for investigation and action.
My contact details
are:
1.
Cellphone
No. 0908 688 4773
2.
Landline
No. (02) 557 3478
3.
leoparas.blogspot.com
Very truly
yours,
LAOAG
A.PARAS, Complainant
Attachment: 200
pages of documentary evidence including this 3-page letter-complaint.
IN
WITNESS WHEREOF, I have hereunto set my hand this ___day of December, 2014
at Taytay, Rizal.
LAOAG A.PARAS
Affiant
SUBSCRIBED
AND SWORN TO before me this ___ day of _________ , in Taytay, Rizal,
affiant who personally appeared and affixed his signature and exhibited before
me as competent evidence of identification _________ with No.
______________________ .
Notary
Public
Doc. No. ___
Page No. ___
Book No. ___
Series of
20__
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