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Motion To Amend Complaint

This document is a petition filed in the Regional Trial Court of Cabanatuan City, Nueva Ecija regarding the settlement of the intestate estate of Francisco B. Mercado. The petitioners are seeking to add a supplemental pleading to provide details of the zonal value of the subject property, which is an 80-acre land in Barangay Bitas, Cabanatuan City worth Php. 2,913,741,000 according to the Bureau of Internal Revenue. The petitioners are requesting the court to admit this supplemental pleading to add the zonal value of the property to the original petition.

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2K views2 pages

Motion To Amend Complaint

This document is a petition filed in the Regional Trial Court of Cabanatuan City, Nueva Ecija regarding the settlement of the intestate estate of Francisco B. Mercado. The petitioners are seeking to add a supplemental pleading to provide details of the zonal value of the subject property, which is an 80-acre land in Barangay Bitas, Cabanatuan City worth Php. 2,913,741,000 according to the Bureau of Internal Revenue. The petitioners are requesting the court to admit this supplemental pleading to add the zonal value of the property to the original petition.

Uploaded by

Maestro Lazaro
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOC, PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


THIRD JUDICIAL REGION
CABANATUAN CITY

In the Matter of the Settlement


of the Intestate Estate of
Francisco B. Mercado

Special Proceeding No. 54321

Teodora A. Mercado
Saturnina Y. Mercado
Maria A. Mercado
Trinidad M. De Guzman
Jose Y. Mercado
- Petitioners,

x ------------------------------------------------- x

PETITION

Petitioners, through the undersigned counsels and to this


Honorable Court, most respectfully moves to attach a supplemental
pleading in view of the Petition filed last April 25, 2022 in this
matter. This supplemental pleading seeks to add details from the
deficiency in the original pleading with regard to zonal value of the
subject property, as follows:

1. The zonal value of the subject property covered by Transfer


Certificate of Title No. 123456 at the Registry of Deeds of
Cabanatuan City, Nueva Ecija, District I as reflected in the
Bureau of Internal Revenue’s Official Assessment, DEPARTMENT
ORDER NO. 030- 2018 is worth Php. 2, 913, 741, 000. Worth
noting is that the subject property located in Barangay Bitas,
Cabanatuan City, Nueva Ecija is an 80-acre land (323, 749
square meters/ Php. 9,000.00 per square meter)

The supplemental pleading is merely an addition to the


original pleading and does not affect the substantive rights of the
parties. Pertinent provisions of Rule 10 of the Rules of Court
provide as follows:

Section 6. Supplemental pleadings. — Upon motion of a party


the court may, upon reasonable notice and upon such terms as
are just, permit him to serve a supplemental pleading setting
forth transactions, occurrences or events which have happened
since the date of the pleading sought to be supplemented. The
adverse party may plead thereto within ten (10) days from
notice of the order admitting the supplemental pleading. (6a)

Petitioner requests that this Court permit this supplemental


pleading in the interest of accuracy of the pleadings.
The substantial portion of the document reflecting the value
of the property is attached hereto as ANNEX “A”. WHEREFORE,
Petitioner respectfully requests that this Honorable Court grant its
Motion to Admit the Supplemental Pleading to add the zonal value
of the property in the petition.

_______________________. April 28, 2022

REQUEST:

The Clerk of the Court


Justice Hall, Cabanatuan City

Greetings:

Immediately upon receipt hereof, kindly submit the foregoing


Motion to the Clerk of Court of Regional Trial Court, Branch 3,
Cabanatuan City, Nueva Ecija for her consideration, approval and
resolution, with or without respondent’s comment/opposition
thereto.

ANNEX “A”

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