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    Motion To Amend Complaint

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    Maestro Lazaro
    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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    Motion To Amend Complaint

    Uploaded by

    Maestro Lazaro
    1K views2 pages
    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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    Motion to Amend Complaint

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    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.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    1K views2 pages

    Motion To Amend Complaint

    Uploaded by

    Maestro Lazaro
    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.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
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    of 2

    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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