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FOR
BRANCH 56
CITY OF ____________
SPOUSES _____
Plaintiffs,
Civil Case No: MAN-7592
-versus- FOR: INVERSE
CONDEMNATION &/OR
PAYMENT OF JUST
COMPENSATION
CITY __,
Defendant.
X-------------------------- /
REJOINDER
1
compensation should be claimed as plaintiffs cannot
prove with certainty that it was the City of
____________ who cemented said road despite its
allegation;
3
evidence. In effect, Plaintiffs are objecting the admissibility of
the Subdivision Plan.
4
with liberality if the presentation of the
merits of the action ends of substantial
justice will be subserved thereby. The court
may grant a continuance to enable the
amendment to be made.;
5
18. As reiterated, the determination of whether or not
there was indeed taking is a factual issue that can only be
resolved thru the presentation of evidence. If the Plaintiffs
would insist that the rule in the NPC case be applied, with
more reason that there should be a trial held in order to
determine whether or not there was indeed taking which is a
pre-condition before such rule can be applied;
PRAYER
6
WHEREFORE, premises considered, it is most
respectfully prayed that the Honorable Court DENY the Motion
for Partial Summary Judgment.
By:
zzzzzzzzzzz
Roll of Attorney No. 122345
IBP Member No. 1014763 01/04/16 Cebu City
PTR No. 0561424 01/04/2016 ____________ City
MCLE Compliance No.: Exempt-passed the Bar 2015
Copy furnished:
Atty. xxxxxxxxxxx
Counsel for the plaintiffs
Walaa Walaa Cezar & xxxxx Law Office
Rm. 206, xxxxx., Tipolo, ____________ City
EXPLANATION
xxxxxx