MANIFESTATION WITH COMPLETE COMPLIANCE AND OPPOSITION -March 10, 2004- REPUBLIC OF THE PHILIPPINES COURT OF APPEALS MANILA FORMER SECOND DIVISION Republic of the Phlippines Petitioner -vs- CA-G.R. SP No. 70014 REGIONAL TRIAL COURT OF PASAY CITY, Beanch 111, Formerly Presided by Hon. Ernesto A. Reyes ANNCACLETO MADRIGAL ACOPIADO, ANNACLETO MADRIGAL ACOP, PRINCE JULIAN MORDEN TALLANO, REGISTER OF DEEDS OF THE PROVINCE OF BULACAN, AT GUIGUINTO BULACAN, REGISTER OF DEEDS OF RIZAL IN PASIG CITY Respondents x-------------------------------------------------------------------------------------------------x MANIFESTATION WITH COMPLETE COMPLIANCE AND OPPOSITION COME NOW, the private Respondent PRINCE JULIAN MORDEN TALLANO in the above entitled Case, by and through undersigned advocate, Collaborating Legal Counsel, whose Certificate of Appearance has been marked as Annex 1 WITH LEAVE, most respectfully submit to esteem Honorable former Second Division of this Honorable Court, this MANIFESTATION WITH COMPLETE COMPLIANCE AND OPPOSITION TO BASELES ACCUSATIONS OF ATTY. PUNO AND ALTERATED CLAIMS OF THE ACOPIADOS, states and allege: a) That by virtue of the Order of Court of Appeals promulgated on March 10, 2004, in the instant case, in its dispositive portion, the National Bureau of Investigation (NBI/ for brevity) has been tasked to conduct a “fact finding investigation into the true identities of Julian Morden tallano” among others. b) Thus on June 11 , 2004, the private respondent SUBMITTED as duly acknowledged and in fact signed-by Atty. Florencio C. Canlas of the NBI the hereto COMPLIANCE addressed to esteem Honorable Reyanaldo G. Wycoco, General and DOJ under Secretary and NBI Director, together with enumerated twenty three (23) documents as evidentiary proof of “positive identity” of said respondent PRINCE JULIAN MORDEN TALLANO, and the copy of said compliance with the documents appended thereto, are attached hereof as an integral parts, Annexes “1” and 1 to 1 “inclusive Prince Julian Morden Tallano. c) That such compliance of June 11, 2004, had not suffice the required infornmation relevant thereto that cause this time to submit additional documents marked as Annexes 24 and 25 etc “inclusive Prince Julian Morden Tallano” with a SUPLEMENTARY FOR COMPLETE COMPLIANCE of the requirements of the NBI by virtue of the Order of the Court of the Second Division, dated March 10, 2004, d) That may the foregoing suffice to justify compliance by the undersigned advocates for private resspondent, Prince Julian Morden Tallano to the directive in the Order of March 10, 2004, with futher PRAYER for such other relief and remedy as in equity and justice availed of great great great Grand Father King Marikudo of Panay, the King of Tri Visayas Empire; (Annex 24 Family Tree) 3) That a clerical error occured over the registration of my birth.That what had registered as my Birth date and month was November 6, 1946, instead of December 17, 1946. And what appeared in the name as my mother under mother column was Faustina Morden, in lieu of the true name of my mother, Cristina Camacho Morden, beccause such name Faustina was taken from ritual sperstitious belief of my mother’s parents, which was usually adapting by the Filipino Family community with the belief that their sicly child would be easily recuperated whenever they would baptized again such sickly child into such ritual superstitious belief (Annex 25- Death Certificate of Cristina Morden at the age of 51 yrs. old). 4) Besides, that such clerical errors openly finds in the office of the Civil Registrar since the establishment of our democratic government up to the present which could be corrected by counter checking from our baptismal certificate from the Roman Catholic church, particularly, in my case, it was registered and appeared Julian Morden Tallano Born on December 17, 1964, as one of among the legitimate children and only son of the Spouses; Cristina Morden and Benito A. Tallano, (Annex 26 Prince’ Birth Certificate issued by the Office of Civil Registrar, San Jose City, Annex 26-A Baptismal Certificates issued by the Roman Catholic Church and 26-B SSS ID Card and 26-C Ceertification bearing SS. No. 03-38534743, and Comelec Voter’s Registration Ceritificate which was issued in the name of Julian Morden Tallano marked as Annex 26-D, Annex 26-E, and 26-E-1 referring to (2) Joint SwornAffidavit of disinterested persons) while other legitimate children of the aforementioned spouses could be identifies as follows, to wit:
Posted on: Wed, 22 Oct 2014 05:42:10 +0000
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