Professional Documents
Culture Documents
)
City of Cebu
) s.c.
REPLY TO CAPS AND PESS JOINT
COUNTER-AFFIDAVIT
I, DOMINGO, Filipino, of legal age, married and a
resident of Abellana, Cebu City, after having been duly sworn
to in accordance with law hereby depose and state, thus:
1. On April 12, 2013, I, through counsel, received a
copy of the Joint Counter-Affidavit of Cap and Pes, the
respondents of the case Qualified Theft I filed for and in
behalf of my sister Paulina before the Office of the City
Prosecutor of Tacloban, on February 20, 2013;
2. In response to the counter-affidavit of the
respondents, I would like to point out relevant matters, to
wit:
2.1. Paulina is the owner of the agricultural land
designated as Lot No. 004 as her share of the
inheritance from our late father;
2.2. Since the partition sometime in 1970, Paulina
exercised acts of ownership such as paying
taxes thereon as evidenced by Tax Declaration
No. 08-19-0015-00050;
2.3. With that fact, in 2002, Paulina offered me two
(2) hectares of her coconut land as a
compensation for administering her properties
but I declined the same;
2.4. Upon showing interest of having a farm land,
Paulina, through me, sold to Theresa, my
daughter, the two (2) hectares of coconut land
originally offered to me for a consideration of
One Hundred Thousand Pesos (P100,000.00);
however, no Deed of Sale was executed as
it was agreed that Theresa should make a
survey first to determine the boundaries
of the 2-hectare coconut land which the
latter never did;
2.5. Since the sale of the property until 2010, my
daughter appointed me to administer and
manage the 2-hectare coconut land she