INDORSEMENT

August 30,2018

A letter Request for Payment of Just Compensation was received from

RICARDO J.M. RIVERA LAW OFFICE by Atty. Ricardo J.M. Rivera , Counsel for
PE Domingo & Co., Inc. dated 30th May 2018 requesting for payment of just
compensation before the office of the Honorable Mayor Herbert M. Bautista
relative to a certain lot allegedly owned by the corporation allegedly being used
by the Quezon City Government without prior notice and payment of just
compensation.

The subject property is Lot 48-L of the subdivision plan PSD – 20202
covered by TCT No. RT-77638 in the name of PE Domingo & Co., Inc. located in
Sitio Kumunoy, Brgy. Bagong Silangan, Quezon City. Allegedly, on a portion of
this property about 610m2a covered court and health center was built without
any building permit, without notice and payment of compensation. Their client
through Rosario D. Lacson had earlier written the Honarable Winston T.
Castelo in a letter dated 15 September 2016 asking for just compensation.

As per ocular inspection and verification conducted by the Department of

the Building Official headed by Engineer Conrado Viardo and Carl J. Senador
dated 13th June 2018, the said project was already constructed more than five
(5) years ago under the implementation of the City Engineer’s Office and there
was already a pending dispute between the Barangay and the lot owner.

A perusal of the Transfer Certificate of Title from the Registry of Deeds, it

appears that P.E.Domingo & Co., Inc. has title over the property. However,the
Approved Plan released by the Land Registration Authority reveals that there
was certain Veronica Angeles, et al. who caused the consolidation subdivision
survey which includes Lot 48 – L in the year 1960. The subject lot has been
consolidated together with Lot 48-M, 48-N, & 48-O, PSD-20202 described in
TCT No. 29776 issued in favour of Manila Remnants Co. Inc. as provided in the
herein attached copy of Consolidation Subdivision Plan.

There is a need to determine how Veronica Angeles acquired title over the
Lot 48 – L before indemnifying the person for the use thereof. If she acquired it
through sale, it necessarily follows to inquire whether the sale was valid or not.
For if valid, the present occupants must be the ones to be paid of the just
compensation because they can be considered as purchasers for value in good
faith. But if invalid, it might be paid to P.E.Domingo & Co.
 As to the present occupants of subdivided Lot 48-L, attached herewith
are the certified true copies of their tax declarations. The following owners
according to the tax declaration issued by the Assessor’s Office are as follows:
Tax Declaration No. F-008-03843 – Angeles Serafin Et Al.; Tax Declaration No.
F-008-03844 –Angeles SerafinAt Al.; Tax Decration No. F-008-03845 – Sps.
Marcos Reyes and Adela Gutierrez; Tax Declaration No. F-008-03846 – Serafin
Angeles and Catalina Cayetano; Tax Declaration No. F-008-03847 – De Castro
Luz Et Al.; Tax Declaration No. F-008-03848 - HierasRufino and Raquel
Villasis; Tax Declaration No. F-008-03849 - HierasRufino and Raquel Villasis;
Tax Declaration No. F-008-03850 – HierasRufino and Raquel Villasis; Tax
Declaration No. F-008-03851 – Hieras Rufino and Raquel Villasis; Tax
Declaration No.F-008-0387 – Felipe Buenviaje and Vicente Buenviaje; Tax
Declaration No. F-008-03856 – De Leon Zenaida and Ramon Et Al.; Tax
Declaration No. F-008-03855 – Cayetano Catalina; Tax Declaration No. F-008-
11363 – Sps. Samuel Castelo and Lily Espejo; Tax Declaration No.F-008-03853
– Cayetano Catalina; and Tax Declaration No. F-008-03852 – HierasRamon and
Milagros Hieras.

In view of the foregoing, it is clear that there would be varying claimants

as to the payment of just compensation once made by the Quezon City
Government. It cannot just simply pay to P.E. Domingo & Co. since it appears
that the owner of the property is uncertain. It is proper for P.E.Domingo & Co.
to bring the matter before the proper court to determine the rightful owner
before asking for payment of just compensation.

Respectfully submitted,

CHRISTIAN B. VALENCIA

City Attorney

OFFICE OF THE CITY ATTORNEY (QC)

Counsel for Petitioner
7 Floor, Quezon City Hall Building,
th

Diliman, Quezon City