Defense Theory:

It is the theory of the defense that spouses Mercedita

Lagdameo and Epifanio Lagdameo are the lawful owner of the
parcels of lands subject to this case by virtue of a Deed of
Donation executed by Oswald Lagdameo and that the act of
donating the said parcels of land was due to the previous
services rendered by spouses defendant since Santiago
Lagdameo and Oswald Lagdameo stayed with them in their
residence and it was spouses defendant who took care of
Santiago Lagdameo when he was already sick and of old age.
Admissions/Stipulations:
1. Will the Plaintiff admit that Defendant Spouses are
presently in possession of the parcels of land subject to
this case
2. Will the Plaintiff admit that a Deed of Donation covering
the parcels of land subject to this case was executed by
Oswald Lagdameo during his lifetime
3. Will the plaintiff admit that the parcels of land was
donated by way of remuneration for the services rendered
by herein spouses defendant to Santiago Lagdameo the
father of Oswald Lagdameo
4. Will the Plaintiff admit that Oswald Lagdameo died single
5. Will the Plaintiff admit that defendant spouses are tenants
of the said parcels of land even before the execution of
the Deed of Donation
6. Will the Plaintiff admit that Santiago Lagdameo and
Epifanio Lagdameo are siblings
7. Will the Plaintiff admit that Oswald Lagdameo is the only
child of Santiago Lagdameo and by virtue of intestate
succession inherited the parcels of land subject of this
case from his father

8. Will the Plaintiff admit that Epifanio Lagdameo is the uncle

of Oswald Lagdameo
9. Will the Plaintiff admit that Santiago Lagdameo and
Oswald Lagdameo during their lifetime and until their
death stayed with defendant spouses in their residence at
Poblacion, Panglao, Bohol
10.
Will Plaintiff admit that it was only in the year 1999
when he first came to Poblacion, Panglao, Bohol in the
residence of defendant spouses and introduce herself as
illegitimate child of Oswald Lagdameo

Documentary Exhibits:
Exhibit 1 Deed of Donation executed by Oswald Lagdameo
and duly notarized by Atty. Jorge Almedilla in the year 1994
Exhibit 2 Death Certificate of Oswald Lagdameo to
substantiate the fact that the Deed of Donation was in fact
executed by Oswald Lagdameo before his Death in the year
2000
Exhibit 3 A Certificate of No Marriage from the National
Statistics Office (NSO) to prove that Oswald Lagdameo died
single
Witnesses:
1. Epifanio Lagdameo defendant
2. Atty. Ruben Almedilla son of Atty. Jorge Almedilla
3. Mr. Perfecto Dima farm worker of defendant spouses
Lagdameo