Republic of the Philippines

First Judicial Region

REGIONAL TRIAL COURT
Branch 26
San Fernando City, La Union

GLORINA ARELLANO-FIGUEROA,
Plaintiff,

CASE NO. 10005

-versus- For: Recovery of Possession with Prayer
for Preliminary Injunction and
Damages

LEONIDA CALUB-DORIA,
Defendant.
x-----------------------------------------------------x

COMMENT ON THE MOTION OF THE DEFENDANT

PLAINTIFF through the undersigned counsel and to this Honorable Court

respectfully states that:

1. Herein plaintiff received a copy of defendant’s motion dated June 6, 2019 and
received on June 14, 2019 to include the property covered by OCT FP-7414 in the
relocation survey which will be conducted by the designated Geodetic Engineer of the
DENR; and

2. The relocation survey subject of the motion is pursuant to the Honorable Court’s
order dated May 30, 2019 directing the DENR to conduct a relocation survey involving
properties covered by Tax Declaration No. 1486 (OCT No. 025-2010001486), OCT
FP-5080, Tax Declaration No.52264 and OCT FP-6021.

WHEREFORE, premises considered, herein plaintiff joins in respectfully praying for

the Honorable Court that the property covered by OCT FP-7414 (Tax Declaration No.
2010-03-0001-01891) in the name of Glorina A. Figueroa (plaintiff) be included in the
relocation survey to be conducted by the designated Geodetic Engineer of the DENR.
Comment on the Motion by Defendant; re: Civil Case No. 10005 Page 1 of 2
(For: Recovery of Possession with Prayer for Preliminary Injunction and Damages)
 City of San Fernando, La Union, _________________.

MOSUELA, GONZALES & ASSOCIATES LAW OFFICES

Counsel for the Plaintiff
NORTESURLU Bldg., Purok 3, Sevilla
San Fernando City, La Union
By:

JAIME C. GONZALES, JR.

Roll No. 68552, May 29, 2017
IBP O.R. No. 098528, January 4, 2019 (LU Chapter)
PTR No. LU 3411669A, January 4, 2019
MCLE Comp. No. VI-0007263, valid until April 14, 2022

COPY FURNISHED: (by registered mail with return card due to distance of office and lack of delivery personnel)

ATTY. AURORA P. SANGLAY

2/F METRO SAN FERNANDO CITY WATER DISTRICT BLDG.

SAN FERNANDO CITY, 2500 LA UNION

Comment on the Motion by Defendant; re: Civil Case No. 10005 Page 2 of 2
(For: Recovery of Possession with Prayer for Preliminary Injunction and Damages)