Republic of Philippines
SUPREME COURT
Supreme Court Building
Padre Faura Street, Ermita, Manila City
HEIRS OF HERMOGENES REYES
RODRIGUEZ, AND VICTORIA MALUBAY RODRIGUEZ
Administratrix / Sole Heir Represented by REINDEL
RODRIGUEZ, Son and Holder of Special Power of Atty.
And Elda Frago Malate, holder of Deed of Sale from
Victoria Malubay Rodriguez
Complainant’s / Applicant’s
“ Case No. SPEC.PROC. NO. IR-
1110
5TH JUDICIAL REGION, RTC
BRANCH 34, IRIGA CITY AND
ENTRY OF JUDGEMENT DATED
SEPTEMBER 21, 2004 AT
SUPREME COURT COVERED BY
G.R. NO. 163695 “.
- VERSUS -
MARICAR ASILO VIVERO, ET AL
Punong Barangay
Barangay Pinagbuhatan, Pasig City
Respondent’s
x----------------------------/
HON. ALEXANDER G.GESMUNDO
Chief Justice
4th Floor Supreme Court Building
Padre Faura Street, Ermita, Manila City
DIRECT REQUEST ON OUR APPLICATION FOR
WRIT OF EXECUTION AND DEMOLITION AND
SIMULTANEOUSLY POSSESSION ORDER
Complainant’s / Applicant’s, with the supervision by the
undersigned counsel and unto the Office of the HONORABLE
ALEXANDER G. GESMUNDO, Chief Justice, Supreme Court, Padre
Faura Street, Ermita, Manila City, respectfully alleges:
JURISDICTIONAL FACTS
1. This is an action lodged this Honorable Office for said Office to
initiate immediate issuance what We are applying for in
connection with the Supreme Court, Manila, Third Division,
Notice, signed by authority of the Court Hon. Misael Domingo
C. Battung III, issued on October 10, 2022 ( See attached
photocopy of said Notice marked as Annex “ A “), of in spite
of the said Notice and Entry of Judgment dated September
21, 2004 copy hereto attached marked as Annex “ B “),
Punong Barangay Maricar Asilo Vivero of Pinagbuhatan,
Pasig City, ignore said documents and make her wrong
doing by not respect the lawful order, and she made her
action to deployed all of her personnel that called
Barangay Police Officers in implementing / Conducting
Destructions, of all tarpaulin that we, established and / or
erected thereat, the herein Lot portion of PSU-2031 ( See
attached photocopy of LRA Certification marked as Annex
“ C “), and portion of Transfer Certificate of Title
No.12022, ( See attached photocopy of Transfer Certificate
of Title No. 12022, issued on May 28, 1977, marked as
Annex “ D “), and located at Nagpayong, Pinagbuhatan,
Pasig City, more particularly described as follows to wit;
TECHNICAL DESCRIPTION
Portion of Psu-2031, Dated August 5, 1992., Transfer Certificate of
Title No. 12022, issued May 28, 1977 And Portion of Parcel I, and the
required Tie Point is at Binondo Church, Manila, Pursuant to Section
2, of Presidential Decree No. 1143, dated May 28, 1977,
CORNER’S LATITUDE LONGITUDE DISTANCE
1 14-32-32-N 121-06-00-E 154.97 M.
2 14-32-28-N 121-06-04-E 155.49 M.
3 14-32-31-N 121-06-06-E 94.81 M.
4 14-32-29-N 121-06-08-E 97.70 M.
5 14-32-24-N 121-06-03-E 196.74 M.
6 14-32-25-N 121-06-03-E 25.45 M.
7 14-32-24-N 121-06-02-E 38.16 M.
8 14-32-28-N 121-05-57-E 191.81 M
Containing an Area of 41,533.92,Square Meters, More or
Less., Tie line from surveyed corner “ 1 “ of Lot to Binondo
Church, Manila, 14-36-00-E, LATITUDE, 120-58-27-E.
LONGITUDE, distance 14,947.51 METERS, ( Please see attached
Survey Plan, marked as Annex “ E “);
2. That Complainant’s / Applicant’s, are have a Deed of Sale
hereto attached marked as Annex “ F “), from Victoria
Malubay Rodriguez, the only administratrix / Sole Heir of
deceased Hermogenes Reyes Rodriguez pursuant to Spec.
Proc. No. IR-1110, Dated February 9, 1994 marked as Annex “
G “), and Certificate of Finality dated March 28, 1994 marked as
Annex “ H “);
PRAYER
WHEREFORE, all told, it is respectfully prayed to the Honorable
Alexander G. Gesmundo, Supreme Court Chief Justice to appoint
the particularly the Presiding Judge, of any Branch of, Regional Trial
Court, of any Judicial Region, in Quezon City, Hall of Justice, and / or
Caloocan City, Philippines. For the reason that Court of Iriga City is
very far from the location site of the land is too expensive, other reliefs
and remedies as are just and equitable under the premises are
likewise prayed for.”
This _______ day of August 2023, at Manila City for
Caloocan City, Philippines.
REINDEL RODRIGUEZ VICTORIA M. RODRIGUES
Seller /Attorney-In-Fact Seller / Administratrix / Sole Heir
TIN_____________________ TIN________________________
FOR AN IN BEHALF OF THE OFFICERS / BOARD OF DIRECTORS
AND MEMBERS IN PARTICULARS, I SIGNED;
ELDA FRAGO MALATE, ET AL
Buyer / President and Chairman of the Board
Far East Community Subdivision-Home Owners Association, Inc.
SUBSCRIBED AND SWORN TO BEFORE ME, this ______day of
August 2023 at Manila City for Caloocan City, Philippines,
Complainant’s / Applicant’s is exhibiting to me their personal identity
shown above below their names and that the preparation of this
instrument is under my full supervisions and it is recommended for
submittal.
Notary Public
Doc. No. _______;
Page No. _______;
Book No. _______;
Series of 2023
