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Republic of the PhilippinesOFFICE OF COMMUNITY ENVIRONTMENT AND NATURAL RESOURCES

Pasonanca, Zamboanga City

MOTION FOR RECONSIDERATION

COMES NOW the applicant Ms. Roshielle Sotto Mercado, by the undersigned

counsel, and unto this Honorable Institution, respectfully alleges:

1. That the City Director of Community Environment and Natural Resources Officealso known as CENRO Denied the application due to the grounds:

i. That the First person who took possession of the lots is different from thepersons presently applying.

ii.At the time of first possession, the lots that have applied were not yet declaredalienable and disposable by the office.

The grounds adduced in this institution is insufficient to justify the said judgment.That said judgment fails to tender an issue, refers to the following matters, to wit:

1. Those who by themselves or through their predecessors - in- interest have been inopen, continuous, exclusive, and notorious possession and occupation of alienable

and disposable lands of the public domain, under a bona fide claim of acquisition ofownership, since June 12, 1945, immediately preceding the filing of the application

for confirmation of title, except when prevented by war or force majeure. Those shall be conclusively presumed to have performed all the conditions essential to a

government grant and shall be entitled to a certificate of title under the provisions of

this chapter. (As amended by P.D.1073).

2. Under Section 48 (b) of Commonwealth Act No. 141, in order to qualify for a grant,the possession of the land should be at least 30 years of open and continuouspossession in the concept of an owner. In the computation of the 30-year period of

open and continuous possession in concept of owner, the possession of the land whileit was still inalienable forest land, or before it was declared alienable and disposable

land of the public domain, should be excluded.

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3. The essential requisites to qualify the applicant under paragraph Section 48 (b) of the

Public Land Law as amended by Republic Act 1942, approved June 22, 1957 and byP.D 1073 are:

i.

That he must be a Filipino citizen,ii. That the land claimed by him is a public agricultural land,iii.That he and his predecessors-in-interest have been in open, continuous,

exclusive and notorious possession of the same under a bona fide claim ofownership since June 12, 1945 or earlier.

In order that all matters in this action may be completely determined that all the saidrequirements needed for the application for a homestead patent was completely acquired.

WHEREFORE, it is respectfully prayed for a Motion for Reconsideration be Granted.

Counsel for Applicant:

ATTY:OFFICE:

ROLL NO.IBP LIFETIME ROLL NO:

PTR NO:MCLE COMPLIANCE NO: